I was just having a discussion on a blog with a Protandim distributor and the distributor claimed that it helped him with his medical condition. I pointed out that such statements are not only against the LifeVantage Policies and Procedures, but they are also against the Federal Food, Drug, and Cosmetic Act and Federal Trade Commission Act.
To back-up my claim I referenced Section 8.11.2 of LifeVantage's Policies and Procedures (PDF). In reading this section I found something interesting that I hadn't noticed before... a second paragraph. I don't know if it's new or if it has been there all along, but here it is:
"8.11.2 – Product Claims
No claims, which include personal testimonials, as to therapeutic, curative or beneficial properties of any products offered by LifeVantage may be made except those contained in official LifeVantage materials. In particular, no Independent Distributor may make any claim that LifeVantage products are useful in the cure, treatment, diagnosis, mitigation or prevention of any diseases or signs or symptoms of disease. Not only are such claims violations of LifeVantage policies, but they potentially violate federal and state laws and regulations, including the Federal Food, Drug, and Cosmetic Act and Federal Trade Commission Act.
An Independent Distributor that provides a product experience testimonial in any medium should use care to disclose their affiliation with LifeVantage ('LifeVantage Independent Distributor'), be honest in their testimonial personal experience, and assert that they are not claiming that their experience is the typical result experienced by consumers."
The first paragraph seems to prohibit any and all health claims that one can say to have experienced. Why? Because to my knowledge there are no claims in the official LifeVantage materials. The claims that I have seen in the LifeVantage materials relate to oxidative stress. However, a person can not relate to others their personal experience of feeling less oxidative stress - it's an imperceptible reaction within the body. No one has the feeling that their oxidative stress levels are high or low like they would with say, blood sugar as an example. (It should go without saying that what most people mean by "stress" is very different than "oxidative stress." I'll put it in writing for those who confuse the two.)
The second paragraph seems to leave it open for distributors to make personal experience testimonials if they are honest and as long as it is disclosed that their experience is not the typical result experienced by consumers.
There are a couple of problems here:
- Given the groundwork that was laid down in the first paragraph, I can't picture a scenario where the second paragraph would ever come into play. The first paragraph essentially eliminates all personal testimonies making the second paragraph irrelevant.
- A distributor may believe they are being honest about their personal testimony, but due to the nature of Protandim being a health product and a pill in particular the placebo effect is very likely the cause. Thus the distributor making the claim may be lying without knowing it. The distributor can't know what is true results or placebo effect. This would mean that the distributor can not be honest in their assessment in most claims.
It seems like LifeVantage is taking a cue from George Orwell's 1984 and using DoubleThink to control the thoughts of its distributors. Here's that definition from Wikipedia:
"Doublethink, a word coined by George Orwell in the novel Nineteen Eighty-Four, describes the act of simultaneously accepting two mutually contradictory beliefs as correct, often in distinct social contexts."
Here is the quote from Orwell's 1984 itself:
"The power of holding two contradictory beliefs in one's mind simultaneously, and accepting both of them....To tell deliberate lies while genuinely believing in them, to forget any fact that has become inconvenient, and then, when it becomes necessary again, to draw it back from oblivion for just as long as it is needed, to deny the existence of objective reality and all the while to take account of the reality which one denies — all this is indispensably necessary. Even in using the word doublethink it is necessary to exercise doublethink. For by using the word one admits that one is tampering with reality; by a fresh act of doublethink one erases this knowledge; and so on indefinitely, with the lie always one leap ahead of the truth."
That paragraph matches up well with everything related to LifeVantage.
Update: It seems that LifeVantage Actually Encourages Distributors to Break the FTC Endorsement Guidelines.
Originally posted 2011-09-09 19:27:13.This post involves: