Olsen Laboratories, Inc

Text (OCR of the scan at left; may contain errors)

IN THE MATTER OF OLSEN LABORATORIES , INC., ET AL.

CONSENT ORDER, ETe., IN REGARD TO ALLEGED VIOLATIONOF SECS. 5 AND \2 OF THE FEDERAL TRADE COMMISSION ACT Feb. 6, 1995 Docket 3556. Complaint, Feb. 1995--Decision, This consent order prohibits, among other things. two Kansas-based finns and an offcial from making false claims for Eez-Away, an arhritis pain treatment, or similar products. The consent order requires the respondents to possess competent and reliable scientific evidence before making any health or medical benefit claim for any personal or household product or service they market in the future; requires them to clearly identify any future infomercial that they disseminate as paid advertising; and prohibits them from misusing endorsements.

Appearances For the Commission: Lesley Anne Fair and Beth M. Grossman. Olsson, Frank Weeda, For the respondents: Tish Pahl, Washington, D.

COMPLAINT The Federal Trade Commission, having reason to believe that Olsen Laboratories Inc. and Richfield Distributors, Inc., corporations, and Peter F. Olsen, individually and as an officer and director of said corporations ("respondents ), have violated the provisions of the Federal Trade Commission Act, and it appearing to the Commission that a proceeding by it in respect thereof would be in the public interest, alleges:

PARAGRAPH 1. Respondent Olsen Laboratories, Inc. is a Delaware corporation, with its principal office and place of business at 11088 Alhambra Street, Leawood, Kansas. New York Respondent Richfield Distributors, Inc. is a corporation, with its principal offce and place of business at 11088 Alhambra Street, Leawood, Kansas.

Respondent Peter F. Olsen is an offcer and director of Olsen Laboratories, Inc. and Richfield Distributors, Inc. Individually or in Complaint J 19 FTC. concert with others, he formulates, directs and controls the acts and practices of Olsen Laboratories, Inc. and Richfield Distributors, Inc., including the acts and practices alleged in this complaint. His principal office and place of business is the same as that of the corporate respondents.

PAR. 2. Respondents have manufactured, advertised, labeled offered for sale, sold, and distributed external analgesics, including Eez-Away Relief, to consumers. These products are "drugs " within the meaning of Sections 12 and 15 of the Federal Trade Commission Act.

PAR. 3. The acts and practices of respondents alleged in this complaint have been in or affecting commerce, as "commerce " is defined in Section 4 of the Federal Trade Commission Act. PAR. 4. Respondents have disseminated or have caused to be disseminated advertisements and promotional materials for Eez- Away Relief, including but not necessarily limited to the attached Exhibits A and B , transcriptions of the program-length television commercials (or "infomercials ) entitled, respectively, "30 Minutes and "Eez-Away the Pain. " The aforesaid advertisements contain the following statements and depictions:

A. JCLIA GABOR (Consumer endorser); "It is a miracle drug and I'm, I, uh I know it is. " (Exhibit A, p. 1) B. SHELLY DUVALL (Anchor): "And we ll tell you about a recent breakthrough in the treatment of arthritis that has brought new hope to many chronic arthritis sufferers. Much new work is being done, and the good news is there s hope. Later on we ll te1J you about a new arthritis remedy that could provide the much sought-after relief from pain. So jf you or someone you love has arthritis, muscle or joint pain, please, stay tuned. The pain may soon be over. " (Exhibit A, e. MARIE GIORDANO (Consumer endorser): "Well, I had my back, lower back pain for about three years, and it was just really so bad I couldn t walk. I had to take time off from work, and I was laid up for reatly two weeks at home on my back flat. I tried many things, and nothing really worked. " (Exhibit A, pp. 4- Exhibit B, p. 3) When I first applied it, I had very little hope that anything was going to help me. I have arthritis, and I figured that was it. But it really made me comfortable after the pain was gone. I felt 'aahhh. '" (Exhibit A , p. 7: Exhibit B, p. 5) D. DAVID FL YNI' (Anchor): "We recently learned that some exciting new research is being done on a new type of pain reliever. We wanted to find out more.

, OLSEN LABORATORIES, INe. , ET AL 163 161 Complain! SHELLY DUVALL "We spoke wirh chiropractor Dr. John Panicali. We learned that he took par in a research study of a new arthritis treatment that's been getting a lot of attention. " (Exhibit A, p. 5) E. SHELL Y DUVALL ' The new product tested by Dr. Panicali is called Eez- Away Relief.' When we spoke with him, he had been dispensing it for several months. And what were his findings?" (Exhibit A , p. 5) DR. JOHN PANICALI (Chiropractor): "Patients thar we ve been working with for many months now have reached a certain point of relief, but at that point, we reached a stone wall. So we tried this product on those patients. And patients are cornng back and telling me Doc, I don t know what that stuff was, but I'm getting further motion, I'm doing things now I never did before, for the first tjme I'm climbing stairs without pain, I can actually look over my shoulder when I back out of my driveway.'" (Exhibit A , p. 6; Exhibit B , p. 4) F. DR. PANICALI: "The unique thing about Eez-Away Relief is that it absorbs through the skin surface at a faster rate than other products. But what's also unique is that once it's at thcjoint surface, it binds to tissues, ligaments and fats and stays within the joint for a much longer period of time, affording relief for a longer period, and pain-free motion. " (Exhibit A, p. 6) G. JOHN BOISE (Consumer endorser): " I tried it, every couple of hours for about three or four days, and the pain just disappeared completely. And so now I've been using it like once a week, and the pain just stays away; and I can stan moving my hands a lot better than I ever used to be able to move them. " (Exhibit A , p. 7; Exhibit B , p. 5) I'vc been trying a lot of different medications over the past two or three years trying to eliminate anhritis in my joints, and since 1 used Eez-A way, it just worked and it s like a miracle. " (Exhihit A , p. 22; Exhibit B , p. 20) H. DA VID FLYNN: "ShelJy, these results are very impressive, but is it safe? Has it been properly tested?"

SHELLY DUVALL: "Absolutely, David. It s met all the FDA requirements and it contains only ingredients that are recognized by the FDA itself to be both safe and effective for pain relief."

FLYNN: "But what s the big secret? Can we now buy it in stores?" DUY ALL: "Til now the only way to get some was to see one of the testing physicians like Dr. PanicaJi. Unfortunately, it's still not available in stores. (Exhibit A , pp. 7- 1. VOICE-OYER: "This breakthrough pain reliever is so new, so revolutionary, that it s not yet avaiJablc in stores. " (Exhibit A, pp. 9, 19 & 25; Exhibit B, pp. 6, 16 & 23) J. VOICE-OYER: "At last, you won t have to live with that nagging pain in your hands, back, arms, elbows, knees and other joints. With Eez-Away, you regain the vitCility you once had to enjoy life again with mobility and freedom. Simple pleasures like biking, fishing, tennis, and fun with your family will a1l return once the pain is gone. " (Exhibit A , pp. 9 , 20 & 26; Exhibit B , pp. 7 17 & 23-24) K. VOICE-OYER: "So if you have arthritis that won t go away, order Eez- Away now. It s guaranteed, so you have nothing to lose but the pain." (Exhibit A pp. 11 22 & 28; Exhibit B , pp. 9 19 & 26) , pp.

Complain! 119 F.T. L. UNIDENTIFIED CONSUMER ENDORSER: " I use it for about ten minutes, all over, and it has no odor. And I got dressed, and about ten minutes later I -- there was no pain. It was like I -- it was hard to believe that there was actually no pain. " (Exhibit A, p. 12) M. Depiction: Close up of assorted over+the-counter medications, including Bufferin, Mineral Ice, Excedrin, Ben Gay, Heet, ley Hot. Tylenol, and Advil. DAVID FLYNN: "This is just a sampling of some of the pain remedies that we found in our local drugstore. There are literally aisles fu!! of pils and ointments that claim to relieve pain. Shelly, what makes Eez-Away so different?" SHELLY DUV ALL: "Well, the people that we spoke to, David, said simply that these remedies just don t work the way that Eez-A way docs. They've been searching for relief, they finally found it with this product. " (Exhibit A, p. 13) N. DAVID FLYNN: "Next we have a woman who was crippled by arthritis pain until she found Eez-Away.

SHELLY DUVALL: "This is the true story offee Sanchez. " (Exhibit A, p. 13) SHELLY DUVALL: ". . . a few short months ago she was suffering from severe chronic arthritis. " (Exhibit A , p. 13) SHELLY DUVALL: "Dee was in excruciating pain. . . . " (Exhibit A, p. 14) DEE SANCHEZ (Consumer endorser): "I had tried just about every type of rub, every type of cream that came on the market. I'd go buy it and give it a try, I'd tried a few, uh, I had an aunt that even made up some home remedies that were supposed to be from the old country that would help my arthritis and so forth. And nothing was doing any good.

SHELL Y DUV ALL (Exhibit A)!EILEEN FULTON (Exhibit B): "Then one day Dee s luck changed. Dee (She) was introduced to new Eez-Away Relief. The results were immediate and dramatic." (Exhibit A , pp. 14+ 15; Exhibit B 12- 13) 0. SHELLY DUV ALL: " (WJe have seen this same story again and again with other people. People who had lost mobility, stopped being active because of the pain, They were able to get up and enjoy life with the help of Eez-Away, " (Exhibit , p. 16) P. SHELLY DUV ALL: "Another physician taking part in the Eez-Away test program was Dr. Thomas Jackson ofVero Beach, Florida. He s a cardiologist with a special concem for the effects of arthritis on a person s general health. " (Exhibit , p. 16) DR. THOMAS JACKSON (Cardiologist): "Minnie Benjamin has juvenile rheumatoid arthritis. Now juvenile rheumatoid arthritis begins in the teenage years. It can begin in childhood, She s had it for a long time. When I saw Minnie, she had a problem with her ankle and with her wrist and was unable to walk properly, Jimping, and had a splint on her hand. I gave her Eez-Away because I had used it in a few other instances. I mentioned to her to use it according to the directions. She came back the next morning, the splint was off and she wasn t limping, So I was really impressed with that overnight response. You know, it's rather fabulous, rather amazing to say the least.

MINNfE BENJAMIN: "You see I'm not wearing my brace. And I hope I don have to put it on anymore because the Eez-Away has helped me get rid of it. (Exhibil A, p. 17: Exhibit B , pp. 14- 15) Q. PHIL SABATO (Consumer endorser): "With this product, Eez-Away, I'm back to normal. I can walk again, I could bend down without being in pain, I could OLSEN LABORATORIES, INe. , ET AL 165 161 Complaint climb up the ladder. I don t have the pain that I did in the past. " (Exhibit A, p. 18; Exhibit B , p. 15) R. SANDY DUV ALL (Consumer endorser): "After using Eez-Away, I don have any problems. I have no pain, and I don t think about it any more. It's really, , it s like a new lease on life. " (Exhibit A, p. 18; Exhibit B , p. 15) I used it three or four times the first day. And by the third time I put it on, I had absolutely no pain in my hand at all." (Exhibit A, p. 24; Exhibit B , p. 22) S. DAVID FLYN: "Needless to say. we are impressed with this new product so we spoke with the person who developed this revolutionary new pain remedy. (Exhibit A, p. 23) (EILEEN FUTON: "Now let s meet the man who developed this revolutionary pain remedy, Mr. Peter Olsen. " (Exhibit B , p. 21)) PETER OLSEN: "When we first developed Eez-Away, we knew it would relieve a lot of pain, and it has. Even doctors are amazed. As a matter of fact, we so confident that we actually have a guarantee. Use the product for 30 days. If you re not satisfied, we l! return your money, " (Exhibit A, p. 23; Exhibit B , p. 21) PAR. 5. Through the use of the statements and depictions contained in the advertisements referred to in paragraph four, including but not necessarily limited to the advertisements attached as Exhibits A and B , respondents have represented, directly or by implication, that Eez-Away Relief is a new and unique product that is a major breakthrough in the treatment of arthritis pain. PAR. 6. In truth and in fact, Eez-Away Relief is not a new and unique product that is a major breakthrough in the treatment of arthritis pain. Therefore, the representation set forth in paragraph five was, and is, false and misleading.

PAR. 7. Through the use of the statements and depictions contained in the advertisements referred to in paragraph four including but not necessarily limited to the advertisement attached as Exhibit A, respondents have represented, directly or by implication that scientific research proves that Eez-A way Relief is effective for the rapid elimination of severe pain and physicai disabilities caused by arthritis.

PAR. 8. In truth and in fact, scientific research does not prove that Eez-Away Relief is effective for the rapid elimination of severe pain and physical disabilities caused by arthritis. Therefore, the representation set forth in paragraph seven was, and is, false and misleading.

PAR. 9. Through the use of the statements and depictions contained in the advertisements referred to in paragraph four including but not necessarily limited to the advertisements attached 166 FEDERAL TRADE COMMISSION DECISIO Complaint 119 FTC. as Exhibits A and B , respondents have represented, directly or by implication, that:

A. Eez-Away Relief rapidly eliminates severe pain and physical disabilities caused by arthritis.

B. Eez-Away Relief provides long-term pain relief. C. Eez-A way Relief significantly increases the range of motion in the affected joints of people with arthritis, including those with rheumatoid arthritis.

D. Eez-Away Relief is more effective than other over-the-counter medications in relieving arthritis pain.

PAR. 10. Through the use of the statements and depictions contained in the advertisements referred to in paragraph four including but not necessarily limited to the advertisements attached as Exhibits A and B , respondents have represented, directly or by implication, that at the time they made the representations set forth in paragraph nine, respondents possessed and relied upon a reasonable basis that substantiated such representations. PAR. 11. In truth and in fact, at the time they made the representations set forth in paragraph nine, respondents did not possess and rely upon a reasonable basis that substantiated such representations. Therefore, thc representation set forth in paragraph ten was, and is, false and misleading.

PAR. 12. Through the use of the statements and depictions contained in the advertisements referred to in paragraph four including but not necessarily limited to the advertisement attached as Exhibit A, respondents have represented, directly or by implication that Eez-Away Relief relieves arthritis pain by penetrating through the skin to the affected joint.

PAR. 13. Through the use of the statements and depictions contained in the advertisements referred to in paragraph four including but not necessarily limited to the advertisement attached as Exhibit A, respondents have represented, directly or by implication that at the time they made the representation set forth in paragraph twelve, respondents possessed and relied upon a reasonable basis that substantiated such representation.

PAR. 14. In truth and in fact, at the time they made the representation set forth in paragraph twelve, respondents did not possess and rely upon a reasonable basis that substantiated such , OLSEN LABORATORIES , INC. , ET AL 167 161 Complaint representation. Therefore, the representation set forth in paragraph thirteen was, and is, false and misleading. PAR. 15. Through the use of the statements and depictions contained in the advertisements set forth in paragraph four, including but not necessarily limited to the advertisements attached as Exhibits A and B, respondents have represented, directly or by implication, that the testimonials or endorsements from consumers appearing in advertisements for Eez-A way Relief reflect the typical or ordinary experience of members of the public who use Eez-Away Relief. PAR. 16. Through the use of the statements and depictions contained in the advertisements set forth in paragraph four, including but not necessarily limited to the advertisements attached as Exhibits A and B, respondents have represented, directly or by implication, that, at the time they made the representation set forth in paragraph fifteen, they possessed and relied upon a reasonable basis that substantiated such representation.

PAR. 17. In truth and in fact, at the time they made the representation set forth in paragraph fifteen, respondents did not possess and rely upon a reasonable basis that substantiated such representation. Therefore, the representation set forth in paragraph sixteen, was, and is, false and misleading. PAR. 18. By and through the " 30 Minutes " infomercial, a transcription of which is attached hereto as Exhibit A, respondents have represented, directly or by implication, that "30 Minutes" is an independent television program and is not paid commercial advertising.

PAR. 19. In truth and in fact 30 Minutes" is not an independent television program and is paid commercial advertising. Therefore the representation set forth in paragraph eighteen was, and is, false and misleading.

PAR. 20. The acts and practices of respondents as alleged in this complaint constitute unfair or deceptive acts or practices and the making of false advertisements in or affecting commerce in violation of Sections 5(a) and 12 of the Federal Trade Commission Act. Commissioner Azcuenaga recused.

Complaint 119 FTC. EXHIBIT A 30 MINUTES Graphic:

This program is a paid for advertisement by Olsen Labs Ioe.

Graphic:

The program you are about to see is true. The names of the people have not been changed and their statements have not been altered. We make this claim for your protection and in the interest of truth.

VOICE -OVER: The program you are about to see is true. The names of the people have not been changed and their statements have not been altered. We make this claim for your protection and in the interest of truth.

MARIE GIORDANO: It' s a good feeling about yourself. You able to smile again, be happy again.

UNIDENTIFIED WOMAN #1: m very excited, yes, I'm very excited. JULIA GABOR: It is a miracle drug and I'm, I know it is. UNIDENTIFIED WOMAN # 2: They want to borrow it, but no one s getting it.

SCOTI W ALTER: When I tried Eez Away, I couldn t believe it. SANDY DUVALL: A product that says it will work that does work.

TOM BURKE: And it works every time. DEE SANCHEZ: Wow! That s all I can -- that s all I can do. Wow.

Depiction:

People playing tennis.

VOICE-OVER: The good life. For most people it means free time, friendship, happiness and health.

Depiction:

Men fishing.

And, thanks to modern medicine, Americans are now living Jonger Depiction:

Woman diving into pool with the opportunity of many more years of this good life.

Depiction:

People playing shuffeboard.

But tragically, there is one common disease that deprives millions of Americans of their chance at the good life - Arthritis.

Depiction:

OLSEN LABORA TORIES, INe., ET AL 169 161 Complaint Man pitching horseshoes.

Since the dawn of civilization, man has searched for a cure for this crippling disease Depiction:

People riding bicycles.

and today we continue that search on "

Minutes Depiction:

Man and woman sitting at anchor news desk with a camera and cameraman off to the side. Moves in to close-up of the two anchors Large superimposed text: 30 Minutes DA VID FLYNN: Hello, I'm David Flynn. SHELLY DUVALL: And I'm Shelly Duvall, and welcome to another edition of " 30 Minutes, DA VID FLYNN: Chances are that you or someone you know has arthritis. This painful disease affects nearJy 40 million Americans. That s) in 7 people in this country.

SHELLY DUVALL: Many of us associate arthritis wirh older people, but the fact is it strikes aU ages, even children.

DA VID FLYNN: There is still no cure for arthritis, and so many people who suffer from it are in a constant search for treatment that will bring them some relief. Today on "30 Minutes " we will take a look at how people are coping with this terrible disease.

SHELLY DUVALL: And we ll tell you about a recent breakthrough in the treatment of arthritis that has brought new hope to many chronic arthritis sufferers. Much new work is being done, and the good news is there s hope. Later on wc JI tell you about a new arthritis remedy that could provide the much sought-after relief from pain. So jf you or someone you love has arthritis, muscle or joint pain, please, stay tuned. The pain may soon be over.

DAVID FLYNN: Let's start at the beginning. What is arthritis and what do we know about it? DA VID FLYNN (Voiceover): The word arthritis is derived from Greek and literally means " inflamed joint.

Graphic:

ARTHRITIS Inflamed Joint DAVID FLYNN (V/O): There are many types of arhritis, but the most common form is osteoarthritis Complaint 119 F. DAVID FLYNN (V 10): Most often characterized by redness, swelling, stiffness, and pain.

Graphic:

Osteoarthriti Redness Swelling Stiffness Pain According to the Arthritis Foundation, every person over 60 probably has Osteoarthritis to some degree.

Graphic:

Every person over 60 probably has Osteoarthritis.

SHELLY DUV ALL: But the worst thing about arthritis is how it can ruin Jives. People who were once strong and active are often reduced to helplessness and depression because of the constant pain. JULIA GABOR: I had arthritis so bad, I was in bed for 6 Arthritis sufferer months, no exercise. I had to get up -- I was in a wheelchair.

SAMUEL GREEN: I had arthritis in these hands so bad, it felt Arthritis sufferer it felt like somebody had a knife -- and then he rammed it jn there lindicating his handl and pulled it.

JANNIE BUHR: It' s very hard on me now with visiting the Arthritis sufferer grandchildren. I do not stay very long with them, and I've always loved them, and planned 10 stay wirh them before, but I can t-- I just can t do it anymore.

MARIE GIORDANO: Wed, I had my back, lower back pain for Arthritis sufferer about three years, and it was just really so bad I couldn t walk. I had to take time off from work, and I was laid up for really two weeks at home on my back flat. I tried many things, and nothing really worked.

DAVID FLYNN: What can these people do? We recently learned that some exciting new research is being done on a new type of pain reliever. We wanted to find out more.

SHELL Y DUVALL: We spoke with chiropractor Dr. John Panicali. We learned that he took part in a research study of a new arthritis treatment that s been getting a lot of attention.

Depiction:

Dr. Panicali in examining room with pcltient. , OLSEN LABORATORIES, INe. , ET AL 171 161 Complaint SHELLY DUVALL (V/O): He sees many arthritis sufferers. We asked him why arthritis is such a difficult disease to treat.

DR. JOHN PANICALI: I find that the worst thing about arhritis is Doctor of Chiropractic that about half the people give up. They feel that once they have it, there is nothing that can be done. And that's not necessarily true.

We find that they give up on life; they become depressed. Their exercise and their activity is limited. A lot of older patients start to gain weight because they re less actjve. So it's a -it's a disease that affects the body, but I find that in more cases it affects the mind.

Depiction:

Dr. Panicah applying, and explaining to patient in examining room how to apply, Eez- Away.

SHELLY DUVALL (V/O): The new product tested by Dr. Panicali is called " Eez-Away Relief." When we spoke with him, he had been dispensing it for several months. And what were his findings? DR. PANICALI: Patients that we ve been working with for many months now have reached a certain point of relief, but at that point, we ve reached a stone waJJ. So we tried this product on those patients. And patients are coming back and telling me Doc, I don t know what that stuff was, but I'm getting further motion, I'm doing things now 1 never did before, for the first time I'm climbing stairs without pain, I can actually look over my shoulder when 1 back out of my driveway." The product is natural. There s no side effects. There s no way at aji this product can harm you.

Depiction:

Dr. Panicali, in front of a panel of x-rays examining x-rays and pointing things out to patient.

DR. PANICALI (V/O): The unique thing about Eez-Away Relief is that it absorbs through the skin surface at a faster rate than other products. But what also unique is that once it's at the joint surface. it binds to tissues, ligaments and fats and stays within the joint for a much longer period of time, affording relief for a longer period, and pain-free motion.

Complaint 119 FTC. DR. PANICALI The best thing I find with Eez-Away Relief Doctor of Chiropractic is that patients can return to their normal lifestyle. Patients have found that they can go on. They can do activities around the house; they can go back to their nental lifestyle perform activities that they thought were long gone.

Depiction:

Dr. Panicali applying Eez-Away to a patient shoulder and explaining how to use the product.

SHELLY DUVALL (V10): Dr. Panicali introduced many of his patients to Eez-Away Relief. We asked a few of them for their reviews.

PAT MURANO: I'm the type of guy, just like you are. I don Businessman believe everything somebody tells me, unless I try it, for myself. I've tried the product, Eez- Away Relief. I know it works.

JOHN BOISE: I tried it, every couple of hours for about justPlant Manager three or four days, and the pain disappeared completely. And so now I've been using it like once a week, and the pain just stays away: and I can start moving my hands a lot better than I ever used to be able to move them.

