United States of America FEDERAL TRADE COMMISSION WASHINGTON, D.C. 20580 ‘Anne Weismann JAN 07 ONG CREW 1400 Eye Street N.W., Suite 450 ington, DC 20005 Menage Re: FOIA-2015-00277 Herbalife/Pershing Square ‘Dear Ms. Weismann: ‘This letter serves as our second and final response to your request dated December 8, ‘eedom of Information Act secking access to documents relating to Herbalife 2014, under the Fr ‘ ‘we are providing you with all and Pershing Square. Per your January 6 email to Andrea Kelly, documents previously released in response to FOIA-2014-01349. In response to FOIA-2014-01349, we released a total of 13,267 pages of responsive records, eight Excel spreadsheets, and six media files. Just as we did when we produced FOIA- 2014-01349, I am granting partial access to the these records, Some documents responsive to this previous request fell within the exemptions to the FOIA’s disclosure requirements, as explained below. In response to the previous request, we withheld certain consumer complaints under FOIA Exemption 3, 5 U.S.C. § 552(b)(3), because they are exempt from disclosure by another statute. Section 21(f) of the FTC Act provides that the FTC may not disclose any material reflecting a consumer complaint obtained from a foreign source if that foreign source has requested confidential treatment. 15 U.S.C.§ 57b-2(0). ‘Additionally, we withheld some responsive records under FOIA Exemption 3, 5 U.S.C. § 552(b)(3), because they are exempt from disclosure by another statute. Section 21(f) of the FTC Act provides that information obtained by the Commission in a law enforcement investigation, whether through compulsory process, or voluntarily in lieu of such process, is exempt from disclosure under the FOIA. 15 U.S.C.§ 57b-2(f), see Kathleen McDermott v. FTC, 1981-1 Trade Cas. (CCH) 63964 (D.D.C. April 13, 1981). ‘Some responsive records contain staff analyses, opinions, and recommendations. Those portions are deliberative and pre-decisional and are an integral part of the agency's decision making process. They are exempt from the FOIA's disclosure requirements by FOIA Exemption 55US.C. § 552()(5). See NLRB v. Sears, Roebuck & Co., 421 US. 132 (1975). Some responsive records contain complaints that consumers have sent to the Federal Trade Commission (FTC). You should know that the enclosed complaints have not necessarily been verified by the FTC. Therefore, you should make your own judgment about relying on the information provided. 1am denying access to consumers’ names and addresses and any other identifying information found in the complaints. This information is exempt from release underFOIA Exemption 6, 5 U.S.C. § 552(b)(6), because individuals’ right to privacy outweighs the tenetal publi’s interest in seeing personal identifying information. See The Lakin Law Firm v. Frc. 382 F.3d 1122 (7th Cir. 2003). This exemption also applies to the addresses and contact information of private individuals who filed FOIA requests with the FTC. Some of the records contain personal identifying information compiled for law enforcement purposes. This information is exempt for release under FOIA Exemption 1), 5 USC. § 552(0)(7)(C), because individuals’ right to privacy outweighs the general public's interest in seeing personal identifying information. ‘Any additional records we may have located would have been exempt from disclosure under FOIA Exemption 7(A), 5 U.S.C. § 552(b)(7)(A), because disclosure of that material could reasonably be expected to interfere with the conduct of the Commission's law enforcement nctivities. See Robbins Tire & Rubber Co. v. NLRB, 437 U.S. 214 (1978), In your letter, you also requested that the PTC provide a detailed description of all withheld documents, citing Vaughn v. Rosen, 484 F.2d 820 (D.C. Cir. 1973). We are not providing such an index at this time because we are not required to do so until ordered by a court Hfter a plaintiff has exhausted administrative process. See, e.g., Judical Watch, Inc. v. Clinton, 880 F. Supp. 1, 11 (D.D.C. 1995). ‘Additionally, you requested that the FTC award you news media status and waive all fees associated with the processing of your request. Because the search and review time associated ‘vith the production of these documents was de minimis and we are providing this information Ulectronically, there are no fees associated with your request and these matters are therefore moot. Ifyou are not satisfied with this response to your request, you may appeal by writing to Freedom of Information Act Appeal, Office of the General Counsel, Federal Trade Commission, 600 Pennsylvania Avenue, N.W., Washington D.C. 20580, within 30 days of the date of this letter. Please enclose a copy of your original request and a copy of this response. If you believe that we should choose to disclose additional materials beyond what the FOIA requires, please explain why this would be in the public interest. Ifyou have any questions about the way we handled your request or about the FOIA regulations or procedures, please contact Andrea Kelly at (202) 326-2836. Sincerely, SS EY Sarah Mackey o- Associate General Counsel5 Pe be oFrice: COMMITTEE On ETHICS Linda T. Sinchez 2479 RAYAURN BULOING nowt 38TH DISTRICT, CALIFORNIA coumarTee on MAYS AND MEANS: WaskincToN, pe 2031s Congress of the United States re oe oistRIcr office: 17906 cRUSADER AVENUE House of Representatives omisecme : 2219 8 5 8 Washington, DC 2055 se Beets he gor 14008387 g 3 S72 Edith Ramirez, Chairwomans aAvR Federal Trade Comission E28 600 Pennsylvania Avenue, NW Bai ‘Washington, DC 20580 eSB BN 38 2 2 June 5, 2013 Dear Chairwoman Ramirez: 1 am writing to express my concem about the marketing and business practices of Herbalife, Ltd In particular, I am troubled by allegations that this company may be harming consumers ~ especially those from our country’s most vulnerable populations. There have been extensive media reports and allegations about Herbalife’s business practices, ‘On March 12, 2013, the National Consumers League wrote a letter urging the FTC to conduct an investigation into the possibility that Herbalife is a complex pyramid scheme.' More recently, on May 17, 2013, the Hispanic Federation also wrote a letter urging an FTC investigation.’ Both groups have voiced concems over whether Herbalife’s distributors are primarily incentivized by recruiting others, or by selling the Herbalife product. Additionally, as the National Consumers League letter states, “Low-income consumers, as well as African-Americans and Hispanics, were found to be especially vulnerable to pyrami ‘business opportunities.”* -schemes masquerading as legitimate home-based {As Ihave learned more about this issue from my constituents and from outside groups, I believe it is the Federal Trade Commission's (FTC) responsibility to examine these allegations. Given the FTC's mission to investigate claims of fraud and potential pyramid schemes, I encourage you to investigate this matter. I have confidence that such an investigation will provide clarity to consumers and I expect you will aggressively pursue it in a timely manner. * sally Greenberg, National Consumers League to Edith Ramirer, Federal Trade Commission, 13 March 2023, http://www nelnet.org/images/POF/FTC%20Letters6200n%20Herbalife.pdf * Jose Calderon, Hispanic Federation to Edith Ramirez, Federal Trade Commission, 17 May 2013, bhutp://www seribd.com/doc/142602752/The-Honorable-Edith-Ramirez-FTC * Sally Greenberg, National Consumers League to Edith Ramiree, Federal Trade Commission, 13 March 2023, http://www nelnet.org/images/PDF/FTC%20Letter%s200n%20Herbalife.pdfIf I can be of additional assistance, please do not hesitate to contact Mike McGourty of my staff at 202-225-6676 or michael megourty@mail house.gov. Thank you for your attention to this important matter. Sincerely, Congresswoman Linda T. Sanchez Member of Congress (CA-38)LORETTA SANCHEZ (COMMITTEE ON ARMED SERVICES. pyaar Congress of the United States ENA inte) eat a00t Pax Fouse of Representatives vr ECONOMIC COMMITTEE Loreen ‘Washington, BC 20515 cea ee ont July 26, 2013 Chairwoman Edith Ramirez, Federal Trade Commission 600 Pennsylvania Avenue, NW Washington, DC 20580 Dear Chairwoman Ramirez: We write to you today as the substantial concems surrounding the business practices of Herbalife, Ltd. continue to increase. As you may be aware, a number of outside groups including the Hispanic Federation, League of United Latin American Citizens (LULAC), National Consumers League, Consumer Action and Consumers Union have raised concems about these business practices, as have a number of media outlets. After careful consideration, we would like to request that the Federal Trade Commission (FTC) look into Herbalife’s business practices, specifically whether Herbalife’s participants are deceived by exaggerated earnings claims, and whether profits are derived primarily from selling to outside consumers or from recruiting others, We believe the FTC is best suited to determine whether Herbalife business model is structured in a way that is in agreement with federal regulations. Ensuring the fair treatment of consumers, many of whom reside in our districts, is a matter of utmost importance and the FTC’s expertise is appropriate for this matter. ‘As members of Congress, we take our duty to represent our constituents very seriously. In their best interest, we have met with groups representing both sides of this issue and we have reviewed countless reports about the concems surrounding Herbalife. It is our general consensus that the FTC is best positioned to investigate this matter and provide a factual response. We are fully confident that your resources will offer the most accurate assessment of the business practices that are in question. We thank you for your attention on this important manner. Sincerely, Mi Chute dias x Leashes Loretta eZ Michelle Lujan Grisham Member of Congress Member of Congress138 19" Steat NW, Sute 1995 @ _ hispanicfederation ew vou 1006 Zax be bree eue oo Mots Get ecteas sine ‘wer hispanicfederation.org May 17,2013 FederalTrade Commission The Honorable Edith Ramirez Re cei ved Chairwoman MAY 28 2013 Federal Trade Commission 600 Pennsylvania Avenue, NW Chairwoman Ramirez Washington,DC 20580 Dear Chairwoman Ramirez: Since its inception in 1980, Hispanic Federation, has as its core mission to empower and advance the Hispanic community. It provides grants to aboard network of Latino non-profit agencies serving the most vulnerable members of the Hispanic community and advocates nationally with respect to the vital issues of education, health immigration, economic empowerment,civic engagement and the environment. ‘As part of our work on economic empowerment we have worked with small businesses to make them Viable and prosperous. We have worked with member agencies that provide loans to entrepreneurs who otherwise would not have the needed capitalto jump start their business dreams. We have offered seminars on mortgage assistance, development of credit and warned our community about amyriad of schemes created to defraud Latinos, especially the most vulnerable in our community. Through our financial literacy workshops, leaders in our network and some of our elected officials we have learned about the proliferation of get rich quick schemes that focus on Latinos and especially our immigrants. We write to you to urge the Federal Trade Commissionto conduct an investigation of the multi-level marketing company known as Herbalife. It is our understanding that the company's marketing materials promise richness for afew hours of work from home. You can imagine that for immigrants, particularly those who are underemployed or have no papers. this promise can seem like their ticket to achieving the American Dream. We understand, however,that when you add expenses to acquire the product, lists and marketing materials, most distributors appear to actually lose money. A particular concern to us about Herbalife is whether distributors make money selling products or recruiting others to selkproducts: The latter is an indicator of a pyramid scheme. Reading the recent debate on this issue;Herbalife's statements to explain its compensation structure are contradictory. We Urge you to focus on this issue:are distributors incentivized to sell product or to recruit new distributors into a pyramid.