UNITED STATES OF AMERICA
FEDERAL TRADE COMMISSION
____________________________________
)
)
In
the Matter of
)
DOCKET NO.
)
ROAD
TO HEALTH, INC.,
)
a
corporation, and
)
)
RUTH
L. O’SULLIVAN,
)
a/k/a/
Bonnie O’Sullivan,
)
individually,
and as an officer
)
of
the corporation, and
)
)
DALE
MAXWELL,
)
an
individual.
)
____________________________________)
COMPLAINT
The Federal Trade Commission, having reason to believe that Road to
Health, Inc., a corporation, Ruth L. O’Sullivan, a/k/a Bonnie O’Sullivan,
individually and as an officer of the corporation, and Dale Maxwell
(hereinafter "respondents") have violated the provisions of the
Federal Trade Commission Act, and it appearing to the Commission that this
proceeding is in the public interest, alleges:
1.
Respondent Road to Health, Inc., is a Nevada corporation with its
principal office or place of business at 1135 Terminal Way, Suite 209, Reno,
Nevada 89502-2168.
Respondent Ruth L. O’Sullivan, a/k/a Bonnie O’Sullivan,
is the president of the corporate respondent. Her business address is
the same as that of the corporate respondent.
Individually or in concert with others, she formulates, directs, or
controls the policies, acts, or practices of the corporate respondent.
Respondent Dale Maxwell is an independent contractor performing services
for the corporate respondent. For
purposes of the activities described in this complaint, his business address
is the same as that of the corporate respondent.
Together with respondent Ruth L. O’Sullivan, he has participated in
the acts and practices described herein.
2.
Respondents have manufactured, promoted, advertised, labeled, offered
for sale, sold, and distributed directly to the public various products,
including the Zapper, Colloidal Silver Generator, P.A.R.-134 Body Soak,
Freeze Dried Black Walnut Hull, and 21 Day Tumor Reduction Program,
including by means of an Internet Web site,
<www.road-to-health.com>.
The Zapper and Colloidal Silver Generator are
“devices” within the meaning of Sections 12 and 15 of the Federal Trade
Commission Act. Freeze Dried
Black Walnut Hull and 21 Day Tumor Reduction Program are
“foods” or “drugs” within the meaning of Sections 12 and 15 of the
Federal Trade Commission Act.
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.
4.
Respondents have disseminated or has caused to be disseminated, via the
Internet among other means, advertisements or promotional materials for the Zapper,
Colloidal Silver Generator, P.A.R.-134 Body Soak, Freeze Dried Black Walnut
Hull, and 21 Day Tumor Reduction Program, including but not
necessarily limited to the attached Exhibits A-E.
These advertisements contain the following statements, among others:
21
Day Tumor Reduction Program
Our
Price: $1,900.00
Dr.
Clark's New 21 Day Program for Advanced Cancers
The 21 day
program is described in detail in Dr. Clark's new book "The Cure for All
Advanced Cancers". Caution: It is intended for severely ill patients and
not for prevention purposes.
We have seen
amazing results in hopeless cases with this program that are nothing short of
miraculous. But bear in mind that
the dental clean‑up and other clean‑ups are still the core
of the therapy;
no therapy in medicine works in 100% of the cases, and be it just for
lack of correct application;
the best results are only possible if Syncrometer testing is available.
Excellent results are possible without if a radical approach is chosen, but
Syncrometer testing definitely makes improved care possible.
Exhibit A, from www.road-to-health.com
Zapper,
Model B5 Continuous,
Copper
Handholds
Our
Price: $95.00
Zapper, Model B5,
continuous, copper Hand Holds This Zapper comes with copper pipe hand holds
and has one frequency (Dr. Clark's 30K frequency). This is a continuous Zapper
you will need to use your own timer when Zapping with this unit. "If you
have been suffering from a chronic infection or have cancer, or AIDS, learn to
build the electronic device that will stop it immediately [or buy one]. It is
safe and without side effects and does not interfere with any treatment you
are now on. (From: "The Cure for all Diseases", after cover;
copyright notice) "Any positively offset [DC] frequency kills all
bacteria, viruses and parasites simultaneously given sufficient voltage (5 to
10 volts), duration (seven minutes), and frequency (anything from 10 Hz to
500,000 Hz). "But it takes more than one treatment. It takes three
treatments to kill everything. Why? The first zapping kills viruses, bacteria
and parasites. But a few minutes later, bacteria and viruses (different ones)
often recur. I conclude they had been infecting the parasites, and killing the
parasites released them. The
second zapping kills the released viruses and bacteria, but soon a few viruses
appear again. They must have been
infecting some of the last bacteria. After a third zapping I never find any viruses, bacteria or parasites, even hours later".
(From: "The Cure for All Diseases" P. 15;
copyright notice)
Exhibit B, from www.road-to-health.com
LN,
PAR Soak, 32 oz.Kills Parasites w/High
Frequency
Signals
Our
Price: $52.00
"Body
Soaks work even when all else fails"
. . . . .
