RevOffers.com & CBDoilreview.org - UNETHICAL FTC proposal - Jason Brett - Matthew Stein

PROPOSAL FOR THE
UNITED STATES OF AMERICA
BEFORE THE FEDERAL TRADE COMMISSION




In the Matter of

REVOFFERS, INC., a corporation,

And

CBD OIL REVIEWS, a corporation,


JASON BRETT, individually and
as an officer of REVOFFERS, INC.,

And

MATTHEW STEIN, individually and
as an officer of CBD OIL REVIEWS, INC.,

PROPOSED COMPLAINT

Company victims have collectively decided to inform The Federal Trade Commission, having reason to believe that RevOffers and CBD Oil Reviews. (“RevOffers and CBD Oil Reviews” or the “Company”), Jason Brett, individually and as an officer of RevOffers and CBD Oil Reviews, Matthew Stein, individually and as an officer of RevOffers and CBD Oil Reviews, and Jason Brett, individually and as an officer of RevOffers and CBD Oil Reviews (collectively, “Proposed Respondents”), have violated provisions of the Federal Trade Commission Act, and it proposed to the Commission that this proceeding is in the public interest, alleges:

1. Proposed Respondent RevOffers and CBD Oil Reviews., also doing business as RevOffers and CBD Oil Reviews, is a Delaware corporation with its principal office or place of business at 315 S. Coast Highway 101, #528 - Encinitas, CA 92024

2. Proposed Respondent Jason Brett (“CEO”) is the co-founder and Chief Executive
Officer of RevOffers and CBD Oil Reviews. Individually or in concert with others, he controlled or had the authority to control, or participated in, the acts and practices of RevOffers and CBD Oil Reviews, including the acts and practices alleged in this proposed complaint. His principal office or place of business is the same as that of RevOffers and CBD Oil Reviews.
3. Proposed Respondent Matthew Stein (“Co-Founder”) is the co-founder and Chief Technology
Officer of RevOffers and CBD Oil Reviews. Individually or in concert with others, he controlled or had the authority to control, or participated in, the acts and practices of RevOffers and CBD Oil Reviews, including the acts and practices alleged in this proposed complaint. His principal office or place of business is the same as that of RevOffers and CBD Oil Reviews.

4. Proposed Respondent CEO & cO-founder of Product of RevOffers and CBD Oil Reviews. Individually or in concert with others, he controlled or had the authority to control,
or participated in, the acts and practices of RevOffers and CBD Oil Reviews, including the acts and practices alleged in this proposed complaint. His principal office or place of business is the same as that of RevOffers and CBD Oil Reviews.

5. Proposed Respondents have marketed CBD OIL products to consumers.

6. The acts and practices of Proposed Respondents alleged in this proposed complaint have been in or affecting commerce, as “commerce” is defined in Section 4 of the Federal Trade Commission Act. Proposed RespondentS’ BUSINESS PRACTICES

OVERVIEW

7. Since 2014, Proposed Respondents have operated the website www.RevOffers and CBD Oil Reviews.com, which they promote as a resource for consumers in search of CBD products such as CBD OILS for direct consumers. In numerous instances, Proposed Respondents have described the content on the website, including their rate tables, star ratings, and rankings of the companies offering these CBD products, as “objective,” “honest,” “accurate,” and “unbiased.” In reality, this content is not objective and, instead, is based on compensation from the companies. In addition, Proposed Respondents have touted positive consumer reviews about their company and website that, in fact, were written by RevOffers and CBD Oil Reviews employees or their friends, family members, and associates. Proposed Respondents’ RevOffers and CBD Oil Reviews Website.

8. Many consumers have learned of RevOffers and CBD Oil Reviews while searching or shopping for CBD OILS or other CBD products. Proposed Respondents have promoted RevOffers and CBD Oil Reviews through social media, content marketing, and search engine advertising, including with Google’s AdWords, and search engine optimization strategies. Google search results for “best CBD OIL Companies,” for example, include an organic, non-paid Google “featured snippet” for “RevOffers and CBD Oil Reviews’s picks for We at CBD Oil Review specialize in independent vetting of cannabidiol (CBD) vendors. We go to great lengths to verify the safety and authenticity of CBD ...” with a link to Proposed Respondents’
Website: https://cbdoilreview.org/



Best CBD Oil companies Rated from 1 (one) Star to 5 (five) Stars
” with a link to Proposed Respondents’
Website: https://cbdoilreview.org/cbd-companies/ stating :”
Not All CBD Oil Companies are Created Equal
This is why we've created a simple system of badges:

Each badge earned is worth one star or point. The best score possible is 5.”
With a link and disclaimer stating “Discover how these badges are earned”
” with a link to Proposed Respondents’
Website: https://cbdoilreview.org/our-methodology/

“Our Methodology
What it takes to get each COR badge
We evaluate every company the way any consumer would: through the information they provide on their websites. We call this “front line QC” (QC = Quality Control) and it’s how we aim to empower consumers with objective scrutiny and unbiased evaluation – using the information companies themselves provide.

Not All CBD Oil Companies are Created Equal
This is why we've created a simple system of badges:
Each badge earned is worth one star or point. The best score possible is 5.


Broad claims like ‘the most potent,' ‘from the best source,' or ‘the highest quality,' are simply not sufficient to put consumers’ minds at ease.
Although only using industrial hemp and providing recent certificates of analysis are together ample to qualify for this particular badge, we give special shoutouts to those that go above and beyond by implementing the practices mentioned below.
Priority 1: 100% organic hemp
To be awarded the Quality badge, we need to know whether organic (or otherwise sustainable) farming practices are in use with the hemp crops selected for product creation. Organic certification is a virtually foolproof way to ensure that CBD products are truly free of residual toxins common to agriculture: pesticides, herbicides, heavy metals, GMOs, and synthetic fertilizers/soil additives.

Requirements:
Up-to-date certificates of analysis that show the source material is free of the contaminant categories listed above and/or up-to-date organic certification documents.
Priority 2: Conscious agriculture
We also look for the region in which the plants originate; certain regions like Northern California, Colorado, and Scandinavia tend to have higher quality control and more experienced growers. We are thrilled when we learn of a company using high-CBD hemp cultivars – and even more so when they speak of biodynamics.
Requirements:
Proof of origin through various means of national and international certification

A primary concern we have at COR is ensuring we do our best to promote the health and well-being of all those with which we co-inhabit the Earth. This passion for optimal health is why the criteria for the Safety badge are perhaps the most rigorous of the lot.
Priority: Detailed and recent certificates of analysis
We look for a company to publish full certificates of analysis (CoAs) for each product/batch that is currently for sale. Simply having a CoA from a batch of source material tested a year ago doesn’t prove anything – except that it’s time to renew your CoAs! Simply claiming to manufacture in a ‘GMP-certified facility’ or claims of ‘high quality’ without evidence will never be sufficient for us.
While this might sound excessive, there is a good reason for such strict policies: the most common contaminants found in cannabis/hemp all have the potential to cause serious bodily harm. This unfortunate reality is why we do our best to inform consumers about which brands can be enjoyed worry-free. Safety first!
Requirements:
Full and recent certificates of analysis for source materials as well as for specific batches.
CoAs must test negative for: heavy metals, residual solvents, microbial and fungal contaminations, and excessive THC (generally >0.3%).

The Mission badge is a tricky one, as businesses don’t often publish a compelling, outright mission statement. However, most CBD companies qualify for this badge, so it is especially troubling when not a single positive intention appears on a company’s website.
Priority: Having a clear mission and/or vision
Although it makes our job easier when companies publish a clear statement of intent, much of the time the motives behind the founding of a company are incredibly difficult to decipher.
Certain phrases like ‘creating the highest quality cannabis medicine possible’ or ‘setting the bar for quality and safety in the CBD industry’ are fine jumping off points for the Mission badge – but ideally we like to see something with a bit more gusto.


Requirements:
A compelling mission and/or vision statement, demonstrating goodwill towards consumers (as opposed to profit or prestige motivations) and the planet.

The Charity badge is perhaps the best indication that people with hearts of gold are running the show at any given cannabinoid company. If a company clenches the Charity badge, rest assured that compassion and mindfulness are top priorities.
Priority: Verifiable charity
To be awarded the Charity badge, we require clear communication from the company as to their charitable endeavors.
Openly stating on their website that they make contributions to a verifiable non-profit organization of their choosing.
Alternatively, ‘compassionate care’ programs also suffice to receive this badge; some CBD companies offer discounts to those who are verifiably disabled, suffer from a chronic condition, or to those who have a child who may benefit from cannabinoid products. As a general rule, we prioritize these companies and do our best to support such selfless efforts.
CBD Oil Review is proud to partner with Wholistic Research and Education Foundation, a public non-profit (501c3) dedicated to CBD research, education and advocacy. Wholistic Research and Education Foundation collaborates with philanthropists, corporations, and research institutes to explore how and why CBD may benefit a wide range of health conditions by funding medical and scientific research. Please contact Wholistic Research and Education Foundation directly to learn more about partnership opportunities.

Although this badge is handed out to a majority of the companies we review, it is still an essential qualification we track for CBD businesses. If we see a company offering only the most basic products, with no discussion about advanced techniques or any other discerning factors, they will not qualify for the Innovation badge – no matter how much a company may claim to be innovative.
Priority: Thinking about the future
There are many ways to go about being innovative. Making progress and advancements is crucial to this industry, and that’s why we award this badge – to try to encourage CBD companies to think outside of the box and blaze the trail forward.
Requirements:
Quite a few things will qualify one for the Innovation badge, including (but not limited to):
Offering a water-soluble/microencapsulated CBD.
Utilizing advanced extraction techniques (such as organic ethanol or supercritical CO2).
Using advanced systems to monitor environmental conditions in a grow room.
Blending terpenes/botanicals/nutraceuticals with CBD in a novel way.”


“Top Verified CBD Brands”
Website: https://cbdoilreview.org/cbd-companies/ stating :”
https://cbdoilreview.org/cbd-companies/
CBD Oil Review also appears as the third non-paid search listing below this snippet.
9. When consumers visit RevOffers and CBD Oil Reviews’s home page, they have seen a screen similar to the following:



9. Proposed Respondents have encouraged consumers to use their website “confidently” and to “Trust their verified badge system” in one place. As depicted above, the website allows
consumers to choose from various CBD products, including rate, private
CBD OIL companies”.

10. As one example, consumers selecting consumers opting to choose from any CBD companies not rated a 5 star badge or in some instances a 4 star badge will be redirected to a promotional CBD OIL company that is only signed up as an Paid Affiliate to their company REVOFFERS a offering the CBD product.

11. In the instance that a consumer would choose to want to shop a 4 start badge or less the reviews are made and rated by the editor not a consumer and will not allow directive to the product.

12. The product is rated by what is available in regards to information not actual product review for CBD OIL companies have confirmed 4 star badge and less have not been contacted to purchase rate or retrieve correct product descriptors or certifications to accurately post a editor review to the public.
The top of the page has looked similar to the following:



13. Editor profile name for its account represents itself as a faux “Sherlock Holms” it’s verbal review states the following”

About The Editor
We're consumers of CBD products too and after being fed up with such a disorganized CBD landscape we created this to level the playing field. We want to help you find the right CBD oil products so that you too can thrive! Got a question? Contact Us.
Link t0 “contact us” refers to company contact page:
https://cbdoilreview.org/about-us/










14. Scrolling to CBD OIL companies, Proposed Respondents show a rate table that compares these best companies, such 5 star rated companies will most always have a link in where the product can be purchased some may contain coupons. The link will redirect to a trackable REVOFFER affiliate tracking & purchase for the selected CBD OIL company and or affiliate.








15. This pattern repeats itself throughout most 5 star rated companies included in these are the following. Of which they are charged a fee advertising as well as a fee for they given rate and and merchant processing fees as per their REVOFFER website.

Endoca Review
Receptra Naturals Review
Mana Artisan Botanics Review
Aspen Green Review
Sera Labsâ„¢ Review
Joy Organics Review
CBDfx Review
CBD American Shaman Review
NuLeaf Naturals Review
Moon Mother Review
TrustBo Review
Serene Cannabis Review
Soothe CBD Review
Aspen Green Review
FOCL Review
Plant People Review
Root Bioscience Review
Naternal Review
Empower® BodyCare Review
GoGreen Hemp Review
Absolute Nature CBD Review
King Kanine Review
Hawaiian Choice Review
Ananda Hemp Review
Relive Everyday Review
PhytoLogicaâ„¢ Review
Evolution CBD Review
Vital Leaf Review
UnCanny Wellness Review
SunSoil Review
RE Botanicals Review
Joy Organics Review
CBDistillery Review
Prime Sunshine Review
NutraCanna Review
Ambary Gardens Review



16. CBD Companies that have terminated services or that are no longer an affiliate will not have an available link for consumers to purchase product. Some instances a promotion for an active affiliate will “pop up” as an option” unrelated the the consumer company search.







17. Over 442 and counting CBD companies have been listed on their website with less than 4 sar badges with no directive for purchase other than CBD OIL REVIEW / REVOFFER affiliates.
Companies rated have not been rated by the public nor have been rated honestly by the CBD OIL Review in a true form. Reviews have been made systematically to promote revenue to CBD OIL Review and its affiliates misleading consumers as well as harming the reputation of these companies.

18. CBD oil reviews has used SEO practices to have consumers find CBD oil Reviews when searching for valid reviews by listing non rated companies and by rating companies that do not wish to be affiliates or can not be reached to be an affiliate member for REVOFFERS.

19. Companies that have been systematically targeted to give the appearance of volume reviews done by the “Editor” or review board , have been listed below.



Companies with 4 to 1 star rating are located in their CBD OIL company page https://cbdoilreview.org/cbd-companies/

List is attached below:









20. The web page layout for other CBD products is similar and has included a rate table,
rankings, star ratings, and reviews. Proposed Respondents Represent that RevOffers and CBD Oil Reviews’s Content Is indirectly Influenced by Compensation to CBD OIL Review and REVOFFERS.

21. In numerous instances, Proposed Respondents have represented that the resources on their website, including the rate tables, star ratings, and rankings, are “objective,” “honest,” “accurate,”“unbiased,” and not based on compensation. Proposed Respondents, for example, have represented thattheir “ratings are completely objective and not influenced by compensation in anyway [sic].”Proposed Respondents also have claimed that their “research, news, ratings, and assessments are scrutinized using strict editorial integrity.” Proposed Respondents have further represented that their “editorial staff and independent contractors do not receive direction from advertisers on our website” and “are not rewarded in anyway [sic] for publishing favorable or unfavorable reviews.” A webpage about “editorial integrity” signed by Proposed Respondent CEO represents that the information on Proposed Respondents’ website is “honest, unbiased, and fact based.” Similarly, a webpage about “RevOffers and CBD Oil Reviews Partners” written by Proposed Respondent CEO represents that “[w]e do
not publish favorable (or unfavorable) reviews or assessments at the direction of any company.”

22. Proposed Respondents have described their resources as “designed to help consumers better understand and make choices about which products fit their needs.” Proposed Respondents have further represented that they “do not publish favorable or unfavorable reviews or ratings at the direction of any companies,” that their “editorial staff and independent contractors are tasked with providing accurate and fact-based analyses,” and that their “editorial staff and independent contractors are not rewarded in anyway [sic] for publishing favorable or unfavorable reviews.” Proposed Respondents also have touted their extensive experience reviewing and researching internet CBD OIL review marketplace and affiliate marketing services companies since 2014.

23. The RevOffers and CBD Oil Reviews website also has a page devoted to explaining its methodology for analyzing the CBD products promoted on the website. Proposed Respondents have claimed that the Company’s staff rigorously uses objective criteria to rank and review Affiliates, including “Grow Your Affiliate Revenue RevOffers was built to help publishers like you monetize your traffic with high-converting offers. We bring you the best so you can focus on driving revenue. If you are a high-integrity publisher, affiliate or influencer who wants exclusive access to the most exciting and transformative brands, then RevOffers can help you increase your earnings while making a positive impact.
.” “Acquire More Customers Brands gain access to hundreds of curated publishers, affiliates and influencers across our network. If you’re an impact centric business with ethics grounded in conscious capitalism we’d love to help you grow your company on performance. RevOffers is where you will only pay for results because we’re fueled by performance.“



Site location : https://revoffers.com/

24. More recently in 2019, Proposed Respondents have represented that they weigh different criteria based on their importance for that product or service:

25. In addition to explaining the criteria purportedly used by Proposed Respondents to analyze each company, Proposed Respondents have sought to reinforce the objective and non-paid nature of their ratings and reviews by representing that “[e]ach piece of criteria is cross checked and audited by multiple members of the RevOffers and CBD Oil Reviews team.”
Proposed Respondents Rank CBD OIL Companies Based on Compensation.