‘Through our work over 23 years we have learned that most mult-level marketing companies are legitimate businesses. They in fact compensate distributors for selling products. In fact, many of these ‘companies have provided new immigrants and other Latinos a real opportunity to move forward and earn a decent living for them and their families. From what we have learned about Herbalife, anecdotally and through our work,we have serious concerns about their business practices and we urge ‘you to look into this matter. ‘Thank you for your attention. Sincerely, wo 7 C Jose Calderon President Taking Hispanic causes toheart07/30/2013 TUE 10:54 PAX 614 771 3990 REP Steve Stivers Boo2/009 FINANCIAL SERVICES COMMITTEE STEVE STIVERS Gongress uf the United States House of Representatives July 30, 2013 Ms. Jeanne Bumpus Director, Office of Congressional Relations Federal Trade Commission 600 Pennsylvania Ave NW Rm 404 ‘Washington, DC 20580-0001 Dear Ms, Bumpus: ‘The attached communication concems a problem my constituent is experiencing with Herbalife and eHome Business Networks Inc. regarding a complaint he has filed with the Federal ‘Trade Commission. Please address the concerns brought forward by constituent, Mr [SSE] Your response can be directed to my caseworker, Adam Slane, regarding this Inquiry. If you have any additional questions, please contact Adam in my district office at 614- 771-3969. My constituents are a top priority and I appreciate your time and attention to this matter. Respectfully, STEVE STIVERS ‘Member of Congress SS/as Enclosed sei eam ——— eee — eae eee cy eat iaiae07/30/2013 TUE 10:54 FAX 614 771 3990 REP Steve Stivers [003/009 UNITED STATES CONGRESS ¢ OHIO Congressman Steve Stivers ‘CONSENT FOR RELEASE OF INFORMATION Passport Number: icy capa jos rola wale Gabe raion Crea adilonal pages Vnsuded or copies ay documentation that you may have which would help expedite your inquiry. Please do not send original documents) Please Priat: Linvested over $20, S00. with Herbalife and etiome Business Networks, Inc., which is wholly owned by A 's THEY DON'T CARE. | HAVE OFFERED TO SETTLE AND THEY WOULD NOT SETTLE UNL TEI crtantra entove mand ot Gorcloye pone easton aptnny san eee nace Congr Signatures, Date; _July 23, 2013, Please Return Completed Form and Documents To: By Malt: By Fax: Questions: Office of Congressman Stivers Pax: (614) 771-3990 Telephone: (614) 771-4968 C/O Adam Slane Attn: Adam Slane 3790 Municipal Way Hilliard, OH 4302607/30/2023 TUE 10:55 FAX 614 771 3990 REP Steve Stivers wooaso0s iome Business Networks, | Herbalife Information Notes Prepared by| April 18, 2013 PRE contact intormation: Mailing Address: hic Pa] Home Phon Cell Phone’ Email: | became a Herbalife Distributor on June 6, 2012. | became a Herbalife Supervisor on July 1, 2012. | as a Herbalife Supervisor became a Herbalife World Team Member on November 1, 2012. Since June 6, 2012 | have spent over $21,000 on Herbalife Product Inventory, Bridge to Business (Chairman's Club Owned) Recruiting Leads ($159.95 each) & Marketing Materials, Other Marketing Materials and 1Office/Connecting Point/Merchant Account Systems (Chairman's Club Owned) $385.00 in monthly fees and total system set up fees of $958.00. | also spent an additional $5,000 on a back up generator for my home so | would never lose internet or phone availabilty as a direct result of being told by my President Team Member PSO do so. As of this date | have received $684. in Wholesale Eamings and $200 in Royalties for a total of $864. Points of Interest: 1. On August 1, 2012 | created and submitted to [ERSEEE)¢ marketing program based on committing to spending 70 hours per week and purchasing 20 Recruiting Leads per month, which based on [OM] [BG verbal commentary, would create an income of $5,000 per month and get me to World Team within six months. This program ultimately cost me $3,500 per month in marketing expense. | spent an additional $4,600 on Retailing the Product over the 6 months, June 6, 2012 through November 30, 2012. 2. eHome Business Networks, Inc. System which is owned by Anthony Powell was designed for Training new distributors and manage recruiting and retailing leads. In general it cost in excess of $1000 per month but the killer point was that in the training process you had to join: the Telephone System: $199 set up fee and $89 per month; the Management System $259 set up and $99 per month; (4) Websites $69 each set up x 4 and 30 per month; Lead Tracker/Call System $224 set up and $89 per month. 3. Minimum of 30% Efficiency in converting Purchased Recruiting Leads to Distributors/Supervisors or Purchased Leads would not be released to Supervisor by Bridge to Business (Needs Presidents Club Member Approval for Release). Combined with point 7 below this made my situation highly stressed and unfair taking Into account that | was spending more than 70 hours per week to accomplish my goals and it still could not please the Upline. 4, lOffice Conversion Created Huge Problems for Distributor’s Websites, which became dysfunctional with each system problem (6 different times) with No Notification from lOrfice.07/30/2013 TUR 10:55 FAX 614 771 3990 REP Steve Stivers @oos/oos 5. Stacking vs, Front Lining Distributors and why Stacking (Sharing Volume to Incentivize more product purchases from the entire Downline re: Supervisor Level) is 0 much more valuable to Royalty Eamers and not to Distributors earning wholesale discounts. 6. Emall Volume in excess of 30 per day and Google Calendar Setup to Schedule 10 to 12 hour days including Trainings, interviews, DAC Calls and Seminars. Upline Sponsor and Upline PTM insisted on having access to Google Calendar, lOffice and Track My Dials. All in the interest of controlling all Downline members through intimidation. 7. First Interview with prospective Recruit completed by Myself (Must be Supervisor) & Immediate Upline Sponsor [UNE] Second Interview with prospective Recruit completed by Myself & Upline Presidents Team Member [EXO] | experienced great success in my interviews to the extent that my Upline Sponsor and PTM did not have the time necessary to do interviews on a timely basis. When | started doing First Interviews and Second Interviews (Out of Necessity) on my own the PTM threatened to discontinue doing my Second Interviews. ! was continually reminded of this by [PR] on 8. Extreme Pressure to Purchase Marketing Materials, Shake Customer Leads and Recruiting Leads from Bridge to Business which | am sure is owned by Chaitman and Presidents Team Members. 9. DAC Calls were daily and the setting was to exert extreme pier pressure on participants progress of dally recruiting and product sales (pushed marketing materials was the purpose) conversions. 10. Training Program includes forced enrollment into Connecting Point and {Office System use to the tune of $300 per month in fees. 11. Purchased Recruiting Lead Return/Replacement Policy Is Favorable to Bridge to Business. They would replace paid leads with unsubstantiated leads on a regular basis without any choice by distributor. 12, Royalty Sales Contact Statement is sent each month to Herbalife as a requirement for Royalty Payment at each Royalty Level: World Team, Global Expansion Team and so on. | did not send my Royally Sales Contact Statement for my first and only check. Funny thing is that regarding my only Royalty Payment Amount as mentioned above ($200.) the Herbalife Home Office said they would make an exception to the *Rule” because | was such an outstanding Supervising Distributor and World Team Member, 13. In conclusion, | must admit that Herbalife, eHome Business Networks, Inc. and Anthony Powell and his cronies have designed the total Program to take advantage of distributors by preaching that each distributor has a huge opportunity to make money as an independent business distributor but the reality is that they control and profit from all elements of the Program through Royalty Income from Recruiting Distributors and Distributor TURNOVER and Not Retail Sells of the Products by Distributors. 14, Then to top all the arrogance and inconsistencies the entire Anthony Powell Organization and all the so called system use benefits that eHome Business Networks, Inc. provided was kicked out of Herbalife with prejudice in January 2013 and immediately moved its 16,000 distributors to VEMMA another MLM Organization selling health supplements.07/30/2013 TUE 10:56 FAX §14 771 3990 REP Steve Stivers Goos/oos 16. So, | now am being asked to invest another $21,000 into VEMMA and the new Anthony Powell ‘Organization and eHome Business Networks, Inc. of Arizona with no support to continue with Herbalife from Herbalife of California.07/30/2013 TUE 10:56 FAX 614 771 3990 REP Stove Stivers 007/003 Bill Ackman & Herballit {formation Notes Prepared by| jon December 23, 2012 PRE contact Information: Mailing Addre rio Home Phone Cell Phone: | became a Herbalife Distributor on June 6, 2012. | became a Herbalife Supervisor on July 1, 2012. | as a Herbalife Supervisor became a Herbalife World Team Member on November 1, 2012. Since dune 6, 2012 | have spent over $14,000 on Herbalife Product Inventory, Bridge to Business (Chairman’s Club Owned) Recruiting Leads & Marketing Materials, Other Marketing Materials and lOffice/Connecting Point/Merchant Account Systems (Chairman's Club Owned) monthly fees. | also ‘spent an additional $5,000 on a back up generator for my home so | would never lose internet or phone availability as a direct result of being told by my President Team Member [BXOREEEto do so. As of this date | have received $684 in Wholesale Earnings and $200 in Royalties for a total of $864, Points of interest: 1. Minimum of 30% Efficiency in converting Purchased Recruiting Leads to Distributors/Supervisors or Purchased Leads would not be released to Supervisor by Bridge to Business (Needs Presidents Club Member Approval for Release). 2. lOffice Conversion Created Huge Problems for Distributors Websites with No Notification from lOffice, 3. Stacking vs. Front Lining Distributors and why Stacking (Sharing Volume to Incentivize more product purchases from the entire Downline re: Supervisor Level) is so much more valuable to Royalty Eamers and not to Distributors earning wholesale discounts. 4, Email Volume in excess of 30 per day and Google Calendar Setup to Schedule 10 to 12 hour days including Trainings, Interviews, DAC Calls and Seminars. Upline Sponsor and Upline PTM insisted on having access to Google Calendar, lOffice and Track My Dials. All in the interest of controlling all Downline members through intimidation, 5. First interview with prospective Recruit completed by Supervisor & Immediate Upline Sponsor. Second Interview with prospective Recruit completed by Supervisor & Upline Presidents Team Member. | experienced great success in my interviews to the extent that my Upline Sponsor and PTM did not have the time necessary to do interviews on a timely basis. When | started doing First Interviews and Second Interviews (Out of Necessity) on my own the PTM threatened to discontinue doing my Second Interviews. 6. Extreme Pressure to Purchase Marketing Materials, Shake Customer Leads and Recruiting Leads from Bridge to Business which | am sure Is owned by Chairman and Presidents Team Members, 7. DAC Calls were dally and the setting was to exert extreme pier pressure on participants progress of daily recruiting and product sales (pushed marketing materials was the purpose) conversions. 8. Training Program includes forced enrollment into Connecting Point and Office System use to the tune ‘of $500 per month in fees. 9. Purchased Recruiting Lead Return/Replacement Policy is Favorable to Bridge to Business.07/30/2013 TUE 10:56 FAX 614 771 3990 REP Steve Stivers 008/009 10. Royalty Sales Contact Statement is sent each month to Herbalife as a requirement for Royalty Payment at each Royalty Level: World Team, Global Expansion Team and so on. | did not send my Royalty Sales Contact Statement for my first and only check. Funny thing Is that regarding my only Royalty Payment Amount as mentioned above ($200.) the Herbalife Home Office said they would make an exception fo the “Rule” because | was such an outstanding Supervising Distributor and World Team Member.07/30/2013 TUE 10:57 PAX 614 771 3990 REP Steve Stivers @oos/o0s Confidential Memo Federal Trade Commission 600 Pennsylvania Avenue, NW Washington, DC 20580 DATE: January 22, 2013 TO: Jon Leibowitz, Chairman of Commissioners FROM: [RIE] Herbalife Distributor & Herbalfe World Team Member Dear Sir, On June 6, 2012 | became a Herbalife Distributor as a result of spending $199.00 for a Herbalife training package and product assortment, | became a Herbalife Distributor Supervisor on July 1, 2012 as a result of purchasing $2,000 worth of Herbalife products. | became a Distributor Supervisor, World Team Member on November 1, 2012 as a result of recruiting distributors that cumulatively bought over $10,000 through my distributorship in the month of October 2012. As of this date | have spent in excess of $20,300: Including Herbalife Product Inventory ($3, , Bridge to Business (Owned by Herbalife Chairman's Club and President's Club Members) Recrui Leads & Marketing Materials ($8,500), Other Marketing Materials ($1,200), \Ofice/Connecting Point/Merchant Account Systems/Website Development (Owned by Herbalife Chairman's Club and President's Club Members) ($3,400). Additionally, | spent over $4,000 on a backup electrical generator and phone/internet system for my home s r be without power, phone and internet, which was a complaint from my sponsor land President's Club Upline Member, Mr a] As of this date | have sold product only to recruited distributors and have received only one check in ‘the amount of $864, which included $684 for wholesale earnings and $200 in Royalties. The following example is just one of thirteen reasons that | have documented, which all thirteen are evidence that | was ripped off by Herbalife and in fact if all Herbalife Distributors lose control of their ‘own distributorship like me then the only thing remaining within Herbalife is a Pyramid Scheme: Example One: Please review the attached Points of Interest dated on December 23, 2013. Please review the attached Points of Interest updated on April 18, 2013.Search Results. Page | of 1 2 SENTINEL 238 Search Results ‘Search Criteria:Pimary Subject Name"herbalfe" Primary Subject Company Name *nerbalife"; Crested Date- (Complaint Info Statute Description _|FTC Act Sec 5 (BCP) (Complaint Info Topic Code [Complaint info Topic Description [CMS# 14008878: MAIL 09/30/2013: [The consumer is a merchant located in Hartford and has come in {contact with many people from the {Hispanic community. The residents lof this neighborhood, also known las Frog Hollow, are trying to do {heir best to provide for their families while serving as good litzens. The recent stories(Complaint info Comments neyorumly Meiwanie nave DEEN very \disturbing. One of the consumer lemployees almost enlisted in [Herbalife because they were ipromised easy money. Many of the reseller are from the Hispanic and lAfrican American communities. The {company demands a very high lupfront financial commitment from its resellers, who are then left to {their own to cover those upfront cost. (Complaint Info CRA Dispute Flag [Complaint Info CRA Dispute Responded [Complaint Info CRA Dispute [Resolved (Complaint Info Fair Resolution Flag (Complaint Info Fair Resolution [Description [Record 48 of 102 [Reference Number [as6e8763 ] [Created Date jo9/30/2013 [Complaint Source | [Federal Trade Commission [Originator Reference Number |Language |English (Contact Type [Complaint [Data Source [Consumer |DNc? IN [Entered By [STAYLORROBINS [Entered Date foara0r2013 ] Updated By [STAYLORROBINS J [Updated Date josia0/2013 ] [Agency Contact [Phone [Complaint Date (ogrs0r2013 [Transaction Date | [Member of armed forces or Li dependant? [Consumer First Name love) (Consumer Middle Name [Consumer Last Name [o(6) ] |Consumer Salutation (Consumer Address, Line 4 in(6) (Consumer Address, Line 2[Consumer Address, Line 3 —___| (Consumer Address, City [Middlefield (Consumer Address, State Code __|CT (Consumer Address, State Name _|Connecticut (Consumer Address, Country Code [USA (Consumer Address, Country Name [UNITED STATES [Consumer Address, ZIP Code [D(6) (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code (Consumer Home Phone, Area (Code (Consumer Home Phone, Number (Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code (Consumer Work Phone, Number (Consumer Work Phone, Extension [Consumer Fax, Country Code [Consumer Fax, Area Code: [Consumer Fax, Number [Consumer Cell Phone, Country (Code (Consumer Cell Phone, Area Code: [Consumer Cell Phone, Number (Consumer Emall [Consumer Age range [Consumer Military Status ‘Consumer Military Station (Consumer Complaining \CompanylOrg (Consumer Military Service Branch (Consumer Consent for volunteer yroup contact? (Company Name. [Herbalife (Company Address, Line 1 (Company Address, Line 2 (Company Address, Line 3 (Company Address, City (Company Address, State Code (Company Address, State Name (Company Address, Country Code [usa[Company Address, County Name UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code (Company Phone, Area Code (Company Phone, Number [Company Phone, Extension [Company Email (Company Website [Company Subject ID Type Code (Company Subject ID Type Name (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name (Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint Info Initial Contact, [Method |Unknown [Complaint nfo Initial Contact Date (Complaint info initial Response [Method |Unknown (Complaint Info Initial Response (Date (Complaint Info Amount Requested [Method (Complaint Info Amount Requested \Value [$0.00 (Complaint Info Amount Paid [Method |Unknown (Complaint Info Amount Paid Value {$0.00 (Complaint Info Product Service (Code jo304 (Complaint Info Product Service [Description [Multi-Level Mktg\Pyramids\Chain Letters. (Complaint Info Law Violation Code [ppm r|Deception/Misrepresentation [Complaint Info Statute Code P J (Complaint Info Statute Description |FTC Act Sec 5 (BCP) ] (Complaint info Topic Code [Complaint info Topic Description (Complaint Info Comments [CMs# 14008873: MAIL 09/30/2013: [The consumer is a skilled lcraftsman, and if very sympathetic, {to hard work. Retail sales are very dificult and take time and support. [The consumer is concem about the Ireports surrounding Herbalife. [Based on what the consumer has Iheard from the media, management lof this company has been pushing {heir products to people to act as. Iesellers, From a faimess iperspective, the actions of this Icompany have clearly crossed the line when it comes toward Iransparency. in many cases with {these green resellers, the promises loften result in crushing debt Instead of having a transparent loperation Herbalife sells these lopportunities to people in \vulnerable communities, takes large upfront payments and doesn't lofter proper support. Due to the icompany’s high above-average costs, itis hard for these people to {sell enough of the product in order to realize a significant return on investment. (Complaint Info CRA Dispute Flag _| (Complaint Info CRA Dispute [Responded (Complaint Info CRA Dispute Resolved (Complaint Info Fair Resolution Flag. [Complaint info Fair Resolution [Description [Record 49 of 102 Reference Number [4s760693, | (Created Date fron72013 [Complaint Source [Federal Trade Commission ] (Originator Reference Number[Language |JEnglish (Contact Type (Compiaint (Data Source [Consumer DNC? IN [Entered By [STAYLORROBINS [Entered Date hion72013 (Updated 8 [STAYLORROBINS (Updated Date fror22i2013 [Agency Contact iPhone [Complaint Date hrorz2i2013 [Transaction Date [Member of armed forces or q \dependant? |Consumer First Name lie) [Consumer Middle Name \o(6) |Consumer Last Name ie) (Consumer Salutation (Consumer Address, Line 1 inv6) (Consumer Address, Line 2 (Consumer Address, Line 3 (Consumer Address, City [Marlborough (Consumer Address, State Code _|CT (Consumer Address, State Name [Connecticut (Consumer Address, Country Code _|USA (Consumer Address, Country Name [UNITED STATES [Consumer Address, ZIP Code [o(6) [Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code [Consumer Home Phone, Area (Code (Consumer Home Phone, Number (Consumer Work Phone, Country (Code [Consumer Work Phone, Area Code [Consumer Work Phone, Number [Consumer Work Phone, Extension [Consumer Fax, Country Code [Consumer Fax, Area Code [Consumer Fax, Number [Consumer Cell Phone, Country (Code|Consumer Cell Phone, Area Code (Consumer Cell Phone, Number [Consumer Email (Consumer Age range (Consumer Miltary Status [Consumer Military Station (Consumer Complaining (CompanylOrg (Consumer Military Service Branch [Consumer Consent for volunteer \group contact? [Company Name [Herbalife (Company Address, Line 1 [Company Address, Line 2 (Company Address, Line 3 [Company Address, City (Company Address, State Code (Company Address, State Name (Company Address, County Code _|USA (Company Address, County Name _|UNITED STATES. (Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code |Company Phone, Area Code (Company Phone, Number (Company Phone, Extension [Company Email | (Company Website [Company Subject ID Type Code (Company Subject ID Type Name ipany Subj ype (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name (Company Rep First Name (Company Rep Middle Name (Company Rep Last Name [Cor Rep Sal[Company Rep Comments [Complaint Info Initial Contact [Method I |Unknown (Complaint Info Initial Contact Date (Complaint Info Initial Response [Method (Complaint Info Initial Response [Date [Unknown (Complaint Info Amount Requested [Method (Complaint Info Amount Requested \Value ‘$0.00 [Complaint Info Amount Paid [Method (Complaint Info Amount Paid Value (Complaint Info Product Service (Code (Complaint Info Product Service Description (Complaint Info Law Violation Code (Complaint Info Law Violation Description (Complaint Info Statute Code (Complaint Info Statute Description [Complaint Info Topic Code (Complaint Info Topic Description |Unknown {$0.00 jo304 [Multi-Level Mkig\Pyramids\Chain [Letters [DDM |Deception/Misrepresentation r [FTC Act Sec 5 (BCP) (Complaint info Comments [CMs# 14008902: MAIL 10/17/2013: [The consumer offers professional Iservices to his patients, and he lunderstands the risks and rewards lofhis practice on a daily basis. tt took him many years of education, Imentoring and hard work to build this opportunity. Many people who lare not fortunate to have these lassets are often the ones to fall prey, Ito rich quick gimmick or someone lwho offers them an easy way {toward prosperity. Based on what Ithe consumer has heard through Ihe media and Internet, the Imanagement of this company has been aggressively pushing their lproducts to people to act as, resellers. This is not the consumer's larea of expertise, but from a Ihumanitarian perspective, the laction of this company has clearly lerossed the line when it comes.toward transparency. Herbalife has Ibeen using powerful techniques to lenlist certain minority groups to resell their products. For green Ireselis, the promises often result in lcrushing debt. Herbalife sells these lopportunities to people in \vulnerable communities, takes large up-front payments and doesn't loffer the proper support. The high, labove-average costs, makes it hard for these people to sell enough of, ithe product in order to realize a [significant retum on the investment. (Complaint info CRA Dispute Flag (Complaint Info CRA Dispute [Responded a (Complaint info CRA Dispute Iv Resolved (Complaint info Fair Resolution Flag] (Complaint Info Fair Resolution [Description [Record 50 of 102 [Reference Number [45766755 (Created Date fior17/2013, (Complaint Source [Federal Trade Commission [Originator Reference Number [Language [English (Contact Type (Complaint [Data Source (Consumer |DNc? IN [Entered By [STAYLORROBINS Entered Date [10/17/2013 (Updated By [STAYLORROBINS Updated Date frov22/2013 [Agency Contact IPhone [Complaint Date fiov222019 [Transaction Date [Member of armed forces or ci dependant? (Consumer First Name io(6) (Consumer Middle Name (Consumer Last Name inv6) (Consumer Salutation J (Consumer Address. Line 1 lve) I|Consumer Address, Line 2 |Consumer Address, Line 3 (Consumer Address, City [Newington (Consumer Address, State Code _|CT (Consumer Address, State Name _|Connecticut (Consumer Address, Country Code [USA (Consumer Address, Country Name [UNITED STATES [Consumer Address, ZIP Code [b(6), (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code (Consumer Home Phone, Area (Code (Consumer Home Phone, Number (Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code [Consumer Work Phone, Number (Consumer Work Phone, Extension (Consumer Fax, Country Code [Consumer Fax, Area Code (Consumer Fax, Number (Consumer Cell Phone, Country (Code (Consumer Cell Phone, Area Code: [Consumer Cell Phone, Number [Consumer Email [Consumer Age range [Consumer Mitary Status [Consumer Military Station (Consumer Complaining (CompanylOrg [Consumer Military Service Branch (Consumer Consent for volunteer \group contact? (Company Name [Herbalife (Company Address, Line 1 (Company Address, Line 2 [Company Address, Line 3 (Company Address, City (Company Address, State Code (Company Address, State Name[Company Address, Country Code [USA (Company Address, County Name [UNITED STATES. [Company Address, ZIP Code (Company Address, ZIP Code [Extension [Company Phone, Country Code [Company Phone, Area Code Company Phone, Number [Company Phone, Extension (Company Email (Company Website (Company Subject ID Type Code (Company Subject ID Type Name (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name. (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name (Company Rep First Name (Company Rep Middle Name [Company Rep | (Company Rep [Company Rep Comments (Complaint Info Initial Contact, [Method |Unknown (Complaint Info Initial Contact Date (Complaint Info Initial Response [Method |Unknown (Complaint info initial Response (Date (Complaint info Amount Requested (Method (Complaint Info Amount Requested Value ($0.00 (Complaint Info Amount Paid [Method |Unknown (Complaint Info Amount Paid Value {$0.00 (Complaint Info Product Service (Code jo304 (Complaint Info Product Service [Description [Multi-Level Mkig\Pyramids\Chain lLetters[Description (Complaint Info Statute Code [Complaint info Statute Description | [FTC Act Sec 5 (BCP) [Complaint Info Topic Code (Complaint Info Topic Description (Complaint info Comments [CMs# 14008911: MAIL 10/17/20%: [The consumer wanted to share her [personal story regarding Herbalife land its sales practices. The lconsumer has used the Herbalife Iproducts and brought them at a local storefront in Connecticut. |While speaking with the sales person, ittook a few minutes before ithe Herbalife sales person was Ishowing me that | could also ibecame a retail agent and eam lgreat riches. At one point, the sales [person was showing the consumer Icancel checks in denominations of '$400, $600 and $2,000 and implied {those checks could easily be lobtained through a regular sales lprogram The sales person was very| ipersistent but the consumer did not fall for it. Any company thatis eager to share their business model with lunderserved communities troubles ithe consumer. The consumer has heard numerous news reports regarding Herbalife and how they Ihave been targeting the Hispanic lcommunity. Many consumers are lashamed they have invested in |Hearbalite retail operations, {committing themselves to large Isums of money and being unable to| imake a go oft. (Complaint Info CRA Dispute Flag_| (Complaint Info CRA Dispute Responded [Complaint Info CRA Dispute [Resolved [Complaint Info Fair Resolution Flag | (Complaint Info Fair Resolution [Description [Record 51 of 102[Reference Number 49930587 (Created Date (osr30r2013 (Complaint Source [BBB CA Oakland [Originator Reference Number __ [1160057266628 [Language [English (Contact Type (Complaint (Data Source (Organization DNC? IN [Entered By [BBBOACA-USER [Entered Date (osia0r2013 [Updated By [Updated Date [Agency Contact [Extemal Agency [Complaint Date jo8i30/2013 [Transaction Date [Member of armed forces or dependant? (Consumer First Name inv6) (Consumer Middle Name (Consumer Last Name io(6) (Consumer Salutation (Consumer Address, Line 1 by (Consumer Address, Line 2 (Consumer Address, Line 3 (Consumer Address, City [ALEXANDRIA (Consumer Address, State Code__|VA [Consumer Address, State Name _ [Virginia |Consumer Address, Country Code [USA (Consumer Address, County Name [UNITED STATES |Consumer Address, ZIP Code [p(6) (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code [Consumer Home Phone, Area [Code [Consumer Home Phone, Number [Consumer Work Phone, Country (Code [Consumer Work Phone, Area Code [Consumer Work Phone, Number (Consumer Work Phone, Extension (Consumer Fax, Country Code[Consumer Fax, Area Code (Consumer Fax, Number (Consumer Cell Phone, Country [Code (Consumer Cell Phone, Area Code (Consumer Cell Phone, Number [Consumer Email [o(6) (Consumer Age range [Consumer Military Status (Consumer Military Station (Consumer Complaining (CompanylOrg [Consumer Military Service Branch [Consumer Consent for volunteer (group contact? (Company Name [Daphne Moris; Herbalife Independent Distributor (Company Address, Line 1 (Company Address, Line 2 (Company Address, Line 3 (Company Address, City [BENICIA (Company Address, State Code __|CA (Company Address, State Name __|Califomia (Company Address, Country Code [USA [Company Address, Country Name [UNITED STATES. (Company Address, ZIP Code __[94510 (Company Address, ZIP Code [Extension (Company Phone, Country Code (Company Phone, Area Code [707 (Company Phone, Number [7450535 [Company Phone, Extension (Company Email idaph-shawn@comeast.net [Company Website [www herbalife.com [Company Subject © Type Code (Company Subject ID Type Name (Company Subject ID Issuing State [Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code [Company Subject ID Issuing[County Name (Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint Info Initial Contact, (Method [Complaint Info Initial Contact Date (Complaint Info Initial Response [Method (Complaint info Initial Response [Date (Complaint info Amount Requested [Method (Complaint info Amount Requested Value [Complaint Info Amount Paid [Method (Complaint Info Amount Paid Value (Complaint Info Product Service (Code 11704 (Complaint Info Product Service (Description. [Health Care: Diet [Products\Centers\Plans [Complaint info Law Violation Code (Complaint Info Law Violation [Description [Complaint Info Statute Code [Complaint Info Statute Description (Complaint Info Topic Code [Complaint info Topic Description (Complaint Info Comments [Service Rep ‘Betty’ simply advised that products cannot be return or lexchanged regardless of purchase \date.Attempted to return item purchased on August 26, 2013 iproduct # 0004 product nane [Herbal Aloe Gallon Service Rep [Betty simply advised that products lcannot be retum or exchanged regardless of purchase date. —- [Additional Comments: Ineed a |quart of the same product and \ifference be refunded. (Complaint Info CRA Dispute Flag (Complaint Info CRA Dispute [Responded[Complaint info GRA Dispute [Resolved (Complaint info Fair Resolution Flag [No olan FairRescuion FET TT respond othe BE ote icomplainant. [Record 52 of 102 [Reference Number [49084845 (Created Date losniao13 (Complaint Source [BBB CA Los Angeles (Originator Reference Number [1300020043637 [Language [English (Contact Type (Complaint (Data Source [Organization DNC? IN [Entered By [BBBCALA-USER [Entered Date losnisr2013 (Updated 8 (Updated Date [Agency Contact [Extemmal Agency [Complaint Date jo9/18/2013 Transaction Date [Member of armed forces or (dependant? (Consumer First Name oie) (Consumer Middle Name [Consumer Last Name io(6) (Consumer Salutation (Consumer Address, Line 1 io(6) (Consumer Address, Line 2 [Consumer Address, Line 3 [Consumer Address, City IRISING SUN (Consumer Address, State Code __|MD (Consumer Address, State Name [Maryland [Consumer Address, Country Code |USA (Consumer Address, Country Name |UNITED STATES [Consumer Address, ZIP Code ) (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code [Consumer Home Phone, Area(Code (Consumer Home Phone, Number (Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code (Consumer Work Phone, Number (Consumer Work Phone, Extension (Consumer Fax, Country Code (Consumer Fax, Area Code (Consumer Fax, Number [Consumer Cell Phone, Country (Code (Consumer Gell Phone, Area Code (Consumer Cell Phone, Number [Consumer Email Ip(6) [Consumer Age range [Consumer Mitary Setus [Consumer Military Station (Consumer Complaining |CompanyiOrg [Consumer Military Service Branch [Consumer Consent for volunteer \group contact? [Herbalife Intemational of America, (Company Name Ine [Company Address, Line 4 |800 W Olympic Blvd Ste 406 (Company Address, Line 2 [Company Address, Line 3 (Company Address, City [LOS ANGELES (Company Address, State Code [CA (Company Address, State Name __|Califomia |Company Address, Country Code [USA (Company Address, County Name_|UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code (Company Phone, Area Code [a0 (Company Phone, Number (4109600 (Company Phone, Extension (Company Email [Company Website Inttp:www.herbalife.com [Company Subject ID Type Code|Company Subject ID Type Name. (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name [Company Rep First Name (Company Rep Middle Name (Company Rep Last Name [Hughes (Company Rep Salutation (Company Rep Comments (Complaint Info Initial Contact, [Method (Complaint Info Initial Contact Date (Complaint Info Initial Response [Method (Complaint info Initial Response [Date (Complaint Info Amount Requested [Method (Complaint Info Amount Requested \Value (Complaint Info Amount Paid [Method (Complaint Info Amount Paid Value [Complaint Info Product Service (Code jo304 (Complaint Info Product Service [Description [Multi-Level Mkig\Pyramids\Chain [Letters [Complaint info Law Violation Code (Complaint Info Law Violation [Description [Complaint Info Statute Code [Complaint info Statute Description [Complaint Info Topic Code [Complaint info Topic Description [Purchased product that had cocoa [powder in it unknowingly, do not land can not consume products with \cocoa powder Purchased product, |with cocoa powder in it junknowingly. Caffeine or any cocoa related products make me sick.[Been trying to see if| could get Irefund or exchange. When I call | lget transferred around and lulimately get hung up on, — [Additional Comments: | would like leither product refunded or lexchanged for another product (Complaint Info CRA Dispute Flag (Complaint Info CRA Dispute [Responded (Complaint info CRA Dispute Resolved (Complaint Info Fair Resolution Flag lyes (Complaint Info Fair Resolution [Description [ASSUMED RESOLVED. The ibusiness addressed the issue, but ithe consumer has not verified with ithe BBB that the complaint is isettled nor requested additional (Complaint Source [BBB assistance [Record 53 of 102 Reference Number [49114593 [Created Date frorzg/2013 I [Federal Trade Commission [Originator Reference Number [Language J [English (Contact Type [Complaint [Data Source [Consumer DNC? IN [Entered By [STAYLORROBINS [Entered Date lrov2gi2013 | (Updates 8 [STAYLORROBINS [Updated Date fr1i04i2013 [Agency Contact iPhone [Complaint Date fr1i04i2013 [Transaction Date [Member of armed forces or ly \dependant? (Consumer First Name io(6) [Consumer Middle Name [Consumer Last Name [D(6) (Consumer Salutation (Consumer Address, Line 4 in(6) [Consumer Address, Line 2 [Consumer Address, Line 3\Consumer Address, City (Consumer Address, State Code |chester [ct (Consumer Address, State Name [Connecticut (Consumer Address, Country Code [Consumer Address, ZIP Code [Consumer Address, Country Name [USA |UNITED STATES: [b(6) J (Consumer Address, ZIP Code [Extension (Consumer Home Phone, County (Code [Consumer Home Phone, Area (Code [Consumer Home Phone, Number [Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code (Consumer Work Phone, Number [Consumer Work Phone, Extension [Consumer Fax, Country Code [Consumer Fax, Area Code [Consumer Fax, Number (Consumer Cell Phone, Country (Code [Consumer Gell Phone, Area Gode [Consumer Gell Phone, Number [Consumer Email [Consumer Age range [Consumer Military Status (Consumer Military Station (Consumer Complaining (CompanylOrg [Consumer Military Service Branch (Consumer Consent for volunteer youp contact? (Company Name [Herbalife ] (Company Address, Line 1 (Company Address, Line 2 [Company Address, Line 3 [Company Address, City [Company Address, State Code [Company Address, State Name (Company Address, Country Code [usa (Company Address, Country Name UNITED STATESCompany Address, ZIP Code —___| Company Adcress, ZIP Code [Extension (Company Phone, Country Code (Company Phone, Area Code (Company Phone, Number (Company Phone, Extension (Company Email (Company Website (Company Subject ID Type Code [Company Subject ID Type Name (Company Subject ID Issuing State \Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name [Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint Info Initial Contact, [Method |Unknown [Complaint Info Initial Contact Date (Complaint Info Initial Response [Method |Unknown (Complaint info Initial Response [Date (Complaint Info Amount Requested [Method (Complaint Info Amount Requested \Value '$0.00 (Complaint Info Amount Paid [Method |Unknown (Complaint info Amount Paid Value {$0.00 (Complaint Info Product Service (Code jo304 (Complaint info Product Service [Description [Multi-Level Mktg\Pyramids\Chain Letters (Complaint Info Law Violation Gode [ppm (Complaint Info Law Violation [Description [Deception/Misrepresentation(Complaint Info Statute Code P (Complaint Info Statute Description [FTC Act Sec 5 (BCP) [Complaint Info Topic Code [Complaint Info Topic Description (Complaint Info Comments (Complaint Info CRA Dispute Flag [MAIL: 10/29/2013: The consumer is lasking the Federal Trade |Commission to investigate |Herbalife’s business practices. The Iconsumer recently reviewed some [publications, and there have been 'some troubling accusations and Ireports conceming Herbalife, and Ihow it sells its products and recruits. Ire-sellers to do the same. Herbalife claims to be a multi-level marketing lcompany, but really they appear to ibe a pyramid scheme. Reports Ishow that Herbalife recruits talk jabout the company as a great ‘business opportunity’. But for most Ipeople who join, its a losing lproposition. These reports indicate {hat the company has a revolving \door workforce — a 90 percent {umover that undermines the {company's claims that itis just like [Costco. Many who do sign up make large up-front cost without the skills, lexperience or support to make a Isuccessful run of the project. Most lpeople don't make a profit and end lup losing money. Many of the [people in my community are forced to recruiting more people to join [The company offers nice rewards to| participants who recruit lots of jpeople and everyone needs money. [The company execs have publically lboasted about their “African lAmerican imitative" and “Latino Ibusiness”. They open up nutition Iclubs, which seems to be a recruitment tool, in minority {communities and they distribute lots lof materials in Spanish. But in the lend, the resellers are left holding ithe bag. (Complaint info CRA Dispute [Responded (Complaint Info CRA Dispute Resolved[Complaint nfo Fair Resolution Flag] (Complaint Info Fair Resolution [Description [Record 54 of 102 [Reference Number [49151853 |Created Date froraor2013 nea Fg ihe Complaint Assistant (Originator Reference Number ‘Language [English (Contact Type (Compiaint (Data Source (Consumer ] DNG? IN [Entered By |FTCCISFTCUSER ] [Entered Date frors02013 (Updated B [Updated Date [Agency Contact lintemet |Complaint Date [10/30/2013 Transaction Date [Member of armed forces or I (dependant? |Consumer First Name io) (Consumer Middle Name (Consumer Last Name ib(6) (Consumer Salutation (Consumer Address, Line 1 (Consumer Address, Line 2 ] (Consumer Address, Line 3 [Consumer Address, City ] (Consumer Address, State Code (Consumer Address, State Name (Consumer Address, Country Code _|USA [Consumer Address, Country Name UNITED STATES |Consumer Address, ZIP Code [Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code (Consumer Home Phone, Area (Code [Consumer Home Phone, Number(Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code (Consumer Work Phone, Number (Consumer Work Phone, Extension (Consumer Fax, Country Code (Consumer Fax, Area Code (Consumer Fax, Number (Consumer Cell Phone, Country (Code [Consumer Cell Phone, Area Code (Consumer Cell Phone, Number [Consumer Email (Consumer Age range (Consumer Miltary Status [Consumer Military Station (Consumer Complaining (CompanylOrg (Consumer Military Service Branch [Consumer Consent for volunteer youp contact? [Company Name. [Herbalife (Company Address, Line 1 [Company Address, Line 2 [Company Address, Line 3 (Company Address, City (Company Address, State Code [Company Address, State Name (Company Address, County Code lusa (Company Address, Country Name UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code (Company Phone, Area Code [Company Phone, Number (Company Phone, Extension [Company Email (Company Website [Company Subject ID Type Code [Company Subject ID Type Name. (Company Subject ID Issuing State [Code(Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name [Company Rep First Name (Company Rep Middle Name (Company Rep Last Name [Company Rep Salutation (Company Rep Comments (Complaint Info Initial Contact [Method [Complaint nfo initial Contact Date (Complaint Info Initial Response [Method (Complaint Info initial Response Date (Complaint info Amount Requested [Method (Complaint info Amount Requested Value (Complaint Info Amount Paid [Method [Complaint info Amount Paid Value (Complaint Info Product Service (Code jo304 (Complaint Info Product Service [Description iMulli-Level Mktg\Pyramids\Chain Letters (Complaint Info Law Violation Code [ppm (Complaint Info Law Violation [Description (Complaint Info Statute Code [Deception/Mistepresentation ee [Complaint info Statute Description [FTC Act Sec 5 (BCP) [Complaint Info Topic Code (Complaint Info Topic Description (Complaint info Comments [This is company really does look like a fraud.. Dont let this be lanother Allied Capital just because |some hedge fund manager who Istands to make money from lexposing Herbalife is the one who Ibroughtitto light. Yes, Ackman is. Ice interested and has brought this fraud into the spotlight to make Imoney. But the company stil is a fraud and not investigating it|destroys faith in the American lgovernment and lets the despicable Icorporate management of the lcompany get away with their con igame when they belong behind bars. (Complaint Info CRA Dispute Flag (Complaint Info CRA Dispute [Responded (Complaint Info CRA Dispute [Resolved (Complaint Info Fair Resolution Flag| [Complaint info Fair Resolution (Description [Record 55 of 102 [Reference Number laos2g054 (Created Date [11/05/2013 [Complaint Source [Federal Trade Commission (Originator Reference Number |Language | |English [Contact Type [Complaint [Data Source [Consumer |DNc? In Entered By [STAYLORROBINS [Entered Date [11/05/2013 (Updated 8 [STAYLORROBINS [Updated Date fr11072013 [Agency Contact [Phone [Complaint Date i11i0712013 ‘Transaction Date [Member of armed forces or Ly dependant? (Consumer First Name in(6) [Consumer Middle Name. (Consumer Last Name [ov6) [Consumer Salutation (Consumer Address, Line + [o(6) [Consumer Address, Line 2 [Consumer Address, Line 3 |Consumer Address, City [Bloomfield |Consumer Address, State Code _|CT (Consumer Address, State Name [Connecticut ‘Consumer Address, County Code [USA |[Consumer Address, Country Name [UNITED STATES (Consumer Address, ZIP Code [n(6) (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code (Consumer Home Phone, Area (Code (Consumer Home Phone, Number (Consumer Work Phone, Country (Code [Consumer Work Phone, Area Code (Consumer Work Phone, Number (Consumer Work Phone, Extension (Consumer Fax, Country Code (Consumer Fax, Area Code [Consumer Fax, Number (Consumer Cell Phone, Country (Code [Consumer Cell Phone, Area Code [Consumer Cell Phone, Number [Consumer Email [Consumer Age range [Consumer Military Status (Consumer Military Station (Consumer Complaining (CompanylOrg [Consumer Military Service Branch (Consumer Consent for volunteer (group contact? (Company Name [Herbalife (Company Address, Line 1 (Company Address, Line 2 (Company Address, Line 3 (Company Address, City (Company Address, State Code [Company Address, State Name [Company Address, Country Code [usa [Company Address, County Name [UNITED STATES [Company Address, ZIP Code [Company Address, ZIP Code [Extension [Company Phone, Country Code|Company Phone, Area Code —___| (Company Phone, Number (Company Phone, Extension (Company Email (Company Website (Company Subject ID Type Code (Company Subject ID Type Name (Company Subject ID Issuing State \Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name [Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation [Company Rep Comments (Complaint Info Initial Contact, [Method |Unknown [Complaint info Initial Contact Date (Complaint Info Initial Response [Method |Unknown (Complaint Info Initial Response [Date (Complaint Info Amount Requested [Method (Complaint Info Amount Requested Value ‘$0.00 (Complaint Info Amount Paid (Method jUnknown (Complaint Info Amount Paid Value [$0.00 (Complaint Info Product Service (Code jo304 (Complaint Info Product Servic [Description Multi-Level Mkig\Pyramids\Chain Letters (Complaint Info Law Violation Code DM ] (Complaint info Law Violation [Description [Deception/Misrepresentation [Complaint info Statute Code iP [Complaint Info Statute Description [FTC Act Sec 5 (BCP) (Complaint Info Topic Code (Complaint Info Topic Descriotion i I[CMs# 14008963: MAIL 11/05/2073: [The consumer wants the FTC to get| lanswers for Herbalife so the free Imarket is a fair market. The {company claims to be a multi-level Imarketing company, but really lappear to be a pyramid scheme. [Reports show that the representatives call the company a {great ‘business opportunity’ but, for Imost people who join, i's an lunpleasant experience. The reports. indicate that the company has a Irevolving door workforce that lundermines the company’s claims thatitis just like Costco. Many who {do sign up make large up-front cost jwithout the skills, experience or Isupport to make a successful run of ithe project. Most people don’t make: la profit and end up losing money. [Many of the people in my lcommunity are forced into recruiting |more people to join. The company lofters nice rewards to participants jwho recruit lots of people, and leveryone needs the money. The |company’s business executives Ihave publically boasted about their initiatives in the minority ‘communities, butin the end, the resellers are left holding the bag. (Complaint Info Comments (Complaint Info CRA Dispute Flag (Complaint Info CRA Dispute Iv Responded (Complaint Info CRA Dispute ly Resolved [Complaint Info Fair Resolution Flag (Complaint info Fair Resolution [Description [Record 56 of 102 Reference Number [49320117 ] (Created Date fr1/0512013 (Complaint Source [Federal Trade Commission ] Originator Reference Number [Language |Contact Type. [Complaint [Data Source [Consumeronc? In [Entered By [STAYLORROBINS [Entered Date [11/05/2013 (Updated 8 [STAYLORROBINS (Updated Date fi1i072013 lagency Contact iPhone [Complaint Date fr1i072013 [Transaction Date [Member of armed forces or Iv \dependant? [Consumer First Name [n(6) (Consumer Middle Name ine) (Consumer Last Name io(6) |Consumer Salutation [Consumer Address, Line 1 lo(6) |Consumer Address, Line 2 (Consumer Address, Line 3 (Consumer Address, City [Los Angeles (Consumer Address, State Code [CA (Consumer Address, State Name _[Califomia ‘Consumer Address, County Code _|USA (Consumer Address, Country Name UNITED STATES (Consumer Address, ZIP Code __|b(6) (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code (Consumer Home Phone, Area (Code (Consumer Home Phone, Number (Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code [Consumer Work Phone, Number (Consumer Work Phone, Extension [Consumer Fax, Country Code [Consumer Fax, Area Code [Consumer Fax, Number (Consumer Cell Phone, Country (Code (Consumer Cell Phone, Area Code: |Consumer Cell Phone, Number [Consumer Email|Consumer Age range (Consumer Miltary Status [Consumer Military Station (Consumer Complaining \CompanylOrg Vamos Unidos USA [Consumer Military Service Branch (Consumer Consent for volunteer youp contact? (Company Name [Herbalife (Company Address, Line 4 (Company Address, Line 2 (Company Address, Line 3 [Company Address, City [Company Address, State Code (Company Address, State Name (Company Address, Country Name [Company Address, County Code [usa [UNITED STATES [Company Address, ZIP Code (Company Address, ZIP Code [Extension [Company Phone, Country Code |Company Phone, Area Code (Company Phone, Number (Company Phone, Extension (Company Email (Company Website (Company Subject ID Type Code [Company Subject ID Type Name (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name (Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint Info Initial Contact [Method |Unknown[Complaint info intial Contact Date (Complaint info Initial Response [Method I |Unknown (Complaint Info Initial Response Date (Complaint Info Amount Requested [Method [Complaint Info Amount Requested \Value [Complaint Info Amount Paid [Method (Complaint Info Amount Paid Value ‘$0.00 |Unknown {$0.00 [Complaint Info Product Service (Code jo304 (Complaint Info Product Service Description (Complaint Info Law Violation Code (Complaint Info Law Violation Description (Complaint Info Statute Code [Complaint Info Statute Description [Multi-Level Mkig\Pyramids\Chain [Lottors [oom [Deception/Misrepresentation | [FTC Act Sec 5 (BCP) [Complaint Info Topic Code (Complaint Info Topic Description (Complaint Info Comments [CMS# 14008994: MAIL 11/05/2013: [The FTC received a letter signed by, Imultiple organization regarding |Herbalife. They see a growing issue in their communities. |Herbalife’s pyramid scheme, isupposedly offering an ‘excellent Ibusiness opportunity, is costing families thousands of hard-earned dollars. In 1986, the California JAttomney General successfully lprought a case against Herbalife in \which the Supreme Court of {California issued an injunction. The. injunction requires Herbalife to \verify retail sales and other {documentation to prove the lcompany's sales to distributors and lcustomers. They believe Herbalife isin direct violation of this injunction. Based on the company's: lpublic records and statements, the Icompany does not collect the Inecessary documentation that the injunction requires. This information is very important for regulators and lconsumers trying to determine if[Herbalife is an illegal pyrami Ischeme. Right now Herbalife’s \distibutors make claims about the health benefits of their products jwithout the science to back it up. [The injunction also requires that the |company stop making claims about ihe extreme health benefit ofits jproducts. The company has false iclaims in advertising and unfair targeting of Ethnic minorities, (Complaint Info CRA Dispute Flag (Complaint Info CRA Dispute Iv [Responded (Complaint Info CRA Dispute ly [Resolved [Complaint inf Fair Resolution Flag (Complaint Info Fair Resolution [Description [Record 57 of 102 [Reference Number [49600774 (Created Date hon102013 Complai roe BBB CA Los Angeles (Originator Reference Naber '13000020048571 [Language English (Contact Type (Complaint [Data Source (Organization |pNc? N [Entered By BBECALA-USER [Entered Date honor013 (Updated 8 (Updated Date [Agency Contact [Extemal Agency [Complaint Date 10/10/2043 Transaction Date [Member of armed forces or dependant? [Consumer First Name bie) ] [Consumer Midéle Name J |Consumer Last Name b(6) (Consumer Salutation (Consumer Address, Line 1 |b(6) (Consumer Address, Line 2 |b(6)[Consumer Address, Line 3 | [Consumer Address, City _ | TAMPA (Consumer Address, State (Code (Consumer Address, State Son Florida (Consumer Addres: (Country Code yea (Consumer Address, Cran tence UNITED STATES (Consumer Address, ZIP (Code (Consumer Address, ZIP fe FL (6) (Consumer Home Phone, (Country Code (Consumer Home Phone, ‘Area Code (Consumer Home Phone, Number. (Consumer Work Phone, (Country Code [Consumer Work Phone, \Area Code [Consumer Work Phone, Number (Consumer Work Phone, [Extension (Consumer Fax, Country (Code (Consumer Fax, Area Code (Consumer Fax, Number (Consumer Gell Phone, (Country Code (Consumer Cell Phone, \Area Code (Consumer Cell Phone, Number [Consumer Email bo) [Consumer Age range (Consumer Military Status [Consumer Miltary Station (Consumer Complaining \CompanylOrg (Consumer Military Service [Branch 'b(6) 'b(6)|Consumer Consent for \volunteer group contact? (Company Name Herbalife International of America, Inc. (Company Address, Line 1 [a00 W Olympic Blvd Ste 406 (Company Address, Line 2 (Company Address, Line 3 (Company Address, City LOS ANGELES (Company Address, State (Code cA (Company Address, State Name (California [Company Address, County (Code USA (Company Address, County Name UNITED STATES (Company Address, ZIP (Code (Company Address, ZIP (Code Extension (Company Phone, Country (Code (Company Phone, Area (Code ‘310 [Company Phone, Number [4109600 (Company Phone, Extension| [Company Email (Company Website Intp:/vww.herbalife.com (Company Subject ID Type (Code (Company Subject ID Type Name (Company Subject ID Issuing State Code (Company Subject ID Issuing State Name (Company Subject ID_ Issuing Country Code (Company Subject ID Issuing Country Name [Company Rep First Name (Mark |Company Rep Middle Name (Company Rep Last Name Hughes [Company Rep Salutation _| [Company Rep Comments(Complaint nfo Initial (Contact Method [Complaint Info initial [Contact Date (Complaint Info Initial [Response Method (Complaint Info Initial [Response Date (Complaint Info Amount [Requested Method (Complaint Info Amount Requested Value (Complaint Info Amount Paid] [Method (Complaint Info Amount Paid \Value (Complaint Info Product (Service Code (0304 (Complaint Info Product ‘Service Description ‘Multi-Level Mktg\Pyramids\Chain Letters (Complaint Info Law \Violation Code (Complaint Info Law \Violation Description (Complaint Info Statute (Code (Complaint Info Statute ription [Complaint Info Topic Code (Complaint info Topic [Description (Complaint info Comments ordered my product almost 2 weeks ago | have yet to receive them. On the web page it clearly states product will be delivered the following day... I's day 10 still | have nothing... tried calling and got the ‘company voice mail but never receive a call yet... have been scammed want my money back...Order_Number: ORDER ID = ‘Additional Comments: DesiredSettiementiD: Refund! still have not received Jucts..Why? Please call ate: Tue, 1 ro: From: pponghonaeicop comSubject: t ConfirmationDeat isis confirmation of your payment to Herbal Product Shop(support@herbalproductshop.com) ORDER INT: 3466ORDER ID: RDER DATE : 1 October 2013 \you have questions about this order, please respond directly to this email or click on the link b (Complaint info CRA [Dispute Flag (Complaint Info CRA [Dispute Responded (Complaint Info CRA Dispute Resolved (Complaint Info Fair Yes (Complaint Info Fair [Resolution Description [ASSUMED RESOLVED. The business addressed the issue, but the consumer has inot verified with the BBB that the complaint is settled nor requested additional BBB lassistance, [Record 58 of 102 Reference Number [49534238 [Created Date [10/04/2013 I (Complaint Source [BBB CA Los Angeles [Originator Reference Number |13000020047257 | [Language [English [Contact Type [Complaint [Data Source [Organization DNC? IN [Entered By [BBBCALA-USER [Entered Date jro/o4/2013 | (Updates 8 [Updated Date [Agency Contact [Extemal Agency [Complaint Date froioai2013, [Transaction Date [Member of armed forces or \dependant? (Consumer First Name io(6) [Consumer Middle Name [Consumer Last Name [D(6) (Consumer Salutation [Consumer Address, Line 1 joe) |Consumer Address, Line 2 [Consumer Address, Line 3|Consumer Address, City WENATCHEE WA [Consumer Address, State Code __ WA (Consumer Address, State Name __ Washington (Consumer Address, Country Code _|USA [Consumer Address, Country Name (Consumer Address, ZIP Code |UNITED STATES: [b(6) J (Consumer Address, ZIP Code [Extension (Consumer Home Phone, County (Code [Consumer Home Phone, Area (Code [Consumer Home Phone, Number [Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code ove) (Consumer Work Phone, Number (b(6) [Consumer Work Phone, Extension [Consumer Fax, Country Code [Consumer Fax, Area Code [Consumer Fax, Number (Consumer Cell Phone, Country (Code [Consumer Gell Phone, Area Gode |Consumer Cell Phone, Number (Consumer Email ioe) [Consumer Age range [Consumer Military Status | (Consumer Military Station (Consumer Complaining \CompanylOrg [Consumer Military Service Branch (Consumer Consent for volunteer roup contact? (Company Name [Herbalife Intemational of America, inc. (Company Address, Line 1 (800 W Olympic Bivd Ste 406 ] (Company Address, Line 2 (Company Address, Line 3 [Company Address, City |LOS ANGELES iny Address, State Code __|CA [Company Address, State Name _|California ] |Company Address, Country Code [USA[Company Address, County Name UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code (Company Phone, Area Code [s10 (Company Phone, Number [4109600 [Company Phone, Extension [Company Email (Company Website Intipyiwww.herbalife.com [Company Subject ID Type Code (Company Subject ID Type Name (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name (Company Rep First Name [Mark (Company Rep Middle Name (Company Rep Last Name [Hughes (Company Rep Salutation (Company Rep Comments (Complaint Info Initial Contact, [Method [Complaint nfo Initial Contact Date (Complaint info initial Response [Method (Complaint Info Initial Response (Date (Complaint Info Amount Requested [Method (Complaint Info Amount Requested \Value (Complaint Info Amount Paid [Method (Complaint Info Amount Paid Value (Complaint Info Product Service (Code jo304 (Complaint Info Product Service [Description [Multi-Level Mktg\Pyramids\Chain Letters (Complaint Info Law Violation Code (Complaint Info Law Violation iDescription (Complaint Info Statute Code [Complaint Info Statute Description [Complaint Info Topic Code [Complaint Info Topic Description (Complaint Info Comments should even be harassing people. Ihave asked numerous