Summary of Action investigated the marketing used by the Stipulating Parties in FTC v. Agora Financial, LLC, et al. and found that they are violating a February 8, 2021 Stipulated Order by continuing to market products using unsubstantiated disease-treatment claims (targeting diabetes, cancer, Alzheimer’s, and even COVID-19, among others) and misleading financial representations. catalogued more than 300 videos, transcripts, web posts, order pages, and print materials that violate the Order. In addition, found that the Stipulating Parties are using dark patterns to induce their target audience – senior citizens and retirees – to purchase products, generally through improperly disclosed auto-renewal offers, they otherwise would not have purchased.

As a result of these findings, sent a complaint letter on June 16, 2021 to the FTC urging it to reopen its investigation and take appropriate enforcement action.

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