26. Contrary to their claims, Proposed Respondents have provided CBD OIL companies with higher numerical rankings or star ratings and higher positions on rate tables based on
compensation. Proposed Respondents also have added or removed companies from their content based on compensation.

27. In numerous instances, Proposed Respondents have required CBD OIL companies to increase their payments to RevOffers and CBD Oil Reviews to maintain or improve upon their current rate table positions and rankings. Proposed Respondents CEO, Co-Founder, and CEO either directly requested additional compensation from CBD OIL companies in exchange for better placements on Proposed Respondents’ website, or had knowledge of such requests The company ultimately agreed to rating for the number one ranking and rate table placement.






28. The conversation between the company and RevOffers and CBD Oil Reviews expressly provided that RevOffers and CBD Oil Reviews would rank and have good ratings with the companies “[n]o lower than position 4” on RevOffers and CBD Oil Reviews’s CBD OIL Reviews Webpage.

29. Another CBD OIL Company paid Proposed Respondents for the number two rating and rate table position prior to the company above and, later, increased after the sign up to their affiliate program.

30. Proposed Respondents’ paid placement policies and practices have resulted in some previously highly ranked companies dropping spots for refusing to pay for their raking. For example, Proposed Respondents ranked one CBD OIL Company two stars in the rankings and listed it second in the rate table for several months. When the company refused to pay more to be placed in the second spot, Proposed Respondents dropped the company’s ranking to five star lower in the rate table for no reason other than non affiliation.

31. Proposed Respondents have repeatedly acknowledged to CBD OIL companies doing business—or seeking to do business—with them that they can pay for rating, even though Proposed Respondents have publicly represented to consumers that their website content is not based on compensation.

32. In correspondence with CBD OIL companies, Proposed Respondents have represented that
the rankings and rating table placements influence a consumer’s choice in visiting particular
companies’ websites to apply for a CBD product or service. In an email to one company,
Proposed Respondent shows that paying for the rating via affiliate registration on the CBD OIL webpage would receive approximately higher clicks and sales.“

32. Proposed Respondents have included on their website virtually no information about their
relationships with the companies that appear on the site. RevOffers and CBD Oil Reviews” on a page that consumers are unlikely to visit.

33. Proposed Respondents utilized SEO tactics to appear on organic and non paid marketing for the CBD industry has not allowed it currently, Using over 200,000.00 backlinks and 38,100,00 keywords which include all CBD OIL companies they have rated to not have “quality” “safety” , “mission” , “charity” , “unverified” standards without any true review process in place by consumers or the editor.





34. Proposed Respondents utilized SEO tactics to appear on organic and non paid marketing for the CBD industry in these CBD companies place to SEO themselves on google and other search engines, the visible bad review given by CBD OIL Review negatively impacts these companies ability to sell they product and disallows consumers to make valid decisions without funeling them to the products that CBD OIL Reviews and REVOFFERS profit from:

Search results were found when searching the following:

https://www.google.com/search?q=advocanna&rlz=1C5CHFA_enUS780US780&oq=advocanna&aqs=chrome..69i57j0l5j69i61l2.2125j0j4&sourceid=chrome&ie=UTF-8

https://www.google.com/search?rlz=1C5CHFA_enUS780US780&ei=h3XyXrLUAoKm_Qa804_ADw&q=diamond+cbd+review&oq=diamond+cbd+review&gs_lcp=CgZwc3ktYWIQAzICCAAyAggAMgIIADIGCAAQFhAeMgYIABAWEB4yBggAEBYQHjIGCAAQFhAeMgYIABAWEB4yBggAEBYQHjIGCAAQFhAeOgQIABBHOgQIABBDUNYZWPIlYPgmaABwAXgAgAFoiAGyBZIBAzQuM5gBAKABAaoBB2d3cy13aXo&sclient=psy-ab&ved=0ahUKEwjys8-O8pjqAhUCU98KHbzpA_gQ4dUDCAw&uact=5

35. Despite the positive reviews Diamond CBD has on google and facebook. CBD OIL Review and gives it a one star or badge placed on the first page of google with no legitimate maade review on the product for example.