P.A.R.‑134
Body Soak
Parasites Only
Besides creating
an unlivable atmosphere for parasites, P.A.R.‑134 uses high frequency
signals to “zap” living parasites and their eggs. Should be used with
PAR‑534 Oral Drops. Item
PAR‑134, 32 ounces
Suggested Retail
Price $52.00
Exhibit C, from www.road-to-health.com
Black
Walnut Freeze Dried, 300
capsules,
50 capsules, 6 Pack
Our
Price: $150.00
Freeze dried
Black Walnut Hull General (non cancer) 3 Capsules 3 times per day for two days
‑ then once per week 3 capsules one time. Cancer 3 Capsules 3 times per
day for four days ‑ then once per week 3 capsules one time Pets at same
time one cap each pet in food 2 times a day. Then once per week 1 time per
day. Larger Dogs 2 caps instead of one cap. Weekly test: Take 3 once per week,
watch the urine for small white spots or clouds. If you see these then do the
2‑4 days of 3 times a day again because you have the parasites again.
Everyone in the household should do the program at the same time. If they do
not take the Black Walnut they will reinfect the family.
Exhibit D, from www.road-to-health.com
Silver
Generator (to Make Homemade
Colloidal
Silver)
Our
Price: $89.00
. . . . .
What is
Colloidal Silver?
Colloidal silver
is a solution of extremely fine submicroscopic particles of pure silver
suspended in water by a positive electric charge on each particle. The
particles remain suspended throughout the solution because these
positive‑charged particles repel each other with a greater force than
gravity . A powerful germicidal, silver is an exceptional metal in that
it is non‑toxic to the human body, but lethal to over 650
disease‑causing bacteria, viruses, fungi, parasites, and molds; while
conventional pharmaceutical antibiotics are typically effective against only 6
to 7 types of bacteria. Some new strains of bacteria classified as MDR
(Multiple Drug Resistant) have proven to be resistant to all
pharmaceutical antibiotics, but not to colloidal silver due to
different germicidal mechanisms of deactivation.
Silver filters
are found in the water fountains of every airliner and space craft to
guarantee germ‑free water. Silver is used also by the Soviets to
sterilize recycled water aboard the Mir Space Station.
Silver is being used to replace chlorine in swimming pools, because it
does not sting the eyes and offers greater germicidal action. Laboratory tests
have shown that Colloidal Silver will kill all known bacteria, fungi, viruses
and parasites within 2‑6 minutes of contact. Many chronic infections,
from pyorrhea to vaginal yeast infections, conditions which are often
resistant to drug therapy, will quickly clear up with Colloidal Silver.
. . . . .
The following is
a partial list of the more than 650 disease conditions in which colloidal
silver has demonstrated proven clinical improvement: Acne, Acne Rosacea,
Anthrax Bacilli, Arthritis, Athlete's Foot, Blood Poisoning, Bladder
Infections, Bubonic Plague, Blood Parasites (causes gray hair), Cancer,
Candidia (Yeast Infection), Chilbains, Cholera, Chronic Fatigue, Colitis,
Conjunctivitis, Cystitis, Dermatitis, Diabetes, Diptheria, Dysentery, Eczema,
Fibrositis, Gastritis, Gonorrhea, Hepatitis, Herpes Virus, Hay Fever,
Impetigo, Influenza, Keratitis, Leprosy, Leukemia, Lupus, Lyme Disease,
Lymphagitis, Malaria, Meningitis, Neurasthenia, Ophthalmia, Pheumonia,
Pluerisy, Pruritis Ani, Psoriasis, Pymphagitis, Rheumatism, Rhiritis,
Ringworm, Rosacea, Scarlet Fever, Seborrhea, Septicemia, Shingles, Skin
Cancer, Staph Infection, Stomach Flu, Strep, Syphilis, Tonsillitis, Toxemia,
Trench foot, Trachoma, Tuberculosis, Whooping Cough.
Exhibit E, from www.road-to-health.com
5.
Through the means described in Paragraph 4 respondents have
represented, expressly or by implication, that:
1.
The 21 Day Tumor Reduction Program is effective in the treatment of
advanced cases of cancer.
2.
The Zapper is effective in the treatment of cancer, AIDS, and chronic
infections.
3.
Three treatments with the Zapper are effective to kill all viruses,
bacteria and parasites in a person’s body.
4.
The P.A.R.-134 Body Soak, used in bath water, kills parasites within
the body with high frequency signals.
5.
Freeze Dried Black Walnut Hull is effective in the treatment of cancer.
6.
Colloidal silver, as produced with the Silver Generator, when ingested,
is effective to treat more than 650 diseases and conditions including
leukemia, tuberculosis, anthrax, bubonic plague and cancer.
6.
Through the means described in Paragraph 4, respondents have
represented, expressly or by implication, that they possessed and relied upon
a reasonable basis that substantiated the representations set forth in
Paragraph 5 at the time the representations were made.
7.
In truth and in fact, respondents did not possess and rely upon a
reasonable basis that substantiated the representations set forth in Paragraph
5 at the time the representations were made.
For example, there are no competent and reliable clinical studies
demonstrating that colloidal
silver is effective in the treatment of anthrax.
Therefore, the representation set forth in Paragraph 6 was, and is,
false or misleading.
8.
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.
THEREFORE, the Federal Trade Commission this day of ________, 2001, has issued this complaint against
respondents.
By the Commission.
Donald S. Clark
Secretary
SEAL: