Mr. Steven Castaneda Tabak’s Health products

DEPARTMENT
OF HEALTH
& HUMIAN SERVICES
Public Health Service
Food and Drug Administration
Washington, DC 20204
Mr. Steven Castaneda
Tabak’s Health products
3 198 Airport Loop Drive
Suite G
Costa Mesa 1California 92626
Dear Mr. Castaneda:
This is in response to your letter to the Food and Drug Administration (FDA), dated
September 6,200O. Your letter appears to be intended to be the notification required by 21
U.S.C. 343(r)(6).Qection 403(r)(6) of the Federal Food, Drug, and Cosmetic Act (the Act))
and 21 CFR 101.93(a).
21 CFR 101.93(a)(3) requires that the notice submitted pursuant to 21 U.S.C. 343(r)(6) and
this section be signed by a responsible individual who can certify the accuracy of the
information presented and contained in the notice, and that the individual certify that the
information contained in the notice is complete and accurate, and that the notifying firm has
substantiation that the statement is truthful and not misleading. Your submission does not
meet this requirement in that the notice does not state that you, as the responsible official, are
, certifjring that the firm is in compliance with the requirements of the Act and the regulation.
Therefore, you have not complied with the notification requirement in 21 U.S.C. 343(r)(6)
and must submit a notification in accordance with 2 1 CFR 10 1.93(a).
Nonetheless, we have reviewed the information you submitted and have the following
comments. Your letter states that Tabak’s Health Products is making the following claims
for the products below:
20120 caps
“...slow down macular generation...”
“...age-related degeneration of the macula”
‘i
Chromium picolinnte
“...help maintain normal blood sugar levels”
ThinkCapsT”
“...patients...who had moderate to severe cognitive decline”
.=
Page 2 - Mr. Steven Castaneda
The statements for the product Heart Shieldrs’ suggest that it is intended to treat, prevent. or
cure cardiovascular diseases in that the context of the discussion is that the use of this
product improved the heart condition of the patient giving the testimonial which had resulted
in two previous heart operations.
21 U.S.C. 343(r)(6) makes clear that a statement included in labeling under the authority of
that section may not claim to diagnose. mitigate, treat. cure, or prevent a specific disease or
class of diseases. The statements that you are making for these products suggest that they are
intended to treat, prevent. or mitigate diseases. These claims do not meet the requirements of
2 1 U.S.C. 343(r)(6). These claims suggest that these products are intended for use as drugs
within the meaning of 21 U.S.C. 32 l(g)(l)(B), and that they are subject to regulation under
the drug provisions of the Act. If you intend to make claims of this nature, you should
contact FDA’s Center for Drug Evaluation and Research (CDER), Office of Compliance.
HFD-3 10, 7520 Standish Place, Rockville, Maryland 20555.
The product Arthritis-Ease is described as a “all-natural homeopathic remedy.” This product
is not a dietary supplement because homeopathic products are drugs under the Act (see 21
U.S.C. 323 l(g)(TxA). E ven if the product were to be labeled as a dietary supplement, its
name (i.e., Arthritis Ease) and its claims that it “... relieve pain. Swelling. Stiffness.,” eases
“serious discomfort” associated with bone movement, “soothes inflamed, swollen. sore
joints, ” “gentle and dependable approach to arthritis pain.” and “less inflammation, less
stiffness, less pain” are not claims subject to 21 U.S.C. 343(r)(6). You should contact FDA’s
Center for Drug Evaluation and Research (CDER), Office of Compliance, at the address
given above.
Please contact us if we may be of further assistance.
Sincerely,
John B. Foret
Director
Division of Compliance and Enforcement
Office of Nutritional Products, Labeling,
and Dietary Supplements
Center for Food Safety
and Applied Nutrition
Copies:
FDA, Center for Drug Evaluation and Research, Office of Compliance, HFD-300
FDA, Office of the Associate Commissioner for Regulatory Affairs, Office of
Enforcement, HFC-200
FDA, Los Angeles District Office, Compliance Branch, HFR-PA240
*
c
Our Guiding Philosophy:
Superior, Science-Based
Nutritional Supplements
A
September
n
Corporation
’
!
6, 2000
i
!
I1
/11.7J.
,A-,---
Attn: Mr. Robert Moore
Dear Robert,
In compliance with the final ruling for Dietary Supplements
here are copies odour offers for your files.
If you have any questions,
dated January 6, 2000,
please give me a call.
Sincerely,
e--Y
Steven Castaneda
Tabak’s Health Products
(714) 850-1007 ext. 235
-.
s-
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/-a
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NOT
MAKE
CORRECTIONS
TO YOUR
ADDRESS
Use this
of
gift
20/20
IF NEEDED.
0028L
L22OOfiL
LOL
L2L23S
REAL
check today to get your FREE' lo-day
supply
eye-sight!
Caps'" to help support healthy
[FIRSTNAME] [LASTNAME]
[STREET ADDRESS]
[CITY],
[STATE],
[ZIPCODE]
[BAR CODE]
To:
[MONTH] [DAY],
Dear
[YEAR]
[Firstname],
Do you want to help promote
chemicals
and NO side-effects?
healthy
eyesight
Now you can --absolutelv
FREE* - with
20/20 Capstm.
new, all natural
Caps tm are specially
by supplying
the nutrients
health,
as you age.
20/20
And now you can get
your
your
- with
IO-day
NO
supply
.
of
the
formulated
to help nourish
your eyes
need
to
support
vision
and
eye
you
lo-day
supply
FREE*!
- absolutelv
-1
When we say FREE, we mean FREE*!
Just endorse it on the back, and we'll
See the check above?
supply of 20/20 caps'".
accept it as payment for your FREE' lo-day
also send you
We're so sure you'll
love 20/20 Caps'" that we'll
so
you'll
have
plenty
on hand,
a 30-day supply at the same time,
Best of all,
you won't pay a penny
if you want to continue.
the goodness
in every
capsule.
until
you've
had time to experience
of nutrients
that support
Caps'" are full
You see, 20/20
your vision,
like
vitamin
A . . . vitamin
C . , . Zinc _ . .
fruit
extract
. . . mixed
selenium
. . . bilberry
. . .
carotenoids
. . . and
Lutein
You're
not
familiar
TJutein is found
and spinach
- that
with
lutein
exclusively
most people
.
[FIRSTNAME]?
in the kind
don't eat.
of vegetables
- kale
Lutein
is a key
But that doesn't
mean your eyes don't need it.
and several
studies
show that
component of your eye's retina,
(Please turn over)
A
CHECK
lutein
supplements
with aging.'
help
down macular
slow
degeneration,
associated
Evidence has been found that carotenoids
and the antioxidants
vitamin
C and E, help retard
destructive
processes
in the retina
that can lead to age-related
and the retinal
pigment,
epithelium,
degeneration
of the macula.2
a double-blind,
placebo-controlled
study found
In addition,
that bilberry
extract
taken daily
for one month helped maintain
healthy
eye function.'
is
Powerful
The bottom line?
exactly
what you get with
Just sign
this letter,
free* lo-day
nutritional
20/20 Caps'".
the back of the gift
check
now - before it expires
supply of 20/20 Capstm.
support
for
your
eyes
attached
at the top of
and we'll
send you a
Could there
you get older?
safer way to support your vision
bg-an easier,
I think
you'll
agree - it's
a good deal.
as
But hurry.
So this
long.
We simply
opportunity
very
Do your
eyes a favor,
can't
afford
to be this
won't last.
and try
absolutely
generous
for
Caps'" now _ . .
20/20
FREE.
-.
Sincerely,
.Carmen Bickell
For 20/20 Caps'"
P.S.
l
Use the gift
20/20
Caps'",
Do it
eyes.
See Sack
cf
gift
check
check above to claim your FREE* lo-day
supply
the natural
supplement
that promotes healthy
before
your
fcnz complete
check
expires!
offer.
Our
Superior,
gift
Guiding
Science-Based
Philosophy:
Nutritional
Supplements
Of
MAKE
ANY TO YOUR
ADDRESS
“._,_ . . ..,_ .
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ABOVE.
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Receive a lo-day supply of ReguCleanse'"
to help keep your bowels regular
. . .
FREE*!
Absolutelv
To:
[FIRSTNAME] [~2sTNmEl
[STREET ADDRESS]
[CITYl,
[STATE], [ZIPCODE]
[BAR CODE]
[MONTH] [DAY],
Dear
[Firstnamel,
I'd like
FREE-.
it
to send you a lo-day
.I've
In fact,
to use.
enclosed
supply
a special
Why am I so excited
simple:
ReguCleanse'"
and elimination
ReguCleanse'"
It's
all
* There
*
It
about
is very
effective.
are NO psyllium
contains..NO
harmful
name on
. . . you must use
[Firstname]?
The answer
-.
to keeping
your
is
bowels
Easy to use.
Safe.
seeds or anything
check
for
allergic.
chemicals.
effects.
Rhubarb, a purgative,
nerve of the colon.
gift
your
natural
It helps to keep your
movements.
* see back df
comoletelv
check with
is FREE*. But
& expires.
ReguCleanse'"
bowels
ReguCleanse'" contains
the perfect
your bowels and colon clean:
*
gift
offers
an intelligent
approach
system working properly.
* There are NO side
*
of ReguCleanse'"
$18.00
Your lo-day supply of ReguCleanse'"
your special
$18.00 gift
check before
*
[YEAR]
complete
moving
ratio
can sensitize
offer.
and promotes
of ingredients
regular
bowel
c
to help
keep
the bowel movement.reflex
L+
(Please
turn
over)
*
Mirabilitum
*
Coptis
gastric
*
Scute increases
your digestion;
helps
smooth bowel movement.
helps digestion
by stimulating
and pancreatic
juice.
juices,
the secretion
There's NO embarrassment
Just
easy as pie to take.
depending on your need.
The sooner
enjoying
its
you start
benefits.
Pick up your
Mail it . _ .
the secretion
of gallbladder
Gift
which
helps
It's
. . . NO "running
to the bathroom."
swallow one to three tablets
per day,
using ReguCleansetm,
So do act now.
special
.-
bile
of saliva,
Read the offer.
Check.
Before
the sooner you'll
it
start
Sign the back.
Expires!
be on your way to maintaining
The sooner you do, the sooner you'll
more regular
bowel and colon.
healthier,
a
Sincerely,
-.
Maria Aguila
For ReguCleanse'"
P.S.
l
RequCleanse'" is not available
in stores.
opportunity
to keep your bowel and colon
Gift Check - before & exoires.
See back of gift
check
for
/ fi ReguCleanse” helps me stay
I regular by working gently in my
: sensitive digestive system.
If you’d like to promote more
i regular bowel movements, I can’t
j think of anvthine better.”
Don't miss this
Mail your
regular.
complete offer.
“I have been using
ReguCleanse” for some time
now and I wouldn’t
be without it.
I’ve tried other products, but was
never satisfied - it’s a good
product.”
-1 take a fair number of
medications for the pain of
arthritis, and sometimes they ‘stop
me up’. ReguCleanselmis gentle
and keeps me regular. And I’d
much rather take a pill than bother with mixing powders.” .
Eva Dupnis, RI
- Constance Spim, CA
A portion
01 our proi~ts go directly to the Leukemia 8 ?ymphoma Society
Thess s:a:ements have no: been evaiua(ed oy :n E Fooo a-11-JDug Axwusiration
a best-case scenario
advlce of a physclan
Our
Guiding
Philosophy:
This g:coJu:i IS no! Intended to diagnose. trea!, cure, 0:
es~lls will vav This product IS not intended to
In&l&al
MAKE CORRECllONS
TO YOUR
ADDRESS
00286
IF NEEDED
7758852
Sleep Sounder Than You Have in Years
And Have More Energy When You Wake!
Try a lo-Day Supply of Natural
DreamCaps'"
ABSOLUTELY FREE*!
To:
[Firstnamel
[Lastname]
[Street Address]
[Apt. #]
[Citynamel,
[ST] [Zipcode + 41
Date:
[Month]
[Date],
[Year]
Dear [Firstname],
I've
receive
enclosed a-$13.00 gift
a FREE* lo-day
supply
check, with your name on it.
of DreamCapstm!
DreamCap@ is an all-natural
really
works _ . . has no side
herbal
effects
Use it
t*J
approach to sleeping
that
. . . and is NOT addictive.
now you can receive a lo-day supply of DreamCaps'" Best of all,
value - absolutely
FREE*! But before I tell
you how to get
it,
do you occasionally
experience
any of these?
a $13.00
* Do you have difficulty
falling
* Do you wake up several
times
* Do your
worries
* Does tension
If
a
night
for
-.
no good reason?
keep you up at night?
keep you awake?
* When you get up, do you feel
just
asleep?
dragged
out and tired?
you answered "yes" to any of the above,
the ticket
for you.
DreamCapP
could
be
and other carefully
selected
DreamCapscm is made of herbal extracts
nutrients
to promote deeper, more restful
sleep in a gentle way - SO
you won't feel drowsy and dopey when you wake up. Just reenergized
and positive.
[FIRST'NAMEI, DreamCaps'" will
oroven sleep promoters
. . .
Valerian
Root
Extract
work for
you because it
contains
two
m
And Kava Kava Extract.
Valerian
root extract
has been used for centuries
in Europe to
promote better
sleep because it safely and gently relaxes your
Central
nervous system - but without
nasty side effects,
or the risk
l
See back of gift
check
for
complete
offer.
(Please
turn
over)
-2-
of dependency.'f2
e
herbal
Kava Kava, another time-honored
at night by calming anxiety
and relaxing
extract
helps you wind down
your muscles.3,4
And that's
not all.
DreamCaps'" give you even more healthy sleeppromoting nutrients:
Hops,
Passion Flower, Calcium, Magnesium,
Vitamin B6, and Melatonin.
and you've
together,
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Put ‘em all
sleep enhancer
got DreamCapstm, the best natural
I know of.
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you've had in years . . . There's
.I
Get your FREE* IO-day supply of DreamCapstm today. Experience
finallv
getting
a good night's
revitalization
that comes from
sleep.
Simply pick
Put it in the
Read the offer.
up your gift
check.
today . . .
the
Endorse the back.
mail
Before
Once you try
DreamCaps'",
It
you'll
Expires!
wonder how you ever-slept
without
it..
Sincerely,
For DreamCaps'"
P.S.
*
get the restful,
relaxing
sleep of your
With DreamCaps'", you'll
dreams - and wake up feeling
re-energized!
Send for your FREE*
lo-day
supply before your gift
check expires.
See back of gift
check
for
complete offer.
Supporting
References
3. PharmacolBiochem Behavior1982 July;l7(1): 65-71.
4. Lippincotts Prim CarePratt 1999 May-June;3 (3): 290-304.
1. Journal PsychosomRes 1999 O&47(4) : 355-8.
2. PharmacoiBiochem Behavior 1989 Apr;32(4) :1065-6.
A portion of out prof~ls go directl)i lo the Leukemia & Lymphoma Societi/.
Tnese statements have nol been evaluated by the Foco and Drug Agmlnlstratlon This product ISnot Inlended tGCilagnOSe
treat, cure. or Prevent any disease To be used for occastonal sleeoiessness
ontv
Our
~llnerinr
srionco-Raead
Guiding
Philosophy:
N~~+ri+inn~l
Cor~nlam~n+c
MAKE
CORRECnONS
-t-D
YOUR
ADDRESS
If
m
IF
NEEDED.
you'd like a quick boost of natural
energy
in the morning or early
afternoon
. . .
try a IO-day supply of EnergyCaps"
. . .
ABSOLUTELY FREE*!
[John Q. Sample]
[1234 Main Street]
[Anytown,
CA 999991
[MONTH,DAY,YEARI
Dear
[FIRSTNAME],
If you want
stamina that'11
Simply
*-
a natural
last a
sign
the
back
boost of energy,
increased
throughout
the dav . . .
of
the
special
Gift
Check I've
I'll
rush you a lo-day
When I receive
it,
nutritional
formula
- EnergyCaps"
- a $13.99
absolutely
Best
its
of all,
ingredients
can
vigor,
supply
value
and extra
enclosed.
Mail
it.
of an amazing
_ . -..
Free*!
. . .
feeling
tired
or sluggish.'
* Give you extra energy even when you're
and awake even if you're
running
on ~'low*~.~
* Help you feel more alert
* Improve your attention
span and performance
in stressful
times.3
a
natural
lift
when
you're
dragging."
* Give your body and your mind
Energycaps"
Moreover,
Work
crclickl~.
feel an almost instant
surge
Just take one capsule a day, and you'll
(Just
don't
take
it
of energy that'11
keep you going strong all day.
.
after
3:00 pm, if you want a good night's
sleep.)
The secret
[FIRSTNAME],
almost instant
behind EnergyCaps"
are the natural
herbal
stimulants
energizing
. . .
power
(Please
* See back
of
gift
check
for
complete
offer.
turn
over)
- 2 guarana
and ma huang.
m
no wonder people
It's
who've
tried
EnergyCaps"
say:
more
natural
energy
l'I've
never felt
And no jitters,
either."
any formula.
- Rene
from
Garcia.
This is the best natural
energy
discovery
I've ever found,
light
years better
than soda, candy or coffee."
- Rosie de La Fuente.
“WOW!
But
This
hurry!
Because of the flood
hear from you within-the
is
a limited
of orders
I expect
next 11 davs.
time
Free*
from this
offer!
Free*
energy booster
that works quickly,
If you want a natural
Mail
Sign the back.
Read the offer.
special
Gift
Check.
It's
that simple.
But do it
offer,
I must
pick up your
it today.
now . . .
Before
Your
Gift
Check Exnires!!
-.
Sincerely,
tc wmcc~
Lawrence
Remember,
absolutelv
now.
P.S
* See back
of
gift
your lo-day
supply
You don't
Free*.
check
for
complete
GA, et al: **Cameine &cc&
on learning.
Adolescent psychiatry 33(j): 107-15, 1991.
1. Galduroz JC. Carlini EA. “The cfrects of long-tern
1073-8,
performance.
administration
-=bdc
President
of EnergyCaps"
is yours
have to risk or send a cent
offer.
Supporting
1. Bernstein
Tabak,
Rcfcrences
and ans~c~y in normal school-age
of couarana or, the cognitton
children
” Journal of the American
of normal, elderly volunteers.”
Revlsta
Academy
of Child and
Paulista dc Medlcina
I I J( I):
1996.
Bell DG, Jacobs I. “Combined caffeine and ephedrine ingestion improves run hmes of Canadun Forces bbtTiOr Test” Avlatiou Space and Environmental
Medicine 70~5). 325-9. 1999.
91(7): 1436-8, 1996
4. Nadir A, et al. “Acute hepatitis assoctated wth the use or a Chlnesr herbal product, m3 huang. ” American Journal of Castroenterology
3
A portton 01 our prol~ts go drectly to the Leukemia & Lymphoma Society.
Tnese statements M/e not been evaluate0 by Ihe Food a7d D:ug Adm~ntstrallon ;r,!s proox! ISnot Intended lo diagnose. treat. cure. or prevent an, alsease Do not
use II pregnant. nursing. under 18 years ot age, have aslhma, history cf hypertenston, slrokes. htgh blood preSSJe. cardiovascular dsease. rhyrold d.sease pfos:ale
problems. diabetes. or 11using MAO Inhio:tors, or antcoagulants Do NOT consume otner products that contain Caffelfle (Cofieelsooa) Do not take al!er 3 30 PM
Keep out of teach 01 children Never exceed 2 capsules per day Improper use may be hazardous to your heaith
Our
Superior,
Guiding
Science-Based
Philosophy:
Nutritional
Supplements
R
L
L.
From:
The Home of Bill
s
Shick
RF:
A FREE* Bottle
of CcEnzyme QlO for you to support
a healthy
heart,
maintain
healthy
gums and give ycju extra energy
BILL SHICK
[First
Name Last NameI
n3
[Street
Address
Apt. CI
[City Name ST Zip Code]
To:
Dear
[DATE]
[Firstname],
I'd like to send.you a Free" bottle
clinically-proven
to support a healthy
And give you extra enerav - naturally!
I've enclosed a gift
check for
you how to use it in a moment.
My name is William
and raised in western
of CoEnzyme QlO capsules,
Maintain
healthy
heart.
$15.00 with
Shick -- "Bill"
Pennsylvania.
your
name on it.
I was born
to my friends.
gums.
I'll
tell
in 1930
.1
Because of this I started
I've had not one, but two heart operations.
In May I saw an ad for a
taking personal
resnonsibilitv
for my health.
And since it was offered
on a free* trial,
product called HeartShield".
it immediately
caught my inzerest.
What happened?
How could I tell?
Well, in about two weeks I felt
The answer is simple . . .
I Had More Enezw
dramaticallv
better!
to Do Things.
Because I felt better,
I could start doing the things I was forced to
Like shooting a
Like going dancing Tao or three times a month.
give up.
few baskets.
two months after I started
taking HeartShieldt",
I had a
scheduled appointment
with my dcctor at the VA hospital
in Boston.
tell
my situation
had reallv
He checked me over and could immediately
this to?"
He asked me, "What do you attribute
improved.
Anyway
I'd
I told
*
See
I
been waiting
for just that
him about my new healthier
back- of
gift
check
for
complete
With a grin,
moment [FIRSTNAME].
I also
diet and exercise
program.
(Please turn over)
offer.
- 2 tossed him an empty bottle
of HeartShield'"
so he could read the label.
studied it for a moment, and said, "Yes, this is
He caught-it,
Hearing that really
reassured me.
excellent."
And You Won't
Believe
What Happened
at My Next
Appointment
. . .
I had a scheduled appointment
with my
A little
while after that,
show up; I was
As it turned out, my regular guy didn't
cardiologist.
He told
of HeartShield'".
seen by a younger man. I showed him my bottle
me that all over the world, people use natural
approaches just like it.
combination
of
And he confirmed
that HeartShieldtm is indeed a terrific
-- backed by studies
-- and that I should keep taking it along
nutrients
with my new healthy way of eating.
I feel
possible.
with me.
I believe
that I can live
so good now.
I’m
doing just about as well as I can.
life
as fully
And my doctors
my
as
agree
L.
(a full
one month's
And that's
why I want to send you a free* trial
together
with your absolutelv
Free* bottle
of
supply) of HeartShield'",
CoEnzyme QlO capsules - a $15.00 value.
Pick up your special
gift
check that's
the
reply
envelope
Mail it in
the back.
Before
It
Read the offer.
enclosed.
provided
. . .
Expires!
-.
going to be taking HeartShield'"
Me? I’m sold.
I’m
edge.
HeartShield'",
I know I have that extra special
news is . . . you can have it, too!
Bill
P.S.
Sign
from now on.
And the really
With
good
Shick
A Free* bott le of CoEnzyme QlO capsules
waiting
to
support
your
Give you extra energy.
Sign the back.
offer.
* See back
of
gift
heart.
check for complete, offer.
Our
Superior,
- a $15.00 value - is
Maintain your gums.
Read the
Pick up your gift
check.
Before it exoires!
Mail it.
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MAKE
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AND
ADDRESS
IF NEEDED
NON-NXOTIARLE/CANNOT
From The
To:
Desk
BE CASHED
of:
[Firstname]
[Lastname]
[Street Address]
[Cityname],
[ST] [Zipcode]
[Month]
Dear
THIS IS NOT A CHECK
[Date],
[Year]
[Firstname],
I'd like
"all-natural"
to send you a FREE* l-month supply of Arthritis-Ease"
homeopsthic
remedy to relieve:
Pain. Swelling.
Stiffnes?
I've enclosed
the cost.
a gift
check with
your
name on it
for
$23.97
to cover
Sign the back of it. Return it to me in the reply envelope.
I-month supply of Arthritis
Ease‘ will
be rushed to you.
--It's
Why am I doing
amazing nutritional
Taking
-Here's
co-factors
FREE*!
this? The answer is simple.
drink:
Mega JointWellness""
Mega JointWellness?
Really
why: Mega JointWellnesstm
contains
specially
formulated
to maintain
In fact,
to function
I'd like you to try an
- on a 30-DAY FREE TRIAL!
Promotes
Joint
What is collagen,
vartilage.
the essential
you ask? It
building
is
Health!
a unique combination
of
healthy
joint
cartilage.
these clinically
proven ingredients
actually
properly
and normally.
How [FIRSTNAME]?
By supplying
A full
blocks
help
your
joints
of collagen.
the key structural
element
of your
Collagen is the "glue",
if you will,
that keeps your cartilage
intact
nd functioning
properly.