times to not ibe called by this number: 503-849- '5865 regarding Metabolife. | |warned them that | would contact, lyou to stop this and nothing has Ihelped. I do not know ifit is a legit [business or not but | do not need to ibe harassed 15x throughout the day, land night! — Additional Comments: [DesiredSettiementiD: Other (requires explanation)To not be {called ever again and for them to be investigated to see ifthis number (Complaint Info CRA Dispute Flag (Complaint Info CRA Dispute [Responded (Complaint info CRA Dispute Resolved (Complaint Info Fair Resolution Flag [No (Complaint Info Fair Resolution [Description [Reference Number Inot have a marketplace transaction. [Record 59 of 102 ] INVALID. The consumer complaint lis incomplete or unintellighle and ithe consumer cannot be reached, or ithe consumer and the business did [49580543 [Created Date [Complaint Source | f11/182013 I [Federal Trade Commission [Originator Reference Number | [Language [English (Contact Type (Complaint [Data Source |Consumer DNC? IN [Entered By ISTAYLORROBINS [Entered Date frsne2013| Updated B: [STAYLORROBINS (Updated Date fr1182013| [Agency Contact iPhone [Complaint Date fis182013[Transaction Date —___| [Member of armed forces or IN dependant? (Consumer First Name ib(6) (Consumer Middle Name (Consumer Last Name in(6) (Consumer Salutation (Consumer Address, Line 1 io(6) [Consumer Address, Line 2 (Consumer Address, Line 3 J [Consumer Address, City New York I |Consumer Address, State Code __|NY | [Consumer Address, State Name _|New York ] [Consumer Address, Country Code _|USA [Consumer Address, Country Name |UNITED STATES [Consumer Address, ZIP Code _b(6) (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code Phone, [Consumer Home Phone, Ares ey [Consumer Home Phone, Number _|b@) (Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code (Consumer Work Phone, Number [Consumer Work Phone, Extension (Consumer Fax, Country Code (Consumer Fax, Area Code be) (Consumer Fax, Number [ove (Consumer Gell Phone, Country (Code (Consumer Gell Phone, Area Code (Consumer Cell Phone, Number [Consumer Email (Consumer Age range (Consumer Miltary Status [Consumer Military Station (Consumer Complaining (CompanylOrg [Audubon Partnership for Economic [Development (Consumer Military Service Branch [Consumer Consent for volunteer(group contact? a (Company Name. [Herbalife Lid (Company Address, Line 1 (Company Address, Line 2 (Company Address, Line 3 (Company Address, City (Company Address, State Code (Company Address, State Name (Company Address, Country Code [usa (Company Address, County Name [UNITED STATES. [Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code [Company Phone, Area Code Company Phone, Number [Company Phone, Extension (Company Email (Company Website (Company Subject ID Type Code (Company Subject ID Type Name (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name. (Company Subject ID Issuing (Country Code [Company Subject ID Issuing (Country Name (Company Rep FirstName (Company Rep Middle Name [Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint Info Initial Contact, [Method |Unknown (Complaint Info Initial Contact Date (Complaint info Initial Response [Method |Unknown (Complaint info initial Response (Date (Complaint info Amount Requested [Method [Ramantnint Inte Reamsint Domania |\s0.00 (Complaint Info Amount Paid (Code (Complaint Info Product Service (Complaint info Law Violation Code | varor {Unknown (Complaint Info Amount Paid Value ($0.00 [Complaint nfo Product Service [ong [Multi-Level Mkig\Pyramids\Chain [Letters loom | (Complaint Info Law Violation [Description [Deception/Misrepresentation [Complaint Info Statute Code iP (Complaint Info Statute Description IFTC Act Sec 5 (BCP) (Complaint info Topic Code (Complaint info Topic Description [Complaint Info Comments (Complaint Info CRA Dispute Flag [CMs# 14009061: MAIL 11/18/2013: [The consumer sent a copy of their letter address to the AG's office. [The consumer is writing on behalf lof their organization. The lorganization is committed to lincreasing opportunities for local residents and small businesses in ithe communities of Washington [Heights and Inwood in New York (City. The organization works to crease access to small business land consumer loans and help ity business attract capital. [People are looking for viable lopportunities for financial growth land new businesses. Herbalife claims to be one such opportunity but, in our experience, they do not. [Herbalife takes advantage of low- jincome and minority people in the lcommunity by convincing them to {take part ina losing business deal. [The company makes false lpromises about the money people Ican make by joining the program, lbut never delivers. In the end, lalmost all the people who join {Herbalife lose their money and end lup in debt. (Complaint Info CRA Dispute [Responded [Complaint info CRA Dispute[Resolve r [Complaint Info Fair Resolution Flag (Complaint Info Fair Resolution [Description [Record 60 of 102 [Reference Number [ag580580 [Created Date f11/1872013 (Complaint Source [Federal Trade Commission [Originator Reference Number [Language [English (Contact Type (Complaint [Data Source (Consumer DNC? IN [Entered By [STAYLORROBINS [Entered Date fis18/2013 [Updated By [STAYLORROBINS [Updated Date [1118/2013 [Agency Contact [Complaint Date [Transaction Date [Member of armed forces or Iv idependant? (Consumer First Name ib(6) (Consumer Middle Name (Consumer Last Name |e) (Consumer Salutation [Consumer Address, Line 1 lo) (Consumer Address, Line 2 (Consumer Address, Line 3 ] (Consumer Address, City [Los Angeles [Consumer Address, State Code _|CA | [Consumer Address, State Name _ [California (Consumer Address, Country Code USA (Consumer Address, Country Name [UNITED STATES [Consumer Address, ZIP Code io(6) (Consumer Address, ZIP Code [Extension (Consumer Home Phone, County (Code [Consumer Home Phone, Area (Code [Consumer Home Phone, Number(Code (Consumer Work Phone, Country (Consumer Work Phone, Area Code (Consumer Work Phone, Number (Consumer Work Phone, Extension (Consumer Fax, Country Code (Consumer Fax, Area Code (Consumer Fax, Number (Consumer Cell Phone, Country (Code [Consumer Cell Phone, Area Code |Consumer Cell Phone, Number [Consumer Email [Consumer Age range [Consumer Military Status [Consumer Military Station (Consumer Complaining \CompanylOrg (Counce! of Bi-national Community \Organizations [Consumer itary Service Branch (Consumer Consent for volunteer \group contact? [Company Name [Herbalife Company Address, Line 1 (Company Address, Line 2 [Company Adcress,Line 3 (Company Address, City (Company Address, State Code (Company Address, State Name (Company Address, Country Code [usa (Company Address, County Name [UNITED STATES. (Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code (Company Phone, Area Code [Company Phone, Number [Company Phone, Extension [Company Email |Company Website [Company Subject Type Code [Company Subject ID Type Name (Company Subject ID Issuing State (Code[Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name (Company Rep First Name (Company Rep Middle Name (Company Rep Last Name [Company Rep Salutation (Company Rep Comments (Complaint Info Initial Contact, [Method jUnknown [Complaint Info Initial Contact Date [Complaint info Initial Response thod |Unknown (Complaint nfo initial Response Date (Complaint Info Amount Requested [Method (Complaint Info Amount Requested Value [$0.00 (Complaint Info Amount Paid [Method |Unknown |Complaint Info Amount Paid Value {$0.00 (Complaint Info Product Service (Code (Complaint Info Product Service [Description (Complaint info Law (Complaint Info Law Violation [Description jo304 [Multi-Level Mkig\Pyramids\Chain lLetters loom [Deception/Misrepresentation [Complaint info Statute Code [Complaint Info Statute Description | iP [FTC Act Sec 5 (BCP) [Complaint Info Topic Code (Complaint Info Topic Description [CMS# 14008093; MAIL 11/18/2013: [The consumer sent a copy of their letter address to the AG's office. [The consumer is writing on behalf lof their organization. Since 2008, ithe organization has provided a Imyriad of services to the Spanish Ispeaking community of the City of |Los Angeles. The organization is [committed to protecting the|members in our mission, which is \why, they are requesting an investigation of Herbalife. Herbalife loperates as a pyramid scheme, lunfairly targeting ethnic minorities, |Herbalife’s pyramid scheme is legal, because members are lincentivized to recruit rather than cell product, leaving those at the ibottom with no way to succeed Iselling the product. Herbalife lunfairly targets minorities and is in Wviolation of the 1986 injunction. The: injunction requires Herbalife to \verify retail sales and other \documentation to prove the {company's sales to distributors and icustomers. They are urging the \Santa Cruz District Attomey to lenforce the 1986 injunction against {Herbalife and demand release of (Complaint Info Comments these records. (Complaint info CRA Dispute Flag __ (Complaintinfo CRA Dispule fy [Responded | (Complaint nfo CRA Dispule fy Resolved [Complaint info Fair Resolution Flag [Complaint info FairResolution [Description [Record 61 of 102 [Reference Number fagse0s13 (Created Date frai1@2013 [Complaint Source [Federal Trade Commission [Originator Reference Number | [Language [English |Contact Type [Complaint | [Data Source [Consumer ] DNC? IN [Entered By |STAYLORROBINS ] [Entered Date fisngi2013 [Updated By ISTAYLORROBINS: Updated Date [11/18/2013 } [Agency Contact |Phone [Complaint Date fr1ng2013 ] [Transaction Date|Member of armed forces or \dependant? IN (Consumer First Name io(6) (Consumer Middle Name in(6) (Consumer Last Name ib(6) (Consumer Salutation (Consumer Address, Line 1 inv6) (Consumer Address, Line 2 [Consumer Address, Line 3 \Consumer Address, City |Los Angeles | [Consumer Address, State Code _ [CA I (Consumer Address, State Name [Consumer Address, Country Code [California ] [usa [Consumer Address, Country Name (Consumer Address, ZIP Code | [UNITED STATES ioe) (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code [Consumer Home Phone, Area (Code lb) [Consumer Home Phone, Number [ov6) (Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code (Consumer Work Phone, Number (Consumer Work Phone, Extension |Consumer Fax, Country Code [Consumer Fax, Area Code (Consur Number (Consumer Cell Phone, Country [Code (Consumer Cell Phone, Area Code (Consumer Gell Phone, Number [Consumer Email [Consumer Age range (Consumer Military Status [Consumer Military Station (Consumer Complaining \CompanylOrg Vamos Unidos USA [Consumer Miltary Service Branch (Consumer Consent for volunteer youp contact?[Company Name \[Herbatite (Company Address, Line 1 [Company Address, Line 2 (Company Address, Line 3 (Company Address, City (Company Address, State Code (Company Address, State Name (Company Address, County Code [usa (Company Address, County Name [UNITED STATES (Company Address, ZIP Code [Company Address, ZIP Code [Extension [Company Phone, Country Code (Company Phone, Area Code [Company Phone, Number |Company Phone, Extension (Company Email (Company Website [Company Subject ID Type Code (Company Subject ID Type Name (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name (Company Rep First Name (Company Rep Middle Name (Company Rep Last Name |Company Rep Salutation (Company Rep Comments (Complaint Info Initial Contact, (Method |Unknown [Complaint Info Initial Contact Date (Complaint Info Initial Response [Method |Unknown (Complaint nfo initial Response Date (Complaint info Amount Requested [Method (Complaint Info Amount Requested Value '$0.00(Complaint Info Amount Paid [Method (Complaint Info Amount Paid Value [$0.00 (Complaint info Product Service |ggo4 |Unknown (Code (Complaint info Product Service Multi-Level Mktg\Pyramids\Chain [Description Letters (Complaint info Law Violation Code [DDM (Complaint info Law Violation [Description [Complaint info Statute Code Je (Complaint Info Statute Description _|FTC Act Sec § (BCP) [Complaint info Topic Code [Complaint Info Topic Description [Deception/Misrepresentation [CMs# 14009097: MAIL 11/18/20%: |The consumer sent a copy of their letter address to the AG's office. [The consumer is writing on behalf lof their organization. The consumer Ihas been working on behalf of the {immigrant community in Southern |California for more than thiry years. [They provide legal and educational Iservices and are located in the city lof Los Angeles. The organization is |committed to protecting the |members in our mission, which is lwhy; they are requesting an estigation of Herbalife. Herbalife loperates as a pyramid scheme, lunfairly targeting ethnic minorities |Herbalife's pyramid scheme is illegal, because members are centivized to recruit rather than Isell product, leaving those at the ibottom with no way to succeed Iselling the product. Herbalife lunfairly targets minorities and is in Wiolation of the 1986 injunction. The injunction requires Herbalife to \verify retail sales and other {documentation to prove the lcompany's sales to distributors and lcustomers. They are urging the {Santa Cruz District Attomey to lenforce the 1986 injunction against {Herbalife and demand release of hese records. (Complaint Info Comments [Complaint Info CRA Dispute Flag _| [Complaint Info CRA Dispute ke[Responded r (Complaint Info CRA Dispute [Resolved IN (Complaint Info Fair Resolution Flag (Complaint Info Fair Resolution [Description [Record 62 of 102 [Reference Number [a9580626 (Created Date fraire2013 (Complaint Source [Federal Trade Commission [Originator Reference Number [Language [English I (Contact Type (Complaint ] (Data Source [Consumer | DNC? IN [Entered By [STAYLORROBINS [Entered Date fi118/2013 (Updated By [STAYLORROBINS [Updated Date [11/18/2013 [Agency Contact [Phone [Complaint Date [11/18/2013 [Transaction Date [Member of armed forces or ly \dependant? (Consumer First Name ib(6) (Consumer Middle Name (Consumer Last Name in(6) (Consumer Salutation ] (Consumer Address, Line 1 ove) J (Consumer Address, Line 2 | (Consumer Address, Line 3 (Consumer Address, City [Long Beach (Consumer Address, State Code __|CA [Consumer Address, State Name _ [California |Consumer Address, Country Code [USA [Consumer Address, Country Name [UNITED STATES [Consumer Address, ZIP Code ove) (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code [Consumer Home Phone, Area(Code Pd (Consumer Home Phone, Number (Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code (Consumer Work Phone, Number (Consumer Work Phone, Extension (Consumer Fax, Country Code [Consumer Fax, Area Code (Consumer Fax, Number [Consumer Cell Phone, Country (Code (Consumer Gell Phone, Area Code (Consumer Cell Phone, Number (Consumer Email [Consumer Age range [Consumer Mitary Setus [Consumer Military Station (Consumer Complaining |CompanyiOrg [Federacion de Clubes Unidos Por |Guerrero. [Consumer Military Service Branch [Consumer Consent for volunteer \group contact? [Company Name [Herbalife [Company Address, Line 1 [Company Address, Line 2 (Company Address, Line 3 (Company Address, City (Company Address, State Code (Company Address, State Name [Company Address, Country Code [usa (Company Address, County Name [UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension [Company Phone, Country Code (Company Phone, Area Code [Company Phone, Number (Company Phone, Extension [Company Email |Company Website [Company Subject ID Type Code (Company Subject ID Type Name(Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing \Country Code [Company Subject ID Issuing (Country Name [Company Rep First Name [Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint info initial Contact, [Method jUnknown [Complaint Info initial Contact Date (Complaint nfo initial Response [Method |Unknown (Complaint Info Initial Response [Date (Complaint info Amount Requested ‘Method (Complaint Info Amount Requested Value {$0.00 (Complaint Info Amount Paid [Method |Unknown (Complaint Info Amount Paid Value [$0.00 [Complaint Info Product Service (Code jo304 (Complaint Info Product Service (Description [Multi-Level Mktg\Pyramids\Chain [Letters [Complaint Info Law Violation Code [ppm (Complaint Info Law Violation [Description [Complaint Info Statute Code [Deception/Misrepresentation iP [Complaint Info Statute Description [FTC Act Sec 5 (BCP) [Complaint Info Topic Code (Complaint Info Topic Description [CMS# 14008095: MAIL 11/18/2013: [The consumer sent a copy of their letter address to the AG's office. [The consumer is writing on behalf lof their organization. The lorganization is located in the City of [Long Beach, California. They are a Inot for profit;community based(Complaint Info Comments lorganization providing civics and leducational services to the residents of Los Angeles county. [The organization is committed to iprotecting the members in our Imission, which is why; they are requesting an investigation of |Herbalife. Herbalife operates as a [pyramid scheme, unfairly targeting lethnic minorities. Herbalife's lpyramid scheme is illegal. because Imembers are incentivized to recruit Iather than sell product, leaving {those at the bottom with no way to Isucceed selling the product. [Herbalife unfairly targets minorities land is in violation of the 1986 junction, The injunction requires [Herbalife to verity retail sales and lother documentation to prove the lcompany's sales to distributors and lcustomers. They are urging the ‘Santa Cruz District Atlomey to lenforce the 1986 injunction against [Herbalife and demand release of these records. (Complaint Info CRA Dispute Flag (Complaint Info CRA Dispute [Responded IN (Complaint info CRA Dispute Iv Resolved (Complaint info Fair Resolution Fi (Complaint info Fair Resolution [Description Record 63 of 102 [Reference Number laose0646 | (Created Date frs182013| (Complaint Source |Federal Trade Commission (Originator Reference Number (Language [Engish |Contact Type |Complaint [Data Source [Consumer [pnc? IN’ ] [Entered By [STAYLORROBINS ] [Entered Date fi1/18/2013 Updated Bi [STAYLORROBINS (Updated Date fr1/1872013[Agency Contact \[Phone [Complaint Date fr1182013 ‘Transaction Date [Member of armed forces or In dependant? (Consumer First Name in(6) (Consumer Middle Name iov6) (Consumer Last Name iov6) (Consumer Salutation (Consumer Address, Line 1 iov6) [Consumer Address, Line 2 |Consumer Address, Line 3 [Consumer Address, Ci [Coachella [Consumer Address, State Code [CA [Consumer Address, State Name [California |Consumer Address, Country Code [USA (Consumer Address, Country Name [UNITED STATES (Consumer Address, ZIP Code foe) [Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code (Consumer Home Phone, Area (Code [Consumer Home Phone, Number (Consumer Work Phone, Country (Code [Consumer Work Phone, Area Code (Consumer Work Phone, Number (Consumer Work Phone, Extension (Consumer Fax, Country Code Consumer Fax, Area Code (Consumer Fax, Number (Consumer Cell Phone, Country (Code [Consumer Cell Phone, Area Code (Consumer Cell Phone, Number [Consumer Email (Consumer Age range [Consumer Military Status [Consumer Military Station (Consumer Complaining (CompanylOrg [Binational Union of Ex-braceros[Consumer Military Service Branch _| (Consumer Consent for volunteer yroup contact? (Company Name [Herbalife (Company Address, Line 1 (Company Address, Line 2 (Company Address, Line 3 (Company Address, City (Company Address, State Code (Company Address, State Name [Company Address, Country Code _|USA (Company Address, County Name_|UNITED STATES [Company Address, ZIP Code (Company Address, ZIP Code [Extension [Company Phone, Country Code |Company Phone, Area Code [Company Phone, Number [Company Phone, Extension [Company Email [Company Website (Company Subject ID Type Code (Company Subject ID Type Name (Company Subject ID Issuing State [Code (Company Subject ID Issuing State Name [Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name |Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation [Company Rep Comments (Complaint Info Initial Contact, [Method [Complaint info Initial Contact Date (Complaint info initial Response [Method (Complaint info initial Response (Date (Complaint Info Amount Requested |Unknown |Unknown(Complaint info Amount Requested [gn 49 Value (Complaint Info Amount Paid. [Method (Complaint Info Amount Paid Value [$0.00 (Complaint Info Product Service |Unknown icone los04 Complaint Info Product Service —_| Multi-Level Mkig\Pyramids\Chain [Description [Letters (Complaint info Law Violation Code [DDM (Complaint Info Law Violation [Description [Complaint Info Statute Code IP [Complaint info Statute Description [FTC Act Sec 5 (BCP) [Complaint nfo Topic Code | (Complaint Info Topic Description [Deception/Misrepresentation [CMs# 14009098: MAIL 11/18/2013: [The consumer sent a copy of their letter address to the AG's office. [The consumer is writing on behalf lof their organization. The lorganization’s focus remains |winning justice for the almost four Imillion Mexican workers who came to work to the US in agriculture, Imining and railroad industries from 11942 through 1964. Thus far, the [Mexican Government has {compensated about 200,000 ex- lbraceros with almost a billion \dollars. The organization is |committed to protecting the Imembers in our mission, which is lwhy; they are requesting an investigation of Herbalife. Herbalife loperates as a pyramid scheme, lunfairly targeting ethnic minorities. |Herbalife's pyramid scheme is gal, because members are entivized to recruit rather than sell product, leaving those at the lbottom with no way to succeed Iselling the product. Herbalife lunfairly targets minonties and is in Wiolation of the 1986 injunction. The injunction requires Herbalife to Werify retail sales and other \documentation to prove the |company's sales to distributors and (Complaint info Commentslcustomers. They are urging the (Santa Cruz District Attomey to lenforce the 1986 injunction against [Herbalife and demand release of Ithese records, (Complaint Info CRA Dispute Flag (Complaint Info CRA Dispute [Responded (Complaint Info CRA Dispute Resolved [Complaint Info Fair Resolution Flag) [Complaint info Fair Resolution [Description [Record 64 of 102 Reference Number lagssose (Created Date fi1i182013 (Complaint Source [Federal Trade Commission (Originator Reference Number Language |English | [Contact Type [Complaint | |Data Source |Consumer onc? IN [Entered By [STAYLORROBINS [Entered Date iane2013 [Updated By |STAYLORROBINS (Updated Date in1182013 lAgency Contact iPhone [Complaint Date f111872013 [Transaction Date [Member of armed forces or ly dependant? (Consumer First Name inv6) (Consumer Middle Name (Consumer Last Name ioe) (Consumer Salutation | [Consumer Address, Line 4 io) ] |Consumer Address, Line 2 [Consumer Address, Line 3 [Compton [Consumer Address, Stato Code ica. (Consumer Address, State Name __|Califomia (Consumer Address, Country Code _|USA[Consumer Address, Country Name JUNITED STATES (Consumer Address, ZIP Code __[b(6) [Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code (Consumer Home Phone, Area (Code Consumer Home Phone, Number [Consumer Work Phone, Country (Code [Consumer Work Phone, Area Code (Consumer Work Phone, Number [Consumer Work Phone, Extension (Consumer Fax, Country Code [Consumer Fax, Area Code (Consumer Fax, Number (Consumer Cell Phone, Country (Code [Consumer Cell Phone, Area Code (Consumer Cell Phone, Number [Consumer Email (Consumer Age range (Consumer Military Status (Consumer Military Station (Consumer Complaining (CompanylOrg [Consumer Military Service Branch (Consumer Consent for volunteer lgroup contact? [Company Name. [Herbalife [Company Address, Line 1 [Company Address, Line 2 [Company Address, Line 3 (Company Address, City (Company Address, State Code (Company Address, State Name (Company Address, County Code _|USA (Company Address, County Name_|UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code \Club Unidos Por Copala|Company Phone, Area Code —___| (Company Phone, Number (Company Phone, Extension (Company Email (Company Website (Company Subject ID Type Code (Company Subject ID Type Name (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name [Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation [Company Rep Comments (Complaint Info Initial Contact, [Method |Unknown [Complaint info Initial Contact Date (Complaint Info Initial Response [Method |Unknown (Complaint Info Initial Response [Date (Complaint Info Amount Requested [Method (Complaint Info Amount Requested Value ‘$0.00 (Complaint Info Amount Paid (Method jUnknown (Complaint Info Amount Paid Value [$0.00 (Complaint Info Product Service (Code jo304 (Complaint Info Product Servic [Description Multi-Level Mkig\Pyramids\Chain Letters (Complaint Info Law Violation Code DM ] (Complaint info Law Violation [Description [Deception/Misrepresentation [Complaint info Statute Code iP [Complaint Info Statute Description [FTC Act Sec 5 (BCP) (Complaint Info Topic Code (Complaint Info Topic Descriotion i I[CMS# 14009096: MAIL 11/16/2013:| [The consumer sent a copy of their letter address to the AG's office. [The consumer is writing on behalf lof their organization. The lorganizations main focus of work is ladvocating for the working towards ithe complete integration of our Imembers, and of the community at large, into the American Imainstream. That is why they ipromote comprehensive jimmigration reform, education and |Obamacare. The organization is [committed to protecting the |members in our mission, which is lwhy; they are requesting an investigation of Herbalife. Herbalife (Complaint info Comments loperates as a pyramid scheme, lunfairly targeting ethnic minorities. |Herbalife's pyramid scheme is gal, because members are lincentivized to recruit rather than sell product, leaving those at the ibottom with no way to succeed Iselling the product. Herbalife lunfairly targets minorities and is in Wviolation of the 1986 injunction. The injunction requires Herbalife to Werify retail sales and other {documentation to prove the {company's sales to distributors and lcustomers. They are urging the {Santa Cruz District Atlomey to lenforce the 1986 injunction against [Herbalife and demand release of these records. [Complaint Info CRA Dispute Flag _| (Complaint Info CRA Dispute Responded u [Complaint Info GRA Dispute fy Resolved [Complaint Info Fair Resolution Flag | (Complaint Info Fair Resolution Description [Record 65 of 102 Reference Number [49580670 (Created Date ir118/2013 [Complaint Source Federal Trade Commission[Originator Reference Number __| [Language [English (Contact Type [Complaint (Data Source (Consumer DNC? IN [Entered By [STAYLORROBINS [Entered Date fi1i182013 (Updated By [STAYLORROBINS [Updated Date f1118/2013 [Agency Contact iPhone [Complaint Date fmea013 [Transaction Date [Member of armed forces or Li \dependant? [Consumer First Name lo(6) |Consumer Middle Name (Consumer Last Name [o(6) (Consumer Salutation [Consumer Address, Line 4 [b@) (Consumer Address, Line 2 [Consumer Address, Line 3 (Consumer Address, Ci [Los Alamitos (Consumer Address, State Code [CA (Consumer Address, State Name |Califomia (Consumer Address, Country Code_|USA (Consumer Address, Country Name [UNITED STATES. [Consumer Address, ZIP Code [d(6) (Consumer Address, ZIP Code [Extension |Consumer Home Phone, Country: (Code (Consumer Home Phone, Area (Code (Consumer Home Phone, Number (Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code [Consumer Work Phone, Number [Consumer Werk Phone, Exons |Consumer Fax, Country Code |Consumer Fax, Area Code [Consumer Fax, Number (Consumer Gell Phone, Country|code (Consumer Cell Phone, Area Code [Consumer Cell Phone, Number [Consumer Email [Consumer Age range (Consumer Miltary Status (Consumer Military Station (Consumer Complaining conearstng (Club Rio Balsa [Consumer Military Service Branch (Consumer Consent for volunteer \group contact? [Company Name [Herbalife [Company Address, Line 1 (Company Address, City [Company Address, Slate Code (Company Address, State Name (Company Address, County Code _|USA (Company Address, County Name _|UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension [Company Phone, Country Code (Company Phone, Area Code (Company Phone, Number [Company Phone, Extension (Company Email [Company Website (Company Subject ID Type Code wy Subj ype [Company Subject ID Type Name (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name [Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name (Company