PATRICIA ROBINSON: I couldn t put up my hair. I couldn t lift up Travel Agent my anns. I couldn t do anything with my right arm. And I started using Eez-Away and I can now lift it.

MARIE GIORDANO: When I first applied it, I had very little hope Teacher s Aide that anything was going to help me. I have arthritis, and I figured that was it. But it really made me comfortable after the pain was gone. I felt" aahhh.

SHELLY DUVALL: I want you to know that these folks have not been paid to endorse this product. They re real people who ve had real results. We found that Eez-Away is giving people a lot of hope, even people who ve tried it all.

DA VID FLYNN: Shelly, these results are very impressive, but is it safe? Has it been properly tested? SHELLY DUV ALL: Absolutely, David. It's met all the FDA requirements, and it contains only ingredients that are recognized by the FDA itself to be both safe and effective for pain relief.

DA VID FLYNN: But what s the big secret? Can we now buy it in stores? OLSEN LABORATORIES, INe. , ET AL 173 161 Complaint SHELL Y DUVALL: Til now the only way to get some was to see one afthe testing physicians like Dr. Panicali. Unfortunately, it s still not available in stores. DAVID FLYNN: ve got to take a break, but when we come back, we ll talk with the person who developed this revolutionar new pain remedy.

SHELLY DUV ALL (Via): And we ll spend a day in the life of an arthritis sufferer, when "30 Minutes " continues.

Depiction:

Child runs and jumps into Dee Sanchez s arms.

DEE SANCHEZ (Via): This just works. I put it on, and I don t hurt. DEE SANCHEZ: It' s everything I could ever have asked for and it s given me back my life.

Superimposed text:

EEZ-A WAY Gets Results COMMERCIAL INSERT Graphic:

ATTENTION! ARTHRITIS SUFFERERS VOICE-OVER: Attention arthritis sufferers, the program you are now watching features a powerful Arthrtis Treatment caled Eez Away Relief Graphic:

(Scrolling down the screen) The program that you are now watching features a powerful Arthritis Treatment called EEZ-A WAY Rellef.

This breakthrough pain reliever is so new, so revolutionary, that it's not yet available in stores.

However, if you or someone you love suffer from chronic aches, pains or stiffness, we have wonderful news.

Depiction:

Dr. Panicali rubbing Eez-Away on a woman hand in an examining room Superimposed text on close up of woman hand:

Aches Pains Stiffness For a limited time only the makers of Eez- A way are offering this amazing new pain remedy directly to you through this introductory TV offer.

Graphic:

, Complaint 119 F.TC. Arm bent at 90 degree angle, with the elbow enhanced in red. A bottle of Eez-A way comes from the right of the screen and then tips toward the reddened elbow, the top flips up, the red disappears, the top closes and the bottle comes to stand at the right hand side of the screen.

At last, you won t have to live with that nagging pain in your hands, back, arms elbows, knees and other joints. With Eez- Away, you ll regain the vitality you once had to enjoy life again with mobility and freedom. Simple pleasures like biking, fishing, tennis, and fun with your family will all return once the pain is gone.

Depictions:

Screen, djvided into four quadrants, with pictures of people bicycling, fishing, playing tennis, and swimming Superimposed text:

Biking Fishing Tennis Just apply Eez Away to the painful area and soon you ll feel the power, the relief. Eez- A way is patented, and has no messy residue or strong medicine smell, and it s not taken internally so it won t upset your stomach like some pain relievers.

Depiction:

Man in locker room applying Eez-Away to his knee Superimposed text:

Easy To Use And doctors recommend it as safe, even on sensitive skin.

Depiction:

Dr. Panicali applying Eez-Away to patient's shoulder in examining room.

Superimposed text:

No Mess No Strong Smell With your order, you get an 8 oz. bottle of EEZ-A WAY Relief. That s a full 30 day supply.

ll also include this beautiful aturaJ Care Workbook. It's 60 pages of valuable OLSEN LABORATORIES, INe. , ET AL 175 161 Complaint infonnation to give you strength and to keep you limber once the pain is gone.

Depiction:

Close up of the front cover of booklet. On the cover is a stop sign with the words "THE PAIN STOPS HERE." Some of the contents of the book are shown, including drawings of exercises, someone receiving a massage, and three progressively smaller profiles of the human body.

This $11.95 value is yours absolutely free. Plus, if YOll call now, we ll also include another 8-oz. bottle of Eez-Away. Perfcct for your purse or briefcase. It s a $24. 95 value free, just for trying Eez-A way.

The entire Eez-Away package, including 2 8oz. bottles plus the natural care workbook would cost over $60.00 if sold separately. But now, through this special TV offer, you pay only $39.95.

re so confident that Eez-A way Relief will work for you, that we re offering a complete money back guarantee.

Superimposed text:

30 DAY GUARANTEE 800-938-2828 If you re not convinced that Eez-Away is the most effective pain remedy that you ve ever tried, return it for a full refund.

So if you have arthritis that won t go away, order Eez-Away now. It's guaranteed, so you have nothing to lose but the pain. Call now. Graphic:

Call 1 - 800 938 -2828 $39. 95 + $5. 95 Shipping Handling EEZ- AWAY O. BoxA Lincoln, KS 67455 ALLOW TO WEEKS FOR DELIVERY OLSEN LABS. INC. . 115 WEST ELM ST, LINCOLN, KS67455 Have your credit card or checkbook ready and call 1-800-938- 2828. A $57.00 value for just $39. , plus $5.95 shipping and handling.

Call 1-800-938-2828 or send your check money order to EEZ-A WAY , P.O. Box A, Lincoln, KS 67455 , or call 800-938-2828.

END COMMERCIAL INSERT Complaint 119 FTC. JANNIE BUHR: Now, I can move the knee without any pain to it. I'm always surprised that I can use them and there s no pain. I mean, you know, I sit down, I lay down, I don t have the pain that I always had.

UNIDENTIFIED WOMAN #3: I use it for about ten minutes, all over, and it has no odor. And I got dressed, and about tcn minutes later I -- there was no pain. It was like I -- it was hard to believe that there was actually no pain.

SAMUEL GREEN: But now that I use this Eez-Away, see, you can see for yourself (opening and closing his hands).

JULIA GABOR: But I just used it on my shoulder and I think that I knew that would help my shoulder within, within a week. I was, oh, I thought it was a miracle drug.

UNIDENTIFIED WOMAN #1: Since I've been using Eez- Away, I have a better grip, and I can do my laundry better, I can do my housework much better, and I can also comb my hair much better, because I couldn t raise my hand or holri a grip on the comb to comb my hair.

UNIDE:-TIFIED WOMAN #2: (Shuffing a deck of cards) And at one time I was not able to shuffe a deck of cards as I'm doing now. Since I've used Eez- Away, I'm able to shuffe the cards on my own with have -- without having someone do it for me. And s the greatest thing to know that you can do it on your own.

Depiction:

The two anchors sitting behind a news desk. To the left is a camera and cameraman.

Large superimposed text: 30 Minutes Depiction:

Close-up of assorted over-the-counter medications, including Buffcrin, Mineral Ice Exccdrin, Ben Gay, Heet, Icy Hot, Tylenol, and Advil.

DA VID FLYNN: This is just a sampling of some of the pain remedies that we found in our local drugstore. There are literally aisles full of pills and ointments that claim to relieve pain. Shelly, what makes Eez-Away so different? SHELLY DUVALL: Well, the people that we spoke to, David, said simply that these remedies just don t work the way that Eez-Away does. They ve been OLSEN LABORATORIES. INC., ET AL 177 161 Complaint searching for relief, they finally found it with this product.

DAVID FLYNN: Next we have a woman who was crippled by arthritis pain until she found Eez-Away.

SHELLY DUVALL: This is the true story of Dee Sanchez. Depiction:

Dee Sanchez outside at a picnic.

SHELLY DUVALL (Via): Dee Sanchez lives in Lynnford, New Jersey. She s marred and the mother of two girls.

From these pictures you wouldn t know that a few short months ago she was suffering from severe chronic arthritis.

DEE SANCHEZ: I just plain hurt. Sometimes I just wanted to sit down and cry because it was so frustrating because I couldn t -- I couldn t do all the things that were me. The simple things. To a lot of people it wouldn t matter. Cleaning my house, taking curtains down and washing them, hanging them back up. I couldn t do that.

SHELLY DUVALL (Via): Dee was in excruciating pain, and it wasn only she that was suffering. The deterioration of Dee s physical and mental state was taking its toll on her family as well.

Depiction:

Sanchez s husband and daughters outside at a picnic table.

FRANK SANCHEZ: We have a family that s close, and yet all want to do things together, and no fault to Dee on this thing, if I were in pain constantly, your nerves were on edge, and things that would not irritate someone normally, I mean the sJighest little thing can, can set off an argument when none need have come. You tend to overreact when you re hurting.

VANESSA SANCHEZ: She d be, like, complaining, start dropping stuff, and, like, we d ask to help, and she say, 'No! I can get it " She d telJ us to go away.

FRANK SANCHEZ: You react two ways. One with anger at yourself because you can t do anything about and probably frustration. Uh, with her .- but combined with her irritability it only made matters worse.

SHELLY DUVALL (Via): Dee was desperate, her life was failing apart. She tried everything.

DEE SANCHEZ: I had tried just about every type of rub, every type of cream that came on the market. I'd go Complaint 119 FTC. buy it and give it a try. I'd tried a few, uh, I had an aunt that even made up some home remedies that were supposed to be from the old country that would help my arthritis and so forth. And nothing was doing any good.

SHELLY DUVALL (V/O): Then one day Dee s luck changed. Dee was introduced to new Eez-Away Relief.

Depiction:

Sanchez pouring Eez-Away on to cotton ball and rubbing onto her shoulder.

The results were immediate and dramatic.

DEE SANCHEZ: I think the first thing I noticed was just when I woke up in the morning just to (stretchingl you know, you automatically stretch and I could stretch. I'm cooking again, my house is spotless again. I can clean.

DEE SANCHEZ (V/O): I can fix my Jittle one s hair every morning before she goes to schoo! Depiction:

Sanchez braiding her daughter s hair.

and sew Depiction:

Sanchez sewing on a button.

and scrub my floor the old fashioned way even though the kids laugh at me for doing it. Depiction:

Sanchez mopping her floor.

I mean I can, 1 can hug my husband, and he can grab me aU he wants. It doesn t hurt anymore.

Depiction:

Sanchez brushing her hair in front of the mirror and her husband comes and hugs her from behind DEE SANCHEZ: Everything that I've ever done it's -- it's back again.

Depiction:

Sanchez and family taking a walk.

SHELLY DUV ALL (V/O) Yes, Dee Sanchez is a happy woman today, enjoying life again. She regained her health and her spirits, and her relationship with her family is better than ever.

Depiction:

Daughter jumping into Sanchez's arms and Sanchez catching her.

\\That docs she think of Eez-A way Relief? OLSEN LABORA TORlES, INC., ET AL 179 161 Complaint DEE SANCHEZ: Wow! Here I am and I work, and I'm, I'm me again. I'm Dee. And that s the best thing I can say, I'm me again.

DAVID FLYNN: This stuff must be very powerful. for DeeSHELLY DUV ALL: Well, David, it cerrainly worked Sanchez. Her story is so inspiring, but we have seen this same story again and again with other people. People who had lost mobility, stopped being active because of the pain. They were able to get up and enjoy life with the help of Eez-Away.

Depiction:

Dr. Jackson examining Minnie Bcnjamin wrist.

SHELLY DUVALL (V /0): Another physician taking part in the Eez- Away test program was Dr. Thomas Jackson of Vera Beach, Florida. He s a cardiologist witha special concern for the effects of arthritis on a person s general health.

DR. THOMAS JACKSON: The arthritis is dangerous when -- when Cardiologist people tend to become sedentary. When they sit down and they tend to not move, and they tend not to walk, and not to exercise, they are limiting the-- their longevity, really. They don t do quite as well as people that are out there, active, and they re doing things. People who are older, many times feel, uh, young as long as they can do the things that, uh younger people do.

I've had an opportunity to -- to give some samples, to see some people get responses and to notice smiles on their faces and flexible joints. That's been good. That's been very good.

Depiction:

Dr. Jackson, in examining room, removing splint from Minnie Benjamin s wrist.

DR. JACKSON (V/O) Minnie Benjamin has juvenile rheumatoid arthritis. Now juvenile rheumatoid arthritis begins in the teenage years. It can begin in childhood. She s had it for a long time. \Ven I saw Minnie, she had a problem with her ankle and with her wrist and was unable to walk properly, limping, and had a splint on her hand. I gave her Eez-Away because I had used it in a few other instances. I mentioned to her to use it according to the directions. Complaint 119 F. She came back the next morning, the splint was off and she wasn t limping.

DR. JACKSON: So I was really impressed with that overnight response. You know, it's rather fabulous, rather amazing to say the least.

MINNIE BENJAMIN: You see I'm not wearing my brace And I Medical technician hope I don t have to put it on anymore because the Eez-Away has helped me get rid of it.

DAVID FLYNN: Do you have arthritis? We ll tell you how to find out when 30 Minutes continues.

Depiction:

Two anchors sitting at desk, camera and cameraman off to the left DR. THOMAS JACKSON: I'm not going to put my reputation on the Cardiologist line for -- for something that s -- that I am not convinced wiJJ be of a benefit of my patients. I'm certainly not going to recommend something that s going to har them. It works! PHIL SABA TO: With this product, Eez-Away, I'm back to Science Teacher normal. I can walk again, r could bend down without being in pain, I could climb up the ladder. I don t have the pain that I did in the past.

SCOTT WALTER: I really used Eez Away quite a bit -- for two Business owner hours straight, and in that two hours time, I was able to bring my finger down and touch my hand. So I was, I was impressed by that. And I stayed with the product and now I've got the mobility where I can close my hand I'm able to use my hand, close my fist, I'm able to write, and J'm free to work with my hands again.

SANDY DUVALL: After using Eez-Away, I don t have any Communications Specialist problems. I have no pain, and I don t think about it any more. It's really, uh, it's like a new lease on Life.

TOM BURKE: Before the product, I could only open and Business Executive close very slowly. Ever since I've been using ir now I have full use of the hand (opening and closing handj. I was out playing football with the kids yesterday, because now I can catch and throw the football. And as long as I use it I got no fear.

COMMERCIAL INSERT Graphic:

ATTENTION! ARTHRITS SUFFERERS OLSEN LABORATORIES, INe., ET AL 181 161 Complaint VOICE-OVER: Attention arthritis sufferers, the program you are now watching features a powerful Arthritis Treatment called Eez-Away Relief.

Graphic:

(Scrolling down the screen) The program that you are now watching features a powerful Arthritis Treatment called EEZ-A WAY RELIEF.

This breakthrough pain reliever is so new, so revolutionary, that it s not yet available in stores.

However, if you or someone you love suffer from chronic aches, pains or stiffness, we have wonderful news.

Depiction:

Dr. Panicali rubbing Eez-Away on a woman hand in an examining room Superimposed text on close up of woman hand:

Aches Pains Stiffness For a limited time only the makers of Eez- Away are offering this amazing new pain remedy directly to you through this introductory TV offer.

Graphic:

Arm bent at 90 degree angle, with the elbow enhanced in red. A bottle of Eez-Away comes from the right of the screen and then tips toward the reddened elbow, the top flips up, the red disappears, the top closes and the bottle comes to stand at the right hand side of the screen.

At last, you won t have to live with that nagging pain in your hands, back, anTIS elbows. knees and other joints. With Eez- Away, you lJ regain the vitality you once had to enjoy life again with mobility and freedom. Simple pleasures like biking, fishing, tennis and fun with your family will alj return once the pain is gone.

Depictions:

Screen, divided into four quadrants. with pictures of people bicycling, fishing, playing tennis, and swimming Superimposed text:

Biking, Complaint J 19 F.TC. Fishing Tennis Just apply Eez-Away to the painful area and soon you ll feel the power, the relief. Eez- A way is patented, and has no messy residue or strong medicine smeJI, and it s not taken internally so it won t upset your stomach like some pain relievers.

Depiction:

Man in locker room applying Eez-Away to his knee Superimposed text:

Easy To Use And doctors recommend it as safe. even on sensitive skin.

Depiction:

Dr. Panicali applying Eez-Away to patient shoulder in examini ng room.

Superimposed text:

No Mess No Strong Smell With your order, you get an 8 oz. bottle of EEZ-A WAY Relief. That s a full 30 day supply.

I! also include this beautiful. "Natural Care Workbook."

It' s 60 pages of valuable infonnation to give you strength and to keep you limber once the pain is gone.

Depiction:

Close up of the front cover of booklet. On the cover is a stop sign with the words "THE PAIN STOPS HERE." Some of the contents of the book are shown, including drawings of exercises, someone receiving a massage, and three progressively smaller profiles of the human body.

This $11.95 value is yours absolutely free. Plus, if you call now, we JI also include another 8 oz. bottle ofEez Away. Perfect for your purse or briefcase. It' s a $24. 95 value free, just for trying Eez Away.

The entire Eez Away package, including 2 8 oz. bottles plus the natural care workbook would cost over $60.00 if sold separately. But now, through this special TV offer, you pay only $39.95.

OLSEN LABOR A TORIES , INC., ET AL 183 161 Complaint re so confident that Eez-Away Relief wil work for you, that we re offering a complete money back guarantee.

Superimposed text:

30 DA Y GUARANTEE 800-938-2828 If you re not convinced that Eez-Away is the most effective pain remedy that you ve ever tried, return it for a full refund.

So if you have arthritis that won t go away, order Eez Away now. It s guaranteed, so you have nothing to lose but the pain. Call now. Graphic:

Call 800-938-2828 $39. 95 + $5. 95 Shipping Handling EEZ-AWAY O. Box A Lincoln, KS 67455 ALLOW TO WEEKS FOR DELIVERY OLSEN labs, INC, 1/5I1EST ELM ST, LINCOLN, KS 67455 Have your credit card or checkbook ready and call 1-800-938- 2828. A $57.00 value for just $39. 95, plus $5.95 shipping and handling.

Call 1-800-938-2828 or send your check or money order to EEZ-AWAY , P.O. Box A Lincoln, KS 67455 , or call 800-938-2828.

END COMMERCIAL INSERT UNIDENTIFIED WOMAN #2: It changed my life in the sense where I'm independent again. Where I can do for myself. I can tie my shoe. I can put my own stockings on, I don t need help to do that anymore. I can button my own clothes and comb my own hair, and it s making me feel like a woman again.

JOHN BOISE: I've been trying a lot of different medications over the past two or three years trying to eliminate arhritis in my joints, and since I used Eez-Away, it just worked and it's like a miracle.

MARJE GIORDA:-O: I wish everybody could feel the same relief that I felt three weeks ago when I first applied it. It's a wonderful feeling knowing that there is something out there that can work and it does work, it s positive thinking. And I would recommend it to everyone.

Depiction:

Complaint J 19 FTC. Two anchors sitting at news desk with camera and cameraman to left of screen.

Superimposed text:

30 Minutes DAVID FLYNN: Needless to say, we are impressed with this new product, so we spoke with the person who developed this revolutionary new pain remedy.

PETER OLSEN: When we first developed Eez-Away, we Developer of Eez-Away knew it would relieve a lot of pain, and it has. Even doctors are amazed. As a matter of fact re so confident that we actually have a guarantee. Use the product for 30 days. If you re not satisfied, we ll return your money. SHELLY DUVALL: Do you have arthritis? Here are the warning signs.

SHELLY DUVALL (V/O): Swelling in one or more joints. Early morning stiffness.

Recurrng pain or tenderness in anyone joint. Inability to move ajoint nonnally.

Obvious redness and warmth in a joint.

Unexpected weight Joss, fever or weakness combined with joint pain.

Graphic:

Arthritis Warning- Swelling Stiffness Pain or Tenderness Inability to Move Nomlally Redness and Warmth Weight Loss or Fever Weakness with Pain DAVID FLYNN: If you have symptoms, you should begin to treat them immediately. Arthritis can be controlled, but the sooner you start, the better. DR. THOMAS JACKSON: This medication is safe, ropicaJ , and will be Cardiologist able ro get around many of the problems that we have not been able to get around before. Uh, it s going to make an impact, I believe, in the way we treat arthritis in the future.

JOHN BOISE: Sometimes my hands got so bad that literally I would have to take some time off from work because I couldn t stand the pain in my knuckles. Uh, now it s no problem. I have no pain whatsoever, my hands are fine, and, I can go back to work and enjoy it and make a living.

OLSEN LABORATORIES, INe., ET AL 185 161 Complaint SANDY DUV ALL: I followed the directions. It was real easy to put on, the smell didn t knock me out. And I used it three or four times the first day. And by the third time I put it on, I had absolutely no pain in my hand at aJL DR. PANICALI: Eez Away Relief is a perfect example that you Doctor of Chiropractic should never give up. Patients that suffer from dajJy pain. there s something out there that can help you. I thank God that this is something that can bring these patients relief.

DEE SANCHEZ: Who knows what my life would have been like? I could still be walking around in such pain that s totally unnecessary. So, anybody that is watching this, try it. It's worth it. COMMERCIAL INSERT Graphic:

ATTENTION! ARTHRITIS SUFFERERS VOICE-OVER: Attention arthritis sufferers, the program you are now watching features a powerful Arthrtis Treatment called Eez-Away Relief.

Graphic:

(Scrolling down the screen) The program that you are now watching features a powerful Arthritis Treatment called EEZ-A WAY RELIEF.

This breakthrough pain reliever is so new, so revolutionary, that it s not yet available in stores.

However, if you or someone you love suffer from chronic aches, pains or stiffness, we have wonderful news.

Depiction:

Dr. PanicaJj rubbing Eez-Away on a woman hand in an examining room Superimposed text on close up of woman hand:

Aches Pains Stiffness For a Jimited time only the makers of Eez A way are offering this amazing new pain remedy directly to you through this introductory TV offer.

Graphic:

Ann bent at 90 degree angle, with the elbow enhanced in red. A bottle of Eez-A way comes from the right of the screen and then tips toward the reddened elbow, the top flips up, , Complaint 119 FTC. the red disappears, the top closes and the bottle comes to stand at the right hand side of the screen.

At last, you won t have to live with that nagging pain in your hands, back, arms elbows, knees and other joints. With Eez Away, you ll regain the vitality you once had to enjoy life again with mobility and freedom. Simple pleasures like biking, fishing, tennis and fun with your family wiJJ all return once the pain is gone.

Depictions:

Screen, divided into four quadrants, with pictures of people bicycling, fishing, playing tennis, and swimming Superimposed text:

Biking Fishing Tennis Just apply Eez Away to the painful area and soon you ll feel the power, the relief. Eez- A way is patented, and has no messy residue or strong medicine smell, and it s not taken internally so it won t upset your stomach like some pain relievers.

Depiction:

Man in Jocker room applying Eez-Away to his knee Superimposed text:

Easy To Use And doctors recommend it as safe. even on sensitive skin.

Depiction:

Dr. Panicali applying Eez-Away to patient's shoulder in examining room.

Superimposed text:

No Mess No Strong Smell With your order, you get an 8 oz. bottle of EEZ-A WAY Relief. That s a full 30 day supply.

ll also include this beautiful Natural Care Workbook." It's 60 pages of valuable information to give you strength and to keep you Member once the pain is gone.

Depiction:

Close up of the front cover of booklet. On the cover is a stop sign with the words "THE OLSEN LABORATORIES, INe. , ET AL 187 '61 Complaint PAIN STOPS HERE. " Some of the contents of the book are shown, including drawings of exercises, someone receiving a massage, and three progressively smaller profiles of the human body.

This $11.95 value is yours absolutely free. Plus, if you call now, we ll also include another 8-oz. bottle of Eez-A way. Perfect for your purse or briefcase. It' s a $24.95 value free, just for trying Eez-Away.

The entire Eez.Away package, including 2 8oz. bottles plus the natural care workbook would cost over $60.00 if sold separately. But now, through this special TV offer, you pay only $39. 95.

re so confident that Eez-Away Relief will work for you, that we re offering a complete money back guarantee.

Superimposed text:

30 DA Y GUARANTEE 800-938-2828 If you re not convinced that Eez-Away is the most effective pain remedy that you ve ever tried, return it for a full refund.

So if you have arthritis that won t go away. order Eez-Away now. It's guaranteed. so you have nothing to lose but the pain. Call now. Graphic:

Call 800-938-2828 $39. 95 + $5. 95 Shipping Handling EEZ-AWAY O. Box Lincoln, KS 67455 ALLOW TO WEEKS FOR DELIVERY OLSEN LABS, INe. 115 WEST ELM ST. LINCOLN, K567455 Have your credit card or checkbook ready and call 1-800-938- 2828. A $57. 00 value for JUS! $39. 95, plus $5.95 sbipping and handling. Call 800-938-2828 or send your cbeck or money order to EEZ-A WAY , P.O. Box A, Lincoln KS 67455, or call 800-938-2828.

END COMMERCIAL INSERT DA VlD FLYNN: 1 hope you ve enjoyed this 30 Minutes. And I hope we ve shown you that you don t need to sit stil for arthritis pain any longer.

Complaint ! 19 FTC. Superimposed text at bottom of screen:

800-938-2828 SHELLY DUVALL: Yes. Now you can fight back. It's your life don t feel old before your time. If you have chronic pain, find a remedy that works for you and begin treatment right away. You ll be glad you did.

DAVID FLYNN: Good Juck, and we ll see you next time on " Minutes. "

SHELLY DUV ALL: Good bye.

Depiction:

The two anchors sitting at the desk with a camera and cameraman in the left part of the screen.

Superimposed text:

Network Marketing International, Inc. (c) 1991.

Graphic:

This program has been a paid for advertisement by Olsen Labs Inc.

A!! rights reserved.

OLSEN LABORATORIES, INe., ET AL 189 161 Complaint EXHIBIT B EEZ-AWAY THE PAIN VOICE-OVER: This program is a paid for advertisement by OJsen Labs. Incorporated.

Graphic:

This program is a paid for advertisement by Olsen Labs, Inc.

EILEEN FULTON: Hi there, I'm Eileen Fulton. Oh, yes, I play that character on a daytime soap opera. Now if you or someone you know is suffering from arthritis, joint or muscle pain, I've got the best news for you, it's called Eez-A way Relief, and believe me, it works and it works fast, and I know because I use it and I just love it. Now please stay tuned because we re gonna tell you more.

MARIE GIORDANO: It's a good feeling about yourself. You re able to smile again, be happy again.

UNIDENTIFIED WOMAN # I I'm very excited, yes, I'm very excited. UNIDENTIFIED WOMAN #2: They wanna borrow it, but no one s getting it. SCOTT WALTER: When I tried Eez-Away, I couldn t believe it. SANDY DUV ALL: A product that says it'll work that does work. TOM BURKE: And it works every time. DEE SANCHEZ: Wow! That s all, that's all I can do. Wow. VOICE-OVER: This is the good life. For most people it means free time, friendship, happiness and good health. We aji want to stay active no matter what our age, but tragically there is one common aiJrnent that deprives many of us of this good life -- Arthritis.

Depictions:

People playing tennis, shuffleboard horseshoes, fishing, swimming, and biking.

VOICE-OVER: Stay tuned, for in the next few moments you llieam about a fabulous new arthritis pain remedy called Eez-Away Relief.

Graphic:

EEZ-AWAY THE PAIN We welcome you now to "EEZ-A WAY THE PAIN " with your host, one of daytime TV' most popular stars, Eileen Fulton.

EILEEN FULTON: , for over 30 years I've been playing this real fun character on a daytime soap opera. I've seen a lot of changes since then.

Television s come a long way, web so have I. Look, I'm not a teenager anymore, thank Complaint ! 19 FTC. goodness for that. But I have to admit, I have noticed some IjttJe aches and pains. My doctor said it s arthritis.

I'm sorry to say that there s no cure for arthritis just yet, but we can control the symptoms now, can t we. Many of us would just do anything to get rid of some of these aches and pains. Of course there s some of us who have serious arthritis, and that can be crippling.

I want you to listen to some of these stories. JULIA GABOR: I had arthritis so bad. I was in bed for 6 Arthritis Sufferer months, no exercise. I had to get up. I was in a wheelchair.

SAMUEL GREEN: I had arhritis in these hands so bad it felt, it Arthritis Sufferer felt like somebody had a knife and then he rammed it in there (indicating his hand), then pulled it.

JANNIE BUHR: It's very hard on me now with visiting the Arthritis Suffer grandchildren. I do not stay very long with them and I've always loved them and planned to stay with them before. But I can, I just can t do it anymore.

MARJE GIORDANO: Well, I had my back, lower back pain for Arthritis Sufferer about three years, and it was just really so bad I couldn t walk. I had to take time off from work, and I was laid up for reaJIy two weeks at home on my back flat. I tried many things and nothing really worked.

EILEEN FULTON: Well, I certainly wasn t about to let that happen to me. I'm having too much fun to Jet a Httle arthrtis slow me down. I have spent years searching for something that could relieve the pain so I could continue doing all the things I love to do. Finally, I found the answer, and it's called Eez-Away Relief. And it is amazing because it really does work, and it works fast. That s why I'm so excited to be telling you about this wonderful product. So stay tuned, because later, we ll tell you how you can get some of this amazing pain reliever for your very own self.

But first, let's hear from chiropractor Dr. John Panicali. He s been dispensing Eez-Away Relief to his patients for several years. We asked him why arhritis is so difficult to treat. Depiction:

Dr. Panicali with patient in examining room. , OLSEN LABORATORIES, INe. , ET AL 191 161 Complaint DR. JOHN PANICALI I find that the worst thing about arhritis is Doctor of Chiropractic that half the people give up. They feel that once they have it there s nothing that can be done, and that s not necessarily true. We find rhat they give up on life. They become depressed, their exercise and their activity is limited. A lot of older patients start to gain weight because they arc less acrive. So, it's a disease that affects the body, but I find that in more cases it affects the mind.

Depiction:

Dr. Panicali applying Eez-Away to a patient shoulder and instructing patient on how to use the product.

EILEEN FULTON: Dr. Panicaii has had great resuhs with Eez- Away Relief, but let him tell you himself.

DR. PANICALI Patients that we ve been working with for many months now have reached a certain point of relief, but at that point, we ve reached a stone wall. So we tried this product on those patients. And patients are coming back and telling me Doc, I don t know what that stuff was, but I'm getting furter motion, I'm doing things now I never did before, for the first time I'm climbing stairs without pain, I can actually Jook over my shoulder when I back out of my driveway. " The product is natural. There s no side effects. There s no way at all this product can hann you.

The best thing I find with Eez Away Relief is that patients can return to their nonna! lifestyle. Patients have found that they can go on, they can do activities around the house, they can go back to their nonnal lifestyle, perfonn activities that they thought were long gone.

Depiction:

Dr. Panicali applying Eez-A way to a patiem shoulder and instructing patient on how to use product.

EILEEN FULTON: Dr. Panicali introduced many of his patiems to Eez-Away Relief. We asked a few of them for their reviews:

PAT MURANO: I'm the type of guy, just like you arc, I don Businessman believe everything somebody tells me unless I try it for myself. I've tred the product, Eez- Away Relicf, I know it works.

Complaint 119 FTC. JOHN BOISE: I tried it, every couple of hours for about three Plant Manager or four days, and the pain just disappeared completely. And so now I've been using it like once a week, and the pain just stays away; and I can star moving my hands a lot better than I ever used to be able to move them.

PATRICIA ROBINSON: I couldn t put up my hair. I couldn t lift my Travel Agent anns, I couldn t do anything with my right arm. And I stared using the Eez-Away and I can now lift it.

MARIE GIORDANO: When I first applied it, I had very little hope Teacher s Aide that anything was going to help me. I have arthritis, and I figured that was it. But it really made me comfortable after the pain was gone. I felt "aahhh.

EILEEN FULTON: I want you to know these folks have not been paid to endorse this product. They're real pcopJe who ve had real results. Eez-Away is giving a lot of people hope. Even people who ve tried it aJl. Before I tried Eez- Away, I wanted to know if it was completely safe. I can assure you that Eez-Away meets with all FDA requirements and it contains only ingredients that are recognized by the FDA as both safe and effective for pain relief. Now right now we re going to take a moment to tell you once more how you can order Eez- Away for your very own, so you stay tuned.

DEE SANCHEZ: This just worked. I put it on and I don t hurtit's everything I could have ever have asked for, it s given me back my life.

Superimposed text:

EEZ-A WAY gets results.

COMMERCIAL INSERT Graphic:

Attention! Arthritis Sufferers.

The program that you are now watching features a powerful arthritis treatment called EEZ-A WAY RELIEF.

VOICE-OVER: Attention arthritis sufferers, the program you are now watching features a powerful artritis remedy called Eez-Away Relief.

This breakthrough pain reliever is so new, so revolutionary, that it s not yet available in stores.

However, if you or someone you love suffers from chronic aches, pain or stiffness we have wonderful news.

Depiction:

OLSEN LABORATORIES, INe. , ET AL 193 161 Complaim Dr. Panicali rubbing Eez-Away on a woman hand in the examining room.

Superimposed text on close up of woman hand:

Aches Pains Stiffness For a limited time only. the makers of Eez- Away arc offering this new pain remedy directly to you through this special introductory TV offer.

At last, you won t have to live with that nagging pain in your hands, back, anns elbows, knees and other joints.

Graphic:

Arm bent at 90 degree angle, with the elbow enhanced in red. A bottle of Eez.Away comes from the right of the screen and tips toward the reddened elbow, the top flips up, the red disappears, the top closes and the bottle comes to stand at the right hand side of the screen.

Superimposed text:

Hands Back Elbows Knees Other Joints With Eez-Away, you ll regain the vitality you once had to enjoy life again with mobility and frcedom. Simple pJeasures like biking, fishing, tennis, and fun with your family will all return once the pain is gone.

Depiction:

Screen, divided into four quadrants, with pictures of people bicycling, fishing, playing tennis, and swimming Superimposed text:

Biking Fishing Tennis Just apply Eez-Away to the painful area and soon you D feel the power, the relief.

Depiction:

Man in locker room applying Eez-Away.

Superimposed text:

Easy to use.

, Complaint 119 FTC. Eez Away is patented. It has no messy residue or strong medicine smell, and it s not taken internally so it won t upset your stomach like some pain relievers.

Depiction:

Dr. Panicali applying Eez Away to woman shoulder in examining room.

Superimposed text:

No mess No strong smell And doctors recommend it as safe even for sensitive skin.

Depiction:

Dr. Panicali giving bottle of Eez-Away to patient.

With your order you get two 8 oz. bottles of Ecz-A way Relief. That s a full 60 day supply.

Plus. when you call we Ji also send you this valuable guide to natural arthritis treatment: The Pain Stops Here," It shows you how exercise, diet, posture and more can fight the affects of arthritis and put you in control again. It s an $11.95 value, but it can be yours free just for tryjng Eez-Away.

And once you try Eez-Away, we know you want to spread the word. So with your order lJ also send you this additional 8 oz. boule of Eez-Away to share with a friend or loved one. This "pass-along" bottle makes a great gift and it s yours absolutely free if you cab now.

When you order you JI get two 8 oz. bottles of Eez-Away plus the free "pass-along" bottle for a total of three bottles of Eez-Away Relief. That's a 90 day supply. Plus, you also get the arthritis carcworkbook The Pain Stops Here " absolutely free.

The entire package including all this would cost over 80 dollars if sold separately, but now through this special TV offer, it can be yours for $29.95. That's a savings of over 50 dollars. Now save money while you stop the pain just pennies a day for Eez-Away Relief.

re so confident that Eez+Away will work for you that we offer a complete money back guarantee.

Superimposed text:

OLSEN LABORATORIES, INe., ET AL 195 161 Complaint 30 Day Guarantee.

If you re not convinced that Eez-Away is the most effective pain remedy you ve ever tried return it for a full refund and keep the arhritis workbook as our gift to you.

Superimposed text (appears above Guarantee in smaller type): Individual Results May Var So if you have arthritis that won t go away, order Eez-A way now. It's guaranteed, so you have nothing to lose but the pain. Call now. Superimposed text:

The program you are watching is a paid advertisement for EEZ-A WAY RELIEF.

Graphic;

EEZ-A WAY RELIEF $29. 95 plus $5. 95 shipping, 10847 Shennan Way CA reidentaddsalesta. Sun Valley, CA 91352 800-674-5700 allow weeks delivery 30 Jay money hack guarGnree Stop the pain. Enjoy life again with Eez- Away. With this special offer, you get two bottles of Eez-Away and a natural care workbook packed with infonnation and exercises to keep you limber and build strength. Call now and get a third bottle free to share. The entire 80 dollar Eez-Away package can be yours for just $29.95 plus shipping. There s no risk. You have nothing to Jose but the pain. Use your credit card and call 1-800-647-5700. Or mail check or money order to EEZ-A WAY.

END COMMERCIAL INSERT Superimposed text (displayed during all of the following testimonials) 800-674-5700 JANNIE BUHR: Now, I can move the knee without any pain to it. I'm always surprised that I can use them and there s no pain, I, you know, I sit down, I lay down. I don t have the pain that I always had.

SCOTT WALTER: I stayed with the product and now I've got the mobility where I can close my hand, I'm able to use my hand, close my fist, able to write and free to work with my hands again.

SAMUEL GREEN: But now that I use this Eez-Away, see, you can see for yourself (moving handsJ.

Complaint 119 F. JULIA GABOR: Well I just used it on my shoulder and I think I knew that that was helping my shoulder within, within a week.

UNIDENTIFIED WOMAN I: Since I've been using Eez- Away, I have a better grip and I can do my laundry better. I can do my housework much better and I can also comb my hair much better because I couldn t raise my hand or hold a grip on the comb to comb my hair.

UNIDENTIFIED WOMAN #2: (Shuffing cards) And at one time I wasn t able to shuffle a deck of cards, as I'm doing now since I've used Eez Away I'm able to shuffle the cards on my own without having someone do it for me, and it's the greatest thing to know that you can do it on your own.

VOICE-OVER: We welcome you back to "EEZ-A WAY THE PAIN " with you host, one of daytime TV' most popular stars, Eileen Fulton.

Graphic:

Eez-Away the Pain With Eileen Fulton EILEEN FULTON: When you re in pain, sometimes the slightest little movement can be so difficult. And if you re Eke I am, you Jl search everywhere trying to find the right medication. And there s so many things on the market today, so what makes Eez-Away so differem? Well for me it works and from the testimony of all these other people, you see I'm not by myself. Now I want you to meet a woman who has really suffered terribly from arhritis pain until she found Eez-Away. This is the true story of Dee Sanchez.

Depiction:

Sanchez family having a picnic.

Dee Sanchez lives in Lindhorst, New Jersey, she s marred and the mother of two girls.

From these pictures, you wouldn t know that just a few short months ago she was suffering from severe chronic arthritis.

DEE SANCHEZ: I just plain hurt. Sometimes I just wanted to sit down and cry because it was so frustrating, because I couldn, I couldn t do alj the things that were me. They re simple things, to a lot of people, it wouldn t matter. Cleaning my house, taking the curtains down, washing OLSEN LABORATORIES. INe., ET AL 197 161 Complaint them, hanging them back up. I couldn t do that.

EILEEN FULTON: Dee was in excruciating pain. And it wasn only she who was suffering. The deterioration of Dee s physical and mental state was taking it's toll on her family as well.

FRANK SANCHEZ: We have a, a family that s close and yet we all want to do things together and, no fault to Dee on this thing, if I were in pain constantly, uh your nerves are on edge and things that would not irritate someone normally the slightest little thing can, can set off an argument when none need to have come -- you tend to overreact when you re hurting.

VANESSA SANCHEZ: She d be like complaining, she kept dropping stuff, and like we d ask to help, and she d say No I can get it!" And she d just tell us to go away.

FRANK SANCHEZ: You react in two ways, one with anger at yourself because you can t do anything about , and probably frustration with her, combined with her irritability, it only made matters worse.

EILEE:\ FULTON: Dee was desperate, her life was falling apart. She tried everything.

Superimposed text:

The program you are watching is a paid advertisement for Eez Away Relief.

DEE SANCHEZ: I had tried just about every type of rub, every type of cream that came on the market. I'd go buy it and give it a try. I'd tried a few, uh, I had an aunt who even made up some home remedies that were supposed to be from the old country that would help my arthritis and so forth. And nothing was doing any good.

Depiction:

Dee pouring Eez-Away onto a cotton baJJ and applying to her shoulders.

EILEEN FULTON: Then one day Dee s luck changed. She was introduced to new Eez-Away Relief. The results were immediate and dramatic.

DEE SANCHEZ: I think the first thing I noticed was just that I woke up in the morning just to, you know you automatically stretch, and I could stretch. I'm cooking again, my house is spotless again, I can clean, I can fix my !ittle one s hair every morning before she goes to school, sew, and scrub my floors the old fashioned way even Complaint 119 FTC. though the kids laugh at me for doing it, I can I mean I can hug my husband and he can grab me all he wants - it doesn t hurt anymore everything that J've ever done, it s back again. Depictions:

Dee sewing, mopping, doing her hair and her daughter s and hugging her husband.

EILEEN FULTON: Yes, Dee Sanchez is a happy woman today. Enjoying life again. She s regained her health and her spirit and her relationship with her family is better than ever. What does she think of Eez-Away Relief? DEE SANCHEZ: Wow! Here I am and I work and I'm, I'm me again, I'm Dee and that s the best thing I can say, I'm me again.

EILEEN FULTON: (Playing piano) Do you know, when my arthritis flares up I can t even play this simplest little piece, and it breaks my heart because I really love the piano. But now that I have my Eez-Away, there s no stopping me no sir. If you have pain that limits your activity, don t you wait another minute--Eez- Away really does work. But don t just take it from me, here s another doctor who s become an Eez-Away believer.

Depiction:

Dr. Jackson, in an examining room, examining Minnie Benjamin s wrist.

This is Doctor Thomas Jackson of Vera Beach, Florida. He s a cardiologist with special concern for the effects of arhritis on a person s general health.

DR. JACKSON: Arthritis is dangerous when, when people Cardiologist tend to become sedentary, when they sit down and they tend to not move, they tend not to walk, not to exercise. They are limiting the their longevity, really, they don t do quite as well as people that are out there, active, and they re doing things. People who are order many times, feel, uh, young as long as they can do the things that, uh, younger people do. I've had an opportunity to, to give some samples, to see some people get responses and to notice smiles on their faces and flexible joints. That's been good, that s been very good.

Depiction:

OLSEN LABORATORIES, INe. , ET AL 199 161 Complaint Doctor Jackson, in examining room, removing wrist splint from Minnie Benjamin.

Minnie Benjamin has juvenile rheumatoid arthritis. Now juvenile rheumatoid arthritis begins in the teenage years. It can begin in childhood. She s had it for a long time. When I saw Minnie. she had a problem with her ankle and with her wrist and was unable to walk properly, limping, and had a splint on her hand. I gave her Eez-Away because I had used it in a few other instances. I mentioned to her to use it according to the directions. She came back the next morning, the splint was off and she wasn t limping.

So I was really impressed with that overnight response. You know, it s rather fabulous rather amazing to say the least.

MINNIE BENJAMIN: You see I'm not wearing my brace. And I Medical Technician hope I don t have to put it on anymore because the Eez-Away has helped me get rid of it.

PHIL SABATO: With this product, Eez.Away, I'm back to Science Teacher nonnal. I can walk again, I could bend down without being in pain, I could climb up the ladder. I don t have the pain that I did in the past.

SCOTIWALTER: I really used Eez-Away quite a bit for two Business Owner hours straight, and in that two hours time I was able to bring my finger down and touch my hand. So I was, I was impressed by that. JULIA GABOR: I'm very satisfied with it and I intend to use Arthritis Sufferer it until even, until I forget that I even have that grab pain every now and then.

SANDY DUV ALL: After using Eez-Away, I don t have any Communications Specialist problems. I have no pain, and I don t think about it anymore. It s really, uh, it's like a new lease on life.

TOM BURKE: Before the product I could only open and Business Executive close very slowly. But since I've been using , I have full use of the hands. LOpens and closes his hands). I was out playing football with the kids yesterday. because now I can catch and throw the football and as long as I use it I got my freedom.

DR. JACKSON: I'm not going to put my reputation on the line or for something that I am not convinced will be of a benefit to my patients. And I'm certainly not going to recommend something that s gonna hann them. It works. It s simple. Complaint 119 FTC. It is effective. The proof is in the pudding. All I say is try the pudding, you know, taste it for yourself, try it.

EILEEN FULTON: Eez-Away is so easy to use, I'll show you how in just a minute. But first, here s another chance to order Eez-Away through our introductory TV offer.

COMMERCIAL INSERT Graphic:

Attention! Arthritis Sufferers.

The program that you are now watching features a powerful arthritis treatment called EEZ-A WAY RELIEF.

VOICE-OVER: Attention arthritis sufferers, the program you are now watching features a powerful arthritis remedy called Eez-Away Relief.

This breakthrough pain reliever is so new, so revolutionary, that it s not yet available in stores.

However, if you or someone you love suffers from chronic aches, pain or stiffness we have wonderful news, Depiction:

Dr. Panicali rubbing Eez-Away on a woman hand in the examining room.

Superimposed text on close up of woman hand:

Aches Pains Stiffness For a limited time only, the makers of Eez- A way are offering this new pain remedy directly to you through this special introductory TV offer.

At last, you won t have to live with that nagging pain in your hands, back, arms elbows, knees and other joints.

Graphic:

Ann bent at 90 degree angle, with the elbow enhanced in red. A bottle of Eez-A way comes from the right of the screen and tips toward the reddened elbow, the top flips up, the red disappears, the top closes and the bottle comes to stand at the right hand side of the screen. Superimposed text:

Hands Back Elbows Knees OLSEN LABORATORIES , INC., ET AL 201 161 Complaint Other Joints With Eez-Away, you ll regain the vitality you once had to enjoy life again with mobility and freedom. Simple pleasures like biking, fishing, tennis, and fun with your family will ail return once the pain is gone.

Depiction:

Screen, divided into four quadrants, with pictures of people bicycling, fishing, playing tennis, and swimming Superimposed text:

Biking Fishing Tennis Just apply Eez-Away to the painful area and soon you ll feel the power, the relief.

Depiction:

Man in locker room applying Eez-Away.

Superimposed text:

Easy to use.

Eez-Away is patented. It has no messy residue or strong medicine smell, and it s not taken internally so it won t upset your stomach like some pain relievers.

Depiction:

Dr. Panicali applying Eez-Away to woman shoulder in examining room.

Superimposed text:

No mess No strong smell And doctors recommend it as safe even for sensitive skin.

Depiction:

Dr. Panicali giving bottle of Eez-Away to patient.

With your order you get two 8 oz. bottles of Eez-Away Relief. That s a ful! 60 day supply. Plus, when you call we ll also send you this valuable guide to natural arthritis treatment: The Pain Stops Here. " It shows you how exercise, diet, posture and more can fight the affects of arthritis and put you in control again. It's an $11.95 value, but it can be yours free just for trying Eez-Away.

And once you try Eez-Away, we know you want to spread the word. So with your order ll also send you this additional 8 oz. bottle of Eez-Away to share with a friend or loved , Complaint 119 FTC. one. This " pass-along" bottle makes a great gift and it's yours absolutely free if you call now.

When you order you ll get two 8 oz. bottles of Eez-Away plus the free "pass-along" bottle for a total of three bottles of Eez Away Relief. That s a 90 day supply. Plus, you also get the arthritis care workbook The Pain Stops Here, " absolutely free.

The entire package inc1ucting ail this would cost over 80 dollars jf sold separately, but now through this special TV offer, it can be yours for $29.95. That s a savings of over 50 dollars. Now save money whiJe you stop the pain just pennies a day for Eez-Away Rehef.

re so confident that Eez-Away will work for you that we offer a complete money back guarantee.

Superimposed text: 30 Day Guarantee.

If you re not convinced that Eez-Away is the most effective pain remedy you ve ever tried. return it for a full refund and keep the arthritis workbook as our gift to you.

Superimposed text (appears above Guarantee in smaller type): Individual Results May Vary So if you have arthritis that won t go away, order Eez-Away now. It' s guaranteed, so you have nothing to lose but the pain. Call now. Superimposed text:

The program you are watching is a paid advertisement for EEZ-A WAY RELIEF.

Graphic:

EEZ-A WAY RELIEF $29. 95 plus $5. 95 shipping 10847 Sherman Way CAresidellsadd.ll/eJlax Sun Valley, CA 91352 800-674-5700 allmv weekldelil'ery 30 day m()ney oackgllarallee Stop the pain. Enjoy life again with Eez- Away. With this special offer. you get two bottles of Ecz-A way and a natural care workbook packed with information and exercises to keep you limber and build strength. Call now and get a third bottle free to share. The entire 80 dollar Eez-Away package can be yours for just $29. 95 plus shipping. There s no risk. You have nothing to lose but the pain. Use your credit card and OLSEN LABORATORIES, INC, ET AL 203 161 Complaint call 1-800-647-5700. Or mail check or money order to EEZ-A WAY.

END COMMERCIAL INSERT Superimposed text:

(displayed during all of the following testimonials) 800-674-5700 UNIDENTIFIED WOMAN #2: It' s changed my life in the sense where I'm independent again, where I can do for myself I can tie my shoe, I can put my own stockings , I don t need help to do that anymore. I can bunon my own clothes and comb my own hair and it's making me feel like a woman again. JOHN BOISE: I've been trying a lot of different medications over the past two or three years trying to eliminate arthritis in my joints, and since I used Eez-Away, it just worked and it s like a miracle.

JULIA GABOR: I'm very grateful that somebody told me about it. It's nothing to keep secret.

SCOTT W ALTER: Listen, I gana telJ you right now, you d better line up and you d better start signing up, because this stuff works.

MARIE GIORDANO: I wish everybody could feel the same relief that I felr 3 weeks ago when I first applied it. s a wonderful feeling knowing that there is something out there that can work and it does work. It's positive thinking, and I would recommend it to everyone.

VOICE-OVER: We welcome you back to "EEZ-A WAY THE PAIN " wirh your host, one of daytime TV' most popular stars, Eileen Fulton.

Graphic:

Eez-Away the Pain With Eileen Fulton EILEEN FULTON: I'm getting ready to go out, and I'm going to dance alj night long with the help of Eez- Away. Not so long ago, ! couldn t do that, but now I'm just going to apply Eez- Away. It works so fast and it !asts so Jong, now I'm going to have a wonderful time. Now let meet the man who developed this revolutionary pain remedy, Mr. Peter Olsen. PETER OLSEN: When we first devcJoped Eez-Away, we Developer of Eez-Away knew it would relieve a lot of pain, and it has. Even doctors are amazed. As a matter of fact Complaint 1!9 FTC. re so confident that we actually have a guarantee. Use the product for 30 days. If you re not satisfied, we JI return your money. DR. JACKSON: This medication is safe, topical, and wiJI Cardiologist be able to get around many of the problems that we have not been able to get around before. It s going to make an impact, I believe, in the way we treat arthritis in the future.

JOHN BOISE: Sometimes my hands got so bad that literally I would have to take some time off from work because I couldn t stand the pain in my knuckles. Now there s no problem, I have no pain whatsoever, my hands are fine, and I can go back to work and enjoy it and make a living.

SANDY DUVALL: I followed the directions. It was really easy to put on, the smell didn t knock me out. And I used it three or four times the first day. And by the third time I put it on, I had absolutely no pain in my hand at all.

DR. PANICALJ Eez-Away Relief is a perfect example that Doctor of Chiropractic you should never give up. Patients that suffer from daiJy pain, there s something out there that can help you. I thank God that this is something that can bring these patients relief. DEE SANCHEZ: Who knows what my life would have been like I could sti)) be walking around in such pain that's totally unnecessary. So anybody that is watching this, try it, it s worth it. EILEEN FULTON: With this money back guarantee, what are you waiting for? If you have arthritis you simply must try Eez-Away. By not treating your arlutis, you actually may be making it worse. Here again is the information on how to order yours.

COMMERCIAL INSERT Graphic:

Attention! Arthritis Sufferers.

The program that you are now watching features a powerful arthritis treatment called EEZ-A WAY RELIEF.

VOICE-OVER: Attention arthritis sufferers, the program you are now watching features a powerful arthritis remedy ca1!ed Eez-Away Relief.

This breakthrough pain reliever is so new, so revolutionary, that it s not yet available in stores.

OLSEN LABORATORIES, INe., ET AL 205 161 Complaint However, if you or someone you love suffers from chronic aches, pain or stiffness we have wonderful news.

Depiction:

Dr. Panicali rubbing Eez-Away on a woman hand in the examining room.

Superimposed text on close up of woman hand:

Aches Pains Stiffness For a limited time only. the makers of Eez- A way are offering this new pain remedy directly to you through this special introductory TV offer.

At last, you won t have to live with that nagging pain in your hands, back, arms elbows, knees and other joints.

Graphic:

Ann bent at 90 degree angle, with the elbow enhanced in red. A bottle of Eez-A way comes from the right of the screen and tips toward the reddened elbow, the top flips up, the red disappears, the top closes and the bottle comes to stand at the right hand side of the screen. Superimposed text:

Hands Back Elbows Knees Other Joints With Eez-Away, you ll regain the vitality you once had to enjoy Efe again with mobility and freedom. Simple pleasures like biking, fishing, tennis, and fun with your family will all return once the pain is gone.

Depiction:

Screen, divided into four quadrants, with pictures of people bicycling, fishing, playing tennis, and swimming Superimposed text:

Biking Fishing Tennis Just apply Eez Away to the painful area and soon you ll feel the power, the relief.

Depiction:

Man in locker room applying Eez-Away.

, 206 FEDERAL TRADE COMMISSIO:' DECISIONS Complaint 119 F.T.c. Superimposed text: Easy to use.

Eez-Away is patented. It has no messy residue or strong medicine smell, and it s not taken intemaJJy so it won t upset your stomach Jjke some pain relievers.

Depiction:

Dr. Panicali applying Eez-Away to woman shoulder in examining room.

Superimposed text:

No mess No strong smell And doctors recommend it as safe even for sensitive skin.

Depiction:

Dr. Panicali giving bottle of Eez-Away to patient.

With your order you get two 8 oz. bottles of Eez-Away Relief. That s a full 60 day supply. Plus, when you cau we JI also send you this valuable guide to natural arthritis treatment: The Pain Stops Here. " It shows you how exercise, diet. posture and more can fight the affects of arthritis and put YOll in control again. It's an $11. 95 value, but it can be yours free just for trying Eez-Away.

And once you try Eez-Away, we know you want to spread the word. So with your order ll also send you this additional 8 oz. bottle of Eez-Away to share with a friend or loved one. This " pass-along" bottle makes a great gift and it's yours absolutely free if you call now.

When you order you ll get two 8 oz. bonJes of Eez-Away pius the free "pass-along " bottle for a total of three bottles of Eez+Away Relief. That's a 90 day supply. Plus, you also get the arthritis care workbook The Pain Stops Here " absolutely free.

The entire package including all this would cost over 80 dollars if sold separately, but now through this special TV offer, it can be yours for $29.95. That's a savings of over 50 dollars. Now save money while you stop the pain just pennies a day for Eez-Away Relief.

\Ve re so confident that Eez-Away wjU work for you that we offer a complete money back guarantee.

Superimposed text:

OLSEN LABORATORIES, INe., ET AL 207 161 Complaint 30 Day Guarantee.

If you re not convinced that Eez-Away is the most effective pain remedy you ve ever tried return it for a full refund and keep the artritis workbook as our gift to you.

Superimposed text (appears above Guarantee. in smaller type) Individual Results May Vary So if you have arthritis that won t go away, order Eez-Away now. It s guaranteed, so you have nothing to lose but the pain. Call now. Superimposed text: The program you are watching is a paid advertisement for EEZ- A WAY RELIEF.

Graphic:

EEZ-A WAY RELIEF $20. lus $5- 95 shipping, 10847 Sherman Way CA residen/J add sales 1= Sun Valley, CA 91352 800-674-5700 aI/ow weeks delivery 30 dny money back gUlJrantee Stop the pain. Enjoy life again with Eez- Away. With this special offer, you get two bottles of Eez-Away and a natural care workbook packed with infonnatjon and exercises to keep you limber and build strength. Cab now and get a third bottle free to share. The entire 80 dollar Eez Away package can be yours for just S29.95 plus shipping. There s no risk. You have nothing to lose but the pain. Use your credit card and call 1-800-647-5700. Or mail check or money order to EEZ-A WAY.

END COMMERCIAL INSERT EILEEN FULTON: Well, I certainly hope you ve enjoyed our show today. I have had a good time doing it for you. And I hope we ve helped you realize you don t have to sit stiJ for arthritis pain anymore, not now that we have Eez-Away.

So yes, yes, you can fight back, so do. It's your life.

Superimposed text (from here until end):

800-647-5700 Don t feel old before your time. If you have pain, try Eez-Away right now. Boy you ll be so glad you did. Well, I have to go, so good luck to you and bye.

Depiction:

Complaint ! 19 FTC. Eileen Fulton getting into limousine and driving away from mansion.

Superimposed text:

Presented by Olsen Labs, Inc.

Produced by New Look Production.

Copyright 1993. Olsen Tabs, Inc.

Graphic:

This program is a paid for advertisement by Olsen Labs, Inc.

OLSEN LABORA TORIES, INe., ET AL 209 161 Decision and Order DECISION AND ORDER The Federal Trade Commission having initiated an investigation of certain acts and practices of the respondents named in the caption hereof, and the respondents having been furnished thereafter with a copy of a draft complaint which the Bureau of Consumer Protection proposed to present to the Commission for its consideration and which, if issued by the Commission, would charge respondents with violations of the Federal Trade Commission Act; and The respondents and counsel for the Commission having thereafter executed an agreement containing a consent order, an admission by respondents of all the jurisdictional facts set forth in the aforesaid draft of complaint, a statement that the signing of said agreement is for settlement purposes only and does not constitute an admission by respondents that the law has been violated as alleged in such complaint, or that the facts as alleged in such complaint, other than jurisdictional facts, are true, and waivers and other provisions as required by the Commission s rules; and The Commission having thereafter considered the matter and having determined that it had reason to believe that the respondents have violated the said Act, and that complaint should issue stating its charges in that respect, and having thereupon accepted the executed consent agreement and placed such agreement on the public record for a period of sixty (60) days, now in further conformity with the procedure prescribed in Section 2.34 of its Rules, the Commission hereby issues its complaint, makes the following jurisdictional findings and enters the following order:

I. Respondent Olsen Laboratories, Inc. is a corporation organized, existing and doing business under and by virtue of the laws of the State of Delaware with its principal offce and place of business located at 11088 Alhambra Street, Leawood, Kansas. Respondent Richfield Distributors, Inc. is a corporation organized, existing and doing business under and by virtue of the laws of the State of New York with its principal office and place of business located at 11088 Alhambra Street, Leawood, Kansas. Respondent Peter F. Olsen is an officer and director of Olsen Laboratories, Inc. and Richfield Distributors, Inc. He formulates directs and controls the acts and practices of Olsen Laboratories,Inc. , Decision and Order ! 19 FTC. and Richfield Distributors, Inc., and his address is the same as that of said corporations.

2. The Federal Trade Commission has jurisdiction of the subject matter of this proceeding and of the respondents, and the proceeding is in the public interest.

ORDER It is ordered That respondents, Olsen Laboratories, Inc. and Richfield Distributors, Inc. , corporations, their successors and assigns, and their offcers; and Peter F. Olsen, individually and as an officer and director of said corporations; and respondents' agents representatives and employees, directly or through any corporation subsidiary, division or other device, in connection with the manufacturing, labeling, advertising, promotion, offering for sale, sale, or distribution of Eez-Away Relief or any substantially similar product, in or affecting commerce, as "commerce" is defined in the Federal Trade Commission Act, do forthwith cease and desist from representing, in any manner, directly or by implication, that the product is a new or unique method of treatment for arthritis pain or is a breakthrough in the treatment of arthritis pain. For purposes of this provision substantially similar product shall mean any external analgesic that contains menthol as the active ingredient.

II.

It is further ordered, That respondents, Olsen Laboratories, Inc. and Richfield Distributors, Inc. , corporations, their successors and assigns, and their officers; and Peter F. Olsen, individually and as an officer and director of said corporations; and respondents' agents, representatives and employees, directly or through any corporation subsidiary, division or other device, in connection with the manufacturing, labeling, advertising, promotion, offering for sale sale, or distribution of any drug in or affecting commerce, as "drug and "commerce" are defined in the Federal Trade Commission Act do forthwith cease and desist from representing, in any manner directly or by implication, that:

, OLSEN LABORATORIES, INC., ET AL 211 161 Decision and Order A. The product rapidly eliminates severe pain and physical disabilities suffered by those persons with arthritis or other similar conditions; or B. The product provides long-term pain relief; or C. The product increases the range of motion in the affected joints of those persons with arthritis or other similar conditions; or D. The product is more effective than other products in relieving pain or in treating the symptoms of those persons with arthritis or other similar conditions; or E. The product relieves the pain of those persons with arthritis or other similar conditions by penetrating through the skin to the affected joint;

respondentsunless, at the time of making such representation, possess and rely upon competent and reliable scientific evidence that substantiates the representation. For purposes of this provision competent and reliable scientific evidence" shall mean tests analyses, research, studies, or other evidence based on the expertise of professionals in the relevant area, that has been conducted and evaluated in an objective manner by persons qualified to do so, using procedures generally accepted in toe profession to yield accurate and reliable results.

Provided that, with respect to any representation covered by subparts A, Band 0 of this Part and any representation covered by subpart C of this Part other than a representation that the product may temporarily increase the range of motion in the affected joints of people with arthritis by temporarily relieving minor pain in those joints competent and reliable scientific evidence " shall mean clinical testingadequate and well-controlled, double-blind conforming to acceptable dcsigns and protocols and conducted by a person or persons qualified by training and experience to conduct such testing.

It is further ordered That respondents, Olsen Laboratories, Inc. and Richfield Distributors, Inc., corporations, their successors and assigns, and their officers; and Peter F. Olsen, individually and as an offcer and director of said corporations; and respondents' agents representatives and employees, directly or through any corporation , Decision and Order 119 FTC. subsidiary, division or other device, in connection with the manufacturing, labeling, advertising, promotion, offering for sale sale, or distribution of any product or service for personal or household use in or affecting commerce, as "commerce" is defined in the Federal Trade Commssion Act, do forthwith cease and desist directly or byfrom making any representation, in any manner, implication, about the health or medical benefits of any such product or service unless, at the time of making such representation respondents possess and rely upon competent and reliable scientific evidence that substantiates the representation. For purposes of this provision competent and reliable scientific evidence" shall mean tests, analyses, research, studies, or other evidence based on the expertise of professionals in the relevant area, that has been conducted and evaluated in an objective manner by persons qualified to do so, using procedures generally accepted in the profession to yield accurate and reliable results.

IV.

It is further ordered That respondents, Olsen Laboratories, Inc. and Richfield Distributors, Inc. , corporations, their successors and assigns, and their officers; and Peter F. Olsen, individually and as an officer and director of said corporations; and respondents' agents representatives and employees, directly or through any corporation subsidiary, division or other device, in connection with the manufacturing, labeling, advertising, promotion, offering for sale sale, or distribution of any product or service for personal or household use, in or affecting commerce, as "commerce" is defined in the Federal Trade Commission Act, do forthwith cease and desist from misrepresenting, in any manner, directly or by implication, that such product or service is a new or unique method of treatment for any disease or condition, or is a breakthrough in the treatment of any disease or condition.

lr is further ordered That respondents, Olsen Laboratories, Inc. and Richfield Distributors, Inc. , corporations, their successors and assigns, and their officers; and Peter F. Olsen, individually and as an officer and director of said corporations; and respondents' agents, OLSEN LABORATORIES , INC. , ET AL 213 161 Decision and Order representatives and employees, directly or through any corporation subsidiary, division or other device, in connection with the manufacturing, labeling, advertising, promotion, offering for sale, sale, or distribution of any product or service for personal or household use, in or affecting commerce, as "commerce" is defined in the Federal Trade Commission Act, do forthwith cease and desist from misrepresenting, in any manner, directly or by implication, the existence, contents, validity, results, conclusions or interpretations of any test or study.

VI.

It is further ordered, That respondents, Olsen Laboratories, Inc. and Richfield Distributors, Inc., corporations, their successors and assigns, and their officers; and Peter F. Olsen, individually and as an officer and director of said corporations; and respondents' agents, representatives and employees, directly or through any corporation, subsidiary, division or other device, in connection with the manufacturing, labeling, advertising, promotion, offering for sale sale, or distribution of any product or service for personal or household use, in or affecting commerce, as "commerce" is defined in the Federal Trade Commission Act, do forthwith cease and desist from representing, in any manner, directly or by implication, that any endorsement (as "endorsement" is defined in 16 CFR 255.0(b)) of such product or service represents the typical or ordinary experience of members of the public who use such product or service, unless respondents, at the time of making such representation, possess and rely upon competent and reliable evidence, which when appropriate must be competent and reliable scientific evidence, that substantiates the representation. For purposes of this provision, "competent and , researchreliable scientific evidence" shall mean tests, analyses studies, or other evidence based on the expertise of professionals in the relevant area, that has been conducted and evaluated in an objective manner by persons qualified to do so, using procedures generally accepted in the profession to yield accurate and reliable results. Provided, however, that respondents may use such endorsements if the statements or depictions that comprise the endorsements are true and accurate, and if respondents disclose clearly and prominently and in close proximity to the endorsement what the generally expected performance would be in the depicted Decision and Order 119 F.TC. circumstances or the limited applicability of the endorser s experience to what consumers may generally expect to achieve, that is, that consumers should not expect to experience similar results. VIl.

It is further ordered That respondents, Olsen Laboratories, Inc. and Richfield Distributors, Inc. , corporations, their successors and assigns, and their officers; and Peter F. Olsen, individually and as an officer and director of said corporations; and respondents' agents, representatives and employees, directly or through any corporation, subsidiary, division or other device, in connection with the manufacturing, labeling, advertising, promotion, offering for sale, sale, or distribution of any product or service in or affecting commerce, as "commerce " is defined in the Federal Trade Commission Act, do forthwith cease and desist from creating, producing, selling, or disseminating:

A. Any advertisement that misrepresents, directly or by implication, that it is not a paid advertisement; B. Any commercial or video advertisement fifteen (15) minutes in length or longer or intended to fill a broadcasting or cablecasting time slot of fifteen (15) minutes in length or longer that does not display visually, in a clear and prominent manner and for a length of time sufficient for an ordinar consumer to read, within the first thirty (30) seconds of the commercial and immediately before each presentation of ordering instructions for the product or service, the following disclosure:

THE PROGRAM YOU ARE WATCHING IS A PAID ADVERTISEMENT FOR (THE PRODUCT OR SERVICE). Provided that, for the purposes of this provision, the oral or visual presentation of a telephone number or address for viewers to contact to place an order for the product or service shall be deemed to be a presentation of ordering instructions so as to require the display of the disclosure provided herein.

OLSEN LABORATORIES, INe., ET AL 215 !6! Decision and Order VII Nothing in this order shall prohibit respondent from making any representation for any drug that is penntted in labeling for any such drug under any tentative final or final standard promulgated by the Food and Drug Administration, or under any new drug application approved by the Food and Drug Administration. IX.

It is further ordered That for five (5) years after the last date of dissemination of any representation covered by this order respondents, or their successors and assigns, shall maintain and upon request make available to the Federal Trade Commission for inspection and copying:

A. All materials that were relied upon in disseminating such representation; and B. All tests, reports, studies, surveys, demonstrations or other evidence in their possession or control that contradict, qualify, or call into question such representation, or the basis relied upon for such representation, including complaints from consumers. It is further ordered That respondents Olsen Laboratories, Inc. and Richfield Distributors, Inc. shall notify the Commission at least thirty (30) days prior to any proposed change in their corporate structure, including but not limited to dissolution, assignment or sale resulting in the emergence of a successor corporation, the creation or dissolution of subsidiares or affiliates, or any other corporate change that may affect compliance obligations arising out of this order. XI.

It is further ordered, That respondents Olsen Laboratories, Inc. and Richfield Distributors, Inc. shall:

A. Within thirty (30) days of service of this order, provide a copy of this order to each of their current principals, officers, directors and Decision and Order 119 F.TC. managers, and to all personnel, agents, and representatives having sales, advertising, or policy responsibility with respect to the subject matter of this order; and B. For a period of five (5) years from the date of entry of this order, provide a copy of this order to each of their principals, offcers, directors, and managers, and to all personnel, agents, and representatives having sales, advertising, or policy responsibility with respect to the subject matter of this order who are associated with it or any subsidiary, successor, or assign, within three (3) days after the person assumes his or her position.

XII.

It is further ordered That respondent Peter F. Olsen shall, for a period of seven (7) years from the date of entry of this order, notify the Commssion within thirty (30) days of the discontinuance of his present business or employment and of his affiliation with any new business or employment. Each notice of affliation with any new business or employment shall include the respondent s new business address and telephone number, current home address, and a statement describing the nature of the business or employment and his duties and responsibilities.

XII It is further ordered, That respondents shall, within sixty (60) days after service of this order, and at such other times as the Federal Trade Commission may require, fie with the Commission a report in writing, setting forth in detail the manner and form in which they have complied with this order.

Commissioner Azcuenaga recused.

AMERICAN HOME PRODUCTS CORPORA non 217 217 Complaint