Without sufficient
collagen,
your cartilaGe
imply dries
out and wears away. Then, when you move, your bones "grind"
>gether where they join.
This can cause serious discomfort.
How can you avoid
's already begun?
ee back'of
gift
this
[FIRSTNAME] ? Or help
check for complete offer.
-------
__
reverse
this
trend
(Please
turn
if
over)
-2-
Spur your
body to produce
more collagen.
And that's
exactly
what the ingredients
in Mega JointWellness'm
They supply the co-factors
you need . . . to make more collagen.
O support
O maintain
O promote
O enhance
O support
Moreover,
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joints.
supplies
Mega JointWellnesst"
is known to:
In addition,
complex, which
do.
a glucosamine/chondroitin
the creation
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synovial
joint
ligament
and muscle health2
tissue,
spinal disk wellness)
the elasticity
of your vertebrae4
the normal formation
of cartilage5
fluid1
Mega JointWellnesstm
is perfect
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of Arthritis
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swollen,
sore
Mega JointWellnessr"
daily
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as 4-8 weeks.
is completely
safe, natural,
and effective
you can expect to notice results
within
Ready to get your FREE* Arthritis
Go to your Gift
Mega JointWellnesse"?
It's
that easy.
back. Mail it.
But do it
before
for
as
Ease"? And your 30-DAY FREE TRIAL of
Check. Read the offer.
Sign the
your
gift
check expires!
Sincerely,
awmcc -=bwk
tc.
Lawrence Tabak
Tabak's
President,
P.S.
Health
Products
Most people know a qood deal when they
A little
word of advice:
a &idal wave of
see one. And this is one of them. I'm expecting
the FREE Arthritis-Ease"to
responses to this offer.
I’m
limiting
first
1,000 customers who respond.
So whatever
* See back of
you do . . . don't
the
delay!
check for complete offer.
gift
Supporting
References
1 Crolle G and D’EsteE: “Glucosamtnesulfate for the management01arthrosis.” CurrentTherapeutrcresearch7: 104-9 (1980)
2 Mazreres,6. et al.: “Revue du Thumatrsmet des Maladtes Osteo-Articulares’.50(7-B): 466-72 (1992)
3. Pipitone.V.R.:“Chondroprotectronwith Chondrortrnsulfate.” Drugs in Experimentaland Clmical Research17(l). 3-7 (1992)
4. DOAmbrosioE, Casa B, Bompasi R. et al.. “Glucosamrnesulphate:a controlled cltnrcal rnvestrgationrn arthrosis ” Pharmatherapeutica2: 504-508 (1998)
5. Kelly GS, “The role of glucosammesulfate and chondroilcnsulfates in Ihe treatmentof degenerativejoint disease.” Altem Med Rev 3(l): 27-39 (1998).
A portion
These staiements have not
be%-
evaida!@
of our profits
si, the
go directly
Food and Drug
Admuxtrallon
Our
Guiding
-
to the Leukemia
& Lymphoma Society
This producl IS no! lnlended to dragnose, treat, cure, or preven! any disease
Philosophy:
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.
g
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TO ADDRESS
00286
IF NEEDED
12ZUU6I
lcll
Ex-School
Teacher
Tries
Amazing
New Vitamin
"95 Year Old Teenager"
Turns Into
I
Would You Like To Try It
. . .
NOTA
REALCHECK
121617
-
FREE*??
[FIRSTNAME LASTNAME]
[STREET mD~~ss1
[CITY STATE ZIPCODE]
Dear
Joseph Bergeron
Age 95
[Date]
[FIRSTNAME],
I'd like to send you a $10.00
System . . .
Absolutelv
.e
I've
enclosed
supply
a special
I'm Joseph Bergeron.
settlement
town of Little
sift
9 days my wife
Free*.
check,
with
your
started
MegaWellness'"
system!
noticing
to use.
- an amazing
a huge difference
The energy
I feel better
than I have in a long time.
from The MegaWellnesstm System is incredible!
It
name on it,
I was born September 29, 1905 in the small
Caillou,
South Louisiana.
Two years ago, I decided to try
multi-herb
multi-vitamin,
mineral,
Within
behavior.
of The MegaWellnesstm
multiin my
boost
I get
didn't
take long for my wife to send for her
own free trial
of The MegaWellness'" System.
Even though I'm 95-years old I act like one of the "young ones"
been building
muscle.
Believe
it or not I've actually
around here..
and
doing
some
stretching
I exercise
by lifting
my 4 pound weights
movements.
I can now walk
In addition,
tired.
I'm
so proud
The truth
is
without
getting
overworked
or
[FIRSTNAME].
. . I feel
Undoubtedly
a mile
like
[FIRSTNAME] all
* See back,of sift check for complete offer
a
"95-year-old
of
my
teenager."
new found
energy comes from
(Please turn over)
-2The MegaWellness'"
.
System.
I highly
recommend it
to everyone
. . .
young QJ old.
My friends
prised.
here
at the retirement
home can't
help
but be sur-
in the recreation
cenweek I came across a group of ladies
I offered
to show them some exercises
I thought would help
ter.
demonstrated
the workout,
and jumped up
I got on the floor,
them.
say to another,
"look how easily
he
only to hear one of the ladies
gets up off the floor."
Last
Moreover, my family
doing so well.
And I give
is delighted
all
to see their
the credit
Daddy happy and
to The MegaWellness"
With it I have--found enough energy to make it
I feel brighter,
still
feel great late at night.
it has even increased
my outlook
on life.
I also seem to remember things
someone my age.
better,
which
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through the day and
sleep better
and
is a real
plus
for
Add life
to your
Stay well?
Would T/OU like to have more energy?
It
reallv
If so . . . you need The MegaWellness'" System.
years?
works.
-.
Send For Your FREE* $10.00 Supply.
Read the offer.
Simply go to your enclosed $10.00 sift
check.
But
do
it
before
it
expires!
Mail
it.
Sign the back.
Don't
else.
If
wait.
you do, your
free*
supply
may be given
to someone
Sincerely,
Joseph Bergeron
P.S.
If I can feel like a teenager at 95 - imagine how it can make
Send for m
free* supply - a $10 value - today.
vou feel.
P.P.S.
* See back
Don't let
Your gift
check will
expire soon.
Right
now!
Send it in.
Endorse the back.
of gift
check
for
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that
happen.
offer.
A portron of our profits go drrectly to lne Leukemia & Lymphoma Society.
These stateme% have not been evaluated by !he Food ana Drug4dmintslralionThis product ISno1ir!e?dedlo diagnose treat, cure or prevenl a?y disease
Our
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IF NEEDED.
1 ii?i?no6
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10 1
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1235
NOTi
REAL CHECK
Receive A lo-Day Supply Of The Diet
Supplement Nature's
Shape'" . _ .
.
FREE*!!
[Month]
Date:
[Date],
[Year]
To:
[Firstname]
[Lastname]
[Street Address]
[Apt. #I
[ST] [Zipcode + 41
[Citynamel,
Dear
[Firstname],
.*
You've been selected
to receive a lo-day
Nature's
Shape'" - FREE*!
supplement,
supply
of the special
diet
The reason I'm so excited
is because the ingredients
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Shape'" can help give you the figure
m the weight loss results
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**Are
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of fad diets
*f Are you frustrated
you lose?
never
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throwing
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money down the drain
me," then you're
If you can say "That's
receive
. . .
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that
Nature's
automatically
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You can acquire a Free* supply of Nature's
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right.
"Secrets To Natural Weight Loss Guide" - a $15.00
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- when you use the special
gift
check enclosed.
That's
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value
Here's
what you'll
1) Free*
lo-day
receive
supply
of
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Nature's
Shape"
This special
new formula contains
decrease your appetite
and increase
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ma huang and guarana that actually
your energy at the same time.'
It's
ideal to take if you snack between meals or tend to overeat
mealtimes.
Why [FIRSTNAME]? Simply because it seems to . . .
* See back
of
gift
check
for
complete
offer.
(Please
turn
at
over)
make you feel really
full
so you won't want to eat.'
.
Plus, it gives you extra energy to get through you;
2) Free*
"Secrets
Natural
to
Weight
day.'
Loss Guide"
discover
the latest
methods for losing
In this Special Guide, you'll
starvation
diets or counting
weight and slimming your body, without
You'll
also learn how to tone your body and keep weight off
calories.
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Why a Free* Offer
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Because we're +bsolutely
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that once you try Nature's
you'll
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to
notice
the
most
amazing changes in your
Shape"",
starting
in
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(or waistline)
. . .
figure
And, once you see that Nature's
Shape'" REALLY WORKS, we're confident
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To receive your Free* lo-day supply of Nature's
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It's
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There's only one small
check today . . .
caveat:
Before
In order
it
not
to miss out,
mail
your
Expires!
Sincerely,
-,
\___
.’
3
1..
._*.
,-
--
._-_,.
-3
-
-
Brenda Griffitil
For Nature's
Shape'"
P.S.
You have nothing to lose
Why wait?
Send in your gift
check - before it
* See back
of
gift
check
for
complete
(except
exoires!
those
extra
pounds).
offer.
Supporting
References
1. RamseyJJ, Colman RJ. Swlck AG. KemnitzJW “Energy expenditure,body compositlon, and glucose metabolism in lean and obese rhesus monkeystreated wrth
ephedrineand caffeine.” AmencanJournal of Cliflrcal Nutritron. 68(l): 42-51, 19%
2. ToubroS, Astrup A, Breum L, DuaadeF. "Theacute and chronrc effects of ephedrme:caffeinemixtures on energy expenditureand glucose melaoohsmIn humans.”
Int J Obes Relat Melab Dlsord. 17 Suppl 3573-7; discussion s62. 1993.
0 compound compared
to ephedrine,caffeine ar.d placebo in obese
3. Astrup A, BreumL, Toubro S, Hem F DuaadeF. “Theeffectandsafetyof an ephedrine!caffeinsubjects on an energy restncled diet, A double blmd irial.” lniernational Journal of Obesityand RelatedMetabolism Dtsorders. 16(4): 269-77, 1992.
A portlon
of our profits go dlreclty to lhe Leukemia
e
& Lymphoma Society
These s:alements bade nor beer! evalua:eo by the Food and Drug i’dm!r~&::a!ion Tn:s proa,- 0 IS nol In!ended to diagnose, !reat, cure. or
prevent any drsease Always consult wrlh your dccror betzre oeglnrilng any weight loss p:ograrr. As wth any diet product, Ihe best results are
r( ‘I’: change your eatlng habE. yc;u’li simply regain
ob:a’neg when you lollow a low-lat die!. eal Sma!ler pc:trcns an3 exe!c;se :e?$Iarly It you “G.
weight over lime Follow label directIons lndlvrdual resul!s WIIIvary This product conta,ns Ma Huang afia Guarana. Do not abuse
Our
Suoerior,
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Nutritional
Supplements
5
00286
-Make correc!, T.,’: t0 address : -ieded.
12220061
101
121555
Not a real check
male vigor and sexual energy
.*. .-,_ :his amazing formula . . .
^ ‘3, supply is waiting for you . .
5 a L-4-L
Ifl~~~~SZ
[John ‘J. Safr@@
[I234 Main Streef’
[AnvtcJ/Jn, CA 99&l
[MONTH, DATE, YEAR]
Dear 11RSTNAMEj.
I have some gr5at ne\r.c -- - I_
increa::ing . . .
sspecialiy
if you’re a man who’s interested in
* r!Uie vigor
*
\ iribty
*
-W sexual energy
7.1: -3-2s to decrease with age.
Is 1’~: you [FIRSTNAt\?: - - - I ;-ab your $14.99 special Gift Check I’ve enclosed.
Sign til:’ Xck. Mail it to r-s -5-z -I 1 ?xpires.
1’11
1.3:
YOU
a
IO-day
I- :- all-natural formula, PotencyPlus’“, to trV.
-.
s,::
Th.; ‘:- day supply - a : - - 5 I
3 2 - is yours , . .
Free! *
Here’s whz:
: - +y 5:: Have Discovered About It’s Ingredients.
Yo’- “:‘.,?e helps entar
=- I I 1Is your body’s blood vessels. In one Clinical study in
Germ,: . . ,:ohimbins was-Z- _ L Z --- __(more effective in boosting feelings Of intimacy in men
.:
than t’\:’ .’ .Icebo.’
G/v--..‘,’:N/oba ha-,
-usyc-.
(Jife*-:: %..‘I Califo:-:Ca stu cjesir~:: ,\ -“Of”
tl/‘ofTr‘~y
-
-Drove circulation and keep blood flowing. In one
-1:
_ _ _ _ _ ziioba had a positive effect on the mascuiine drive and
=
=e
/q\*p
‘A LiffVa, [FI~=JNA,
_ _ - = your body free up testosterone, which stimulates
T -desirrs .< ~f~llmaCy. in one --y _ _
-he Institute for Advanced Study of Human Sexuality,
avenc?+va rncrea~~~ fee!,. : I- _.c-2 _ -1 macy in over 60% of men who had experienced
(Please turn over)
‘=.
- _ A;-~37?mi:lrajiOn Thrs prOddc; ,S flat Imended to diagnose.
vea:. cure or preven: a-y disease
- 2 -
age-related declines.’
e
Saw Palmetto Extract helps your body maintain a healthy prostate with helpful sterols and
fatty acids.”
While each of these ingredients alone are excellent for promoting male virility and vigor where they have declined due to age - together, they can worh even more effectively!
Why such a Free* offer?
Because I’m so sure PotencyPlus’” will help rekindle the intimacy in your life. And once
you try it, I’m confident you (and your partner) will love it so much, you’ll want to keep using
it everyday.
But don’t take my word for it. Try PotencyPlus’” yourself - &$
- for 10 days
Make your dreams come true. Pick up your special Gift Check. Read the offer. Sign Ihe
back. Mail it. It’s that simple.
Don’t wait a moment longer. I must hear from you ---A
within the next 11 days . .
Or Your Gift Check will Expire!
..
Howard Simpson
Research Department
PS.
You won’t find a better offer than this. Get a lo-day supply of PotencyPlus’”
Free.*
PPS. Your PotencyPlus’” will arrive in a confidential, non-descript, plain brown package.
* See back of gift check for complete offer.
Supporting References
1 Vogl HJ. et a/ “Double-blind placebo-controlled safely and efficacy trial with yohlmblne hydrochloride in the treatment ot nonorganlc erecflle
dyslunction ” Inf J lmpol Res 3 15.5-61, 1997
c
2 Cohen Al and Bartlik B “Ginkgo biloba for antldepressant-induced sexual dysfunction.” J Sex Mafifal Ther 2’139-43. 1998.
3 A recent study by the lnstltute for Advanced Study of Human Sexuaflty, “Effects on men sutfertng from sexual impotance.’
4 Champault G. el a/: “Medical treatment of prostatic adenoma Conrrolled trial PA 109 vs placebo in 110 patients “Ann Uf0/6.407-IO. 1984
A portion of our profits go directly to the Leukemia & Lymphoma Society
’ These statements have not been evalualed by the Food and Drug kdminlstralion.
diagnose, treat, cure, or prevent any disease.
This product is noi intended to
Our Guiding Philosophy:
Superior,
Science-BasedNutritional Supplements
z
N
Y
MAKE
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ADDRESS
Beverly
Chicago,
From:
-7.2 :
TO
IF NEE=)ED
A Frok* IO-day
be=
formula
[Firstname]
Tc:
[ Street
[Citynamel,
/
I
Carlsen
111.
I
supply
cf
is waiting
a rsvoiutionary
for yo2.
ilastnamel
Address]
[ST]
[Apt.
$1
[ZiFcode
+ 41
[Month]
Dear
To get ycur Free* supply
check with your name on it.
before
&
Here's
*
*
*
*
*
*
[Year!
all
*
*
*
*
*
ReFaze'"
else the enclosed
$15.CO gift
Endorse
tje back ar?d mail
ReFaze'"
formula
does
for
you
. . .
Remolsturizes
cell
structures.
Ge-ltly
attacks
wrinkles,
making t-hem less -Jisible.
Diminishes
the appearance cf fine lines.
Helps to reduce the "puffy-eye"
look.
Helps reduce the visibility
of age spots and Blemishes.
Helps you feel and loo:k years younger!
why it
The ReFaze'"
surface
the
to
the
help
works
so well
formula
create
nutrients
mole
you
crobvs feet, are definitely ;1lot
less noticeable.
Puffiness under my ryes
seems to have left me. My
skin is ti@x clnc!fimier.
The skin on my face and
neck feels much softer.
My skin seems to have
taken on a new, healthy gIow.
_ hlost importantly, friends
have commented on ho\\:
much younger I look. Send
for your free’ 1O-day s~pply.~
Beverly Car!sen, Age 59
[FIRSTNPNZ]:
loaded
is
[Firstname] ,can
you guess my age?
*The appexsnce of fine
lines and wrinkles, particularly
expires!
what
Here’s
at
[Date],
[Firstname],
A A
FreP* lo-day
supply
of z‘ne amazing
beauty
formula
is wai+ing
fcr you.
it
- ,i
i
with
vo,lvety,
natural
botanicals
smooth5:T,
that
wor:k cnder
yDUlJ?r-lOOking
t%e
Losk
Skin.
get:
cells.
Xacural
fruit
acids
co gently
remove dead surface
Su;lflower
oil
to nourish
new cells.
healthier
skin.
Kola nut, mate and GLarana to help maintain
Oat flour
to soothe
>rour skin.
Chamomile to help keep your skin soft
and supple.
So fast
[FIRSTNAXE] : The ReFaze'"
formula
and simple
to
can be applied
use
under
your
makeup
(Please
* See back of gift
/
check
for
complete
in
turn
offer.
--_____..
the
over)
-
morning
and before
you
go to
So ?t's
an ideal
way to
without
wasting
time.
And there's
another
bed
get
big
at
2 -
night,
smoother,
advantage
The ReFaze'"
formula
contains
30 seconds
healthier,
to
Natural
in
using
or
less!
younger-looking
the
ReFaze'"
skin
-
formula:
botanicals
natural
botanicals
for
"deep
level"
cell
care:
and lemon oranae,
Natural
fruit
acids
- bilberrv,
susar cane, maple,
Fine,
but what about
provide
gentle
exfoliation
to get rid of dead cells.
You can help protect
them from free
my new skin cells
underneath,
you ask?
radical
damage with
vitamin
E and green tea, which are included.
greasy.
Suitable
And more beautiful?
a whole lot younger?
Mail it to
Endorse
it.
Read the back.
Take
me in the
Easy
The ReFazetm formula
is safe.
for all
skin types.
.And it works!
Best
of
all,
a FREE* lo-day
Ready to start
looking
your $15.00
gift
check.
reply
envelope
. . .
supply
Before
Not
to
use.
is
waiting
it
for
oily
or
you.
I
expires!
..
Sincerely,
Beverly
For the
P.S.
P.P.S.
Caflsen
ReFazec"
formula
Send for your
$15.00
value.
Free*
lo-day
supply
of
the
amazing
ReFaze'"
formula
- a
endorse'the
back of your gift
Instead,
Don't
send any money.
Don't
Place
it
in
the
reply
envelope.
Before
it
expires.
check.
I've
never seen a better
Run to the nearest
mailbox.
walk.
faster
- don't
opportunity
to look younger
and more beautiful,
miss
out!
Please
act
* See back
now
of gift
. . . before
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for
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complete
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check
expires!
c
offer.
A portion ot our profits go dreciiy to the Leukemia & Lymphoma Society
I-
Tnese staIer?erils have nor been evaluated by
disease
ihe
Food and 3rug Adzmc!rai,cn
I
Our
Superior,
This prcduc: IS no1 mlenaed lo OagQose. !:ear. cure, or preveni any
Guiding
Science-Based
Philosophy:
Nutritional
Supplements
iaPLEASE
1
No (
MAKE
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NAME
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AND
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S5898OL~
No-r I C”(ECK
ABOVE
C.Y”OT
007
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A FREE Bottle
of Chromium
Picolinate
is Waiting
For You . . .
[Firstname]
[Lastname]
[Street
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[ST] [Zipcodel
[Citynamel,
[Date]
Dear
I'd
[Firstname],
like
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I!;;
What's more,
you to use.
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shown to:
reduce
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[FIRSTNAME].
eyes-glaze-over
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(Please
These siatewms
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turn
over)
avi disease
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it
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Stipporring
Fleferen~es
1 R A 4noerson. “Nulrllional 9ole 01 Cn:o~t~um,” kence 01 To!~! Env!ronment. 17. p 13 (1981)
rncn Tolerance ant! Serum Ltp~ds iriclilrjing HDL of Adu!l Me?,,” An J
on GIJ-,~~
2 R 5a,ies. M J Albrlni\ “Eliecr of Chro?Ium Ctilcrlde Sc;pp!e"enia'iort
Clan Mr 34, p 2670 (:981)
*2~ol1sm ar.d Eflecl 01 Chronwm Supplemental~cn,” Am J C;n Nurr 38 p 574
3 G Saner. H Gunoz and S C@dem. ‘Yllerailons 31 Chro”nrum Me?,,
( 1993)
4 W Me,n and WE Cornatzer, “Chr~mlum Metat0lsm the G!ucose Tolerance Factor,” In Kewe! Trace Elements In biutrltiori, Marcei 3ekke,. I&W York,
pp 120-50 (1997)
A portion ol our ptol~ts go directly IO the Leukemia & Lymphoma Society
Ti-es@sIarernen[s have not been evalual& oy the Food and Drug a3mwtralton
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L22OOLL
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HOT A
REAL CHECK
L2L235
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[FIRSTNAME]
[LASTNAMEI
[STREET ADDRESS1
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EZIPCODEI
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To:
[MONTH1 IDAY 1 I
Dear
[Firstname],
You've
been
ThinkCaps'".
selected
to
..
I've
I'll
[YEJW
tell
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you how to use it in a moment.
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[FIRSTNAMEl.3-4
(Please turn over)
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REALLY
supply
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please
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it.
-.
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Sincerely,
_.---- : I
/ *- .--?--,_--, __.
,
i;;.#g y, ,';
.A
,. ,_.J.'I<.j Lb*!-..L
Lawrence
President,
Tabak
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* See back of gift
check
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Health
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[FIRSTNAME LASTNAMEI
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* See back
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[FIRSTNAME] are atoms that
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These starements have no! been &aluar&
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by the FsO:! and Drug 4dmXJra:~On
are highly
reactive
(Please turn
This ptOduCl 6 nOI mlwded
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IO dtagnose teal Cure, Cr Drwenl an,, disease
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2
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A portlori 01 our profits go directly lo the Leukemia & Lymphoma Society
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These sl~le~,pn~s have no1 hen
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nG!
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To:
[FIRSTNAME]
[LASTNAME]
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[CITY],
[STATE],
[ZIPCODE]
[BAR CODE]
Li-LG-7
55898
NoTA
REAL CHECK
of glucosamine
healthy
joints
[MONTH]
[DAY],
[YEAR]
.I
Dear
[FIRSTNAME],
I'd
like
to
send
you
a bottle
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find
your
a $12.00
gift
free'
bottle.
Glucosamine
Sulfate
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help
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has
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ligaments.*
formation
the
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and
like
See b&k
c,~,,nmon,r
to
of
simple
send
of gift
check
h,,l,a
o,,p,, ,g,on t... <,.o r-e,.
~ln, hoon
.
.
you
a healthy
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Glucosamine
of
Sulfate
todav
to
need
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normal
synovial
[FIRSTNAME
]?
-
[FIRSTNAME]..j, -.;
you
for
of
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.
.
wel1ness.l
for
is
. .
and vertebrae
provide
I'd
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to
disk
why a FREE* bottle
i
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l
check
been
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Absolutelv
You'll
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offer
a 30-day
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qnr( rx,n
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All
safe,
natural
aentle
- without
stomach
receive
pain!
Do you
Shoulders?
one cent
less
comes
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need relief
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fingers?
check
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For Arthritis-Ease"
P.S.
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your
* See back of gift
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check
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- SupportIng References-
1. AlternatIveMedicrne Review, June : 999
2. Annals of Pharmacotherapy,May 199E. de CamaraCC and Dowless GV.
3.Cranro,Oct. 1998. ShanklandWE 2nd
Our Guiding
Superior,
Science-Based
4 AlternatrveMedlclne Revrew,Feb 1998. Kelly GS
5. Lrpids. NOV 1998. James MJ. et at
Philosophy:
Nutritional
Supplements
..
of