Rep First Name (Company Rep Middle Name [Company Rep Last Name[Company Rep Salutation I (Company Rep Comments | (Complaint Info Initial Contact [Method (Complaint Info Initial Contact Date (Complaint info Initial Response toe |Unknown (Complaint info Initial Response [Date [Complaint info Amount Requested | ‘Method ‘Complaint info Amount Requested Value ‘$0.00 | [Complaint Info Amount Paid rated [Unknown (Complaint Info Amount Paid Value _|$0.00 [Complaint Info Product Service \Code (e304 [Complaint Info Product Service |Mult-Level Mikig)Pyramids\Chain Description lLeters (Complaint Info Law Violation Code [DDM [Complaint Info Law Violation | aceciorinmmoniesananan Description [Complaint Info Statute Code Pr. [Complaint Info Statute Description _|FTC Act Sec 5 (BCP) [Complaint info Topic Code | (Complaint Info Topic Description |Unknown [CMs# 14009099: MAIL 11/18/2073: [The consumer sent a copy of their letter address to the AG's office. [The consumer is writing on behalf lof their organization. The lorganizations main focus of work is ladvocating for the working towards ithe complete integration of our Imembers, and of the community at large, into the American Imainstream. That is why they lpromote comprehensive jimmigration reform, education and |Obamacare. The organization is |committed to protecting the |members in our mission, which is lwhy; they are requesting an investigation of Herbalife. Herbalife (Complaint Info Comments loperates as a pyramid scheme, lunfairly targeting ethnic minorities, |Herbalife’s pyramid scheme is illegal, because members arejincentivized to recruit rather than sell product, leaving those atthe ibottom with no way to succeed Iselling the product. Herbalife lunfairly targets minorities and is in Wiolation of the 1986 injunction. The: injunction requires Herbalife to \verfy retall sales and other {documentation to prove the {company's sales to distributors and Icustomers. They are urging the \Santa Cruz District Attomey to lenforce the 1986 injunction against [Herbalife and demand release of hese records. (Complaint info CRA Dispute Flag (Complaint info CRA Dispute [Responded (Complaint info CRA Dispute [Resolved [Complaint info Fair Resolution Flag | (Complaint Info Fair Resolution [Description [Record 66 of 102 [Reference Number [49703316 |Created Date lo [BBB CA San Jose (Complaint Source [Originator Reference Number __[12160020033718 [Language [English [Contact Type [Complaint [Data Source lOrganization |DNC? IN [Entered By [BBBSANCA-USER Entered Date jos/07/2013 [Updated By (Updated Date [Agency Contact [Extemal Agen [Complaint Date (0807/2013 [Transaction Date [Member of armed forces or dependant? |Consumer First Name love) (Consumer Middle Name [Consumer Last Name lve) (Consumer Salutation[Consumer Address, Line 1 fore) [Consumer Address, Line 2 |Consumer Address, Line 3 [Consumer Address, City [PHOENIX (Consumer Address, State Code [AZ (Consumer Address, State Name __[Arizona (Consumer Address, Country Code usa [Consumer Address, Country Name | [UNITED STATES (Consumer Address, ZIP Code (Consumer Address, ZIP Code 6) [Consumer Home Phone, Country (Code (Consumer Home Phone, Area (Code (Consumer Home Phone, Number (Consumer Work Phone, Country (Code. (Consumer Work Phone, Area Code [b(6), [Consumer Work Phone, Number _ | [o(6) (Consumer Work Phone, Extension (Consumer Fax, Country Code (Consumer Fax, Area Code (Consumer Fax, Number (Consumer Cell Phone, Country (Code (Consumer Cell Phone, Area Code. [Consumer Cell Phone, Number [Consumer Email [Consumer Age range [Consumer Military Status [Consumer Military Station (Consumer Complaining [CompanyOrg [Consumer Military Service Branch (Consumer Consent for volunteer {group contact? (Company Name (Company Address, Line 1 [Herbalife Intemational of America, Inc. [00 W Olympic Bivd Ste 406 [Company Address, Line 2 [Company Address, Line 3 | [Company Address, City LOS ANGELES[Company Address, State Code _|CA (Company Address, State Name __|Califomia (Company Address, County Code [USA [Company Address, County Name [UNITED STATES. (Company Address, ZIP Code __| (Company Address, ZIP Code (Company Subject ID Type Code: [Extension (Company Phone, Country Code [Company Phone, Area Code [s10 (Company Phone, Number [4109600 [Company Phone, Extension (Company Email | (Company Webs Initp:/inww.herbalife.com [Company Subject ID Type Name _| J (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name [Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint info Initial Contact, [Method [Complaint Info initial Contact Date _| (Complaint info Initial Response [Method (Complaint Info Initial Response Date (Complaint Info Amount Requested [Method [Complaint Info Amount Requested \Value [Complaint Info Amount Paid [Method [Complaint Info Amount Paid Value_| |Complaint Info Product Service Code pA(Complaint Info Product Service Description |Mult-Level Mktg\Pyramids\Chain lLetters (Complaint Info Law Violation Code (Complaint Info Law Violation Description (Complaint Info Topic Code [Complaint Info Statute Code (Complaint Info Statute Description (Complaint Info Topic Description (Complaint Info Comments [The owner of Plaza Kora LLC rents lout a small location to a lady called Who advertises to [put nails and sells herba life shakes to the public. Within the location lwere she does the procedure to put Inails there no certificate from the state that allows her to do that Iservice, the tools she uses are not Iterilizes because Ihave witness it [She also sells shakes, she blends {hem there she serves them there land charges $$ for that service. The location its self does not the the room tempature and does not have ihe proper equipment to keep it isantitary. She has no light installed, Ishe wired a cable to other busy lacross (zumba class) and the wire is very visable. She has no certificate on the wall that shows lanything for food handler, because Ihere is times were food is sold there. This may not be important Ibuy she has no documents is he lwith a traveling passaport, pays no taxes. To a future citizen she needs Ihe law applied and owes her dues {to paying taxes in the state, Her business has been running for lalmost one lyear Product_Or Service: Nails, |Herba Life Shakes — Additional ‘Comments: DesiredSettiementiD: (Other (requires explanation)To Ihave the location to which [OXI] jas been renting feom |Plaza Kora LLC shut down. (Complaint Info CRA Dispute Flag (Complaint Info CRA Dispute Responded (Complaint Info CRA Dispute[Resolved ! —___| (Complaint Info Fair Resolution Flag [No (Complaint Info Fair Resolution INVALID. The consumer complaint is incomplete or unintelligble and ithe consumer cannot be reached, or Peseiipton Ihe consumer and the business did Inot have a marketplace transaction. [Record 67 of 102 [Reference Number [49703333 (Croated Date losarzors [Complaint Source [BBB CA San Jose [Originator Reference Number [1216002021389 [Language [English (Contact Type [Compiaint [Data Source [Organization oNc? IN [Entered By |BBBSANCA-USER [Entered Date josi14/2013 (Updated 8 (Updated Date [Agency Contact [Extemal Agency [Complaint Date (osii472013 [Transaction Date [Member of armed forces or (dependant? (Consumer First Name [o(6) [Consumer Middle Name [Consumer Last Name [o(6) [Consumer Salutation [Consumer Address, Line 1 io) [Consumer Address, Line 2 (Consumer Address, Line 3 | (Consumer Address, City BROOKLYN [Consumer Address, State Code _|NY (Consumer Address, State Name _ |New York (Consumer Address, Country Code _|USA (Consumer Address, Country Name |UNITED STATES (Consumer Address, ZIP Code __|b(6) (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code|Consumer Home Phone, Area (Code [Consumer Home Phone, Number (Consumer Work Phone, Country (Code [Consumer Work Phone, Area Code (Consumer Work Phone, Number ove) [D(6) (Consumer Work Phone, Extension (Consumer Fax Country Code (Consumer Fax, Area Code [Consumer Fax, Number (Consumer Cell Phone, Country (Code (Consumer Cell Phone, Area Code (Consumer Cell Phone, Number (Consumer Email ove) (Consumer Age range (Consumer Miltary Status [Consumer Military Station (Consumer Complaining \CompanylOrg [Consumer Military Service Branch (Consumer Consent for volunteer \group contact? [Herbalife Intemational of America, (Company Name re [Company Address, Line 1 [800 W Olympic Bivd Ste 406 [Company Address, Line 2 [Company Address, Line 3 [Company Address, City Los ANGELES ] [Company Address, State Code CA ] |Company Address, StateName _|California (Company Address, County Code _|USA (Company Address, County Name_|UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code (Company Phone, Area Code [a10 (Company Phone, Number [4109600 (Company Phone, Extension (Company Email (Company Website [nttp:www.herbalife.com[Company Subject ID Type Code | I (Company Subject ID Type Name. (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name [Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint info initial Contact [Method [Complaint Info initial Contact Date (Complaint Info Initial Response [Method (Complaint info initial Response Date (Complaint Info Amount Requested [Method (Complaint Info Amount Requested \Value (Complaint Info Amount Paid [Method (Complaint Info Amount Paid Value (Complaint Info Product Service (Code jo304 (Complaint Info Product Service [Description [Multi-Level Mkig\Pyramids\Chain [Letters [Complaint Info Law Violation Code [Complaint Info Law Violation [Description [Complaint Info Statute Code [Complaint Info Statute Description [Complaint Info Topic Code (Complaint Info Topic Description [A few months ago, | received a lletter and ID card saying that | am |now a distributor for Herbalife. [Having not at all heard of Herbalife Inor signed up to be a distributor, \disregarded the letter. About a(Complaint Info Comments |month later, Iwas delivered 7 large Iboxes of Herbalife through Fed&x to my address. The name laddressed on the box is extremely iclose to mine in spelling. tuned Ihe delivery woman away with the 7. large boxes of supplements since | [placed no such order. When I called [Herbalife, Iwas told that that was Inot the frst order placed to my laddress. and that more were to lcome. | related my issue to the Imanager| fo whom | spoke jwith, and demanded to be given the Iname of the ‘sponsor’ who hired me las distributor. However, even with Imy pressing suspicion of identity theft, they would not provide me |with means to contact this sponsor. [They did say they would notify this Isponsor that l was trying to geta Ihold of hinvher. Weeks later, |have lyet to receive contact from this {sponsor of mine. Ihave strong reason to believe that Herbalife's lemployment policies involve fraudulent processes and their lack lof assistance in this issue leads me {to believe that their business. lpractices are dishonest, Due to their| lack of investigation in this matter, | Ihave also taken measures to report {them to FTC and local police. — [Additional Comments: [DesiredSettlementiD: Other (requires explanation)Herbalife Ineeds to conduct a thorough linvestigation on:- Who this ‘sponsor’ jis - How he stole my information - |What other information about me he_ Ihas.- Remove me from their lsystem Also: revise their lemployment policies to prevent lother similar situations from Ihappening as reviewed and lapproved by a licensed lawyer. [Herbalife needs to provide levidence of investigation and Ichanges or be subject to pressed icharges. (Complaint Info CRA Dispute Flag (Complaint Info CRA Dispute Responded|Complaint Info CRA Dispute [Resolved [Complaint Info Fair Resolution Flag [Yes |ADMINISTRATIVELY CLOSED. (Complaint Info Fair Resolution _| The response from the business [Description laddresses the complaint to the [BBB's satisfaction, [Record 68 of 102 Reference Number jag703334 (Created Date fosnigr2013 [Complaint Source [BBB CA San Jose [Originator Reference Number [1216002004367 [Language [English (Contact Type [Compiaint [Data Source [Organization ONC? iN [Entered By |BBBSANCA-USER [Entered Date jov/1872013 (Updated 8 (Updated Date [Agency Contact [Extemal Agency [Complaint Date (os/i8r2013 [Transaction Date [Member of armed forces or dependant? (Consumer First Name [o(6) [Consumer Middle Name [Consumer Last Name [o(6) [Consumer Salutation [Consumer Address, Line 1 io) [Consumer Address, Line 2 (Consumer Address, Line 3 | (Consumer Address, City IRISING SUN [Consumer Address, State Code _|MD (Consumer Address, State Name [Maryland (Consumer Address, Country Code_|USA (Consumer Address, Country Name |UNITED STATES (Consumer Address, ZIP Code __|b(6) (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code|Consumer Home Phone, Area (Code [Consumer Home Phone, Number (Consumer Work Phone, Country (Code [Consumer Work Phone, Area Code (Consumer Work Phone, Number (Consumer Work Phone, Extension (Consumer Fax, Country Code (Consumer Fax. Area Code [Consumer Fax, Number (Consumer Cell Phone, Country (Code (Consumer Cell Phone, Area Code (Consumer Cell Phone, Number (Consumer Email ove) (Consumer Age range (Consumer Miltary Status [Consumer Military Station (Consumer Complaining \CompanylOrg [Consumer Military Service Branch (Consumer Consent for volunteer \group contact? [Herbalife Intemational of America, (Company Name re [Company Address, Line 1 [800 W Olympic Bivd Ste 406 [Company Address, Line 2 [Company Address, Line 3 [Company Address, City Los ANGELES ] [Company Address, State Code CA ] |Company Address, StateName _|California (Company Address, County Code _|USA (Company Address, County Name_|UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code (Company Phone, Area Code [a10 (Company Phone, Number [4109600 (Company Phone, Extension (Company Email (Company Website [nttp:www.herbalife.com[Company Subject ID Type Code | I (Company Subject ID Type Name. (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name [Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint info initial Contact [Method [Complaint nfo initial Contact Date (Complaint Info Initial Response [Method (Complaint info initial Response Date (Complaint Info Amount Requested [Method (Complaint Info Amount Requested \Value (Complaint Info Amount Paid [Method (Complaint Info Amount Paid Value (Complaint Info