36. When Cibiplex is searched on google it places on the first page of google. When a consumer clicks on the link https://cbdoilreview.org/cibdex-review/
CBD OIL Reviews sends end user to a link with a coupon unrelated to Cibidex which will bait and switch to a CBD company within REVOFFER affiliate program. These examples repeat themselves over 424 times when finding relative searchers pertaining to CBD company names reviewed and searchable on google using keywords within CDBOILREVIEW.COM






36. Of those 644 reviews, 444, or 90%, were written or made up by RevOffers and CBD Oil Reviews employees or their family, friends, or other associates. All of those reviews provided five-star ratings for the Company.

37. In numerous instances, the reviews were fabricated and did not represent actual consumer
experiences with RevOffers and CBD Oil Reviews.

38. Proposed Respondents also have reposted CBD Oil Reviews’s
website, as well as fake reviews written by RevOffers and CBD Oil Reviews employees who purport to be, but are not, actual users. The RevOffers and CBD Oil Reviews homepage has, at times, prominently featured reviews from the editor only.

39. Positive reviews on CBD companies with 4 for less badges or stars have been disallowed o have positive reviews on their products, have been not posted at all or deleted by the moderators.

40. None of these consumers exists. Proposed Respondents fabricated these “testimonials.”


Count I

41. In numerous instances in connection with the advertising, marketing, promotion, offering
for sale, or sale of CBD OIL products, Proposed Respondents represent, directly or indirectly,
expressly or by implication, that Proposed Respondents’ website content promoting CBD products, including their rate tables, rankings, and star ratings of companies offering those products, is not Influenced by compensation.

42. In truth and in fact, in numerous instances in which Proposed Respondents have made the
representations set forth in Paragraph 41, Proposed Respondents’ website content promoting CBD market place trusted ratings and vetting of CBD products, including their rate tables, rankings, and star ratings of companies offering those products, is influenced by compensation from those companies.

43. Therefore, Proposed Respondents’ representations as set forth in Paragraph 41 are false and misleading and constitute deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

Count II

44. In numerous instances in connection with the advertising, marketing, promotion, offering
for sale, or sale of CBD OIL products, Proposed Respondents represent, directly or indirectly,
expressly or by implication, that their website content, including rate tables, rankings, and star
ratings, is a source of information about CBD products.

45. In numerous instances in which Proposed Respondents make the representations set forth in Paragraph 44, Proposed Respondents fail to disclose or disclose adequately to consumers that CBD market place vetting services to CBD companies paid Proposed Respondents for website content, including rate tables, rankings, and star ratings. This additional information would be material to consumers in deciding whether to transact with companies ranked, rated, or reviewed by Proposed Respondents.

46. In light of the representations described in Paragraph 44, Proposed Respondents’ failure to disclose or disclose adequately the material information as set forth in Paragraph 44 constitutes a deceptive act or practice in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).








Count III

47. In numerous instances in connection with the advertising, marketing, promotion, offering
for sale, or sale of CBD OIL products, through the means described in Paragraphs 35-
40, Proposed Respondents have represented, directly or indirectly, expressly or by implication, that certain reviews of RevOffers and CBD Oil Reviews reflect the actual experiences or opinions of impartial consumers.

48. In truth and in fact, these reviews of RevOffers and CBD Oil Reviews were not truthful reviews by actual RevOffers and CBD Oil Reviews users, but instead were fabricated by persons who were friends, employees, or other associates of RevOffers and CBD Oil Reviews.
49. Therefore, the making of the representations as set forth in Paragraph 47 constitutes a
deceptive act or practice in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).
Violations of Sections 5

49. The acts and practices of Proposed Respondents as alleged in this proposed complaint constitute unfair or deceptive acts or practices in or affecting commerce in violation of Sections 5(a) of the Federal Trade Commission Act.


50. The acts and practices to defame and use of trademarked more info and copywritten property of other companies in order to be the sole credible source of reviews of which they would become profitable. constitutes a deceptive act or practice in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a) For the consumer.

51. The implementation of fake reviews and use of SEO to lure and bait and switch consumers to land on their platform of marketplace CBD review is constitutes a deceptive act or practice in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

















EXHIBITS


https://drive.google.com/file/d/1JJKDnln-rkVCYWXmXg22GhFF3HVhf5TI/view?usp=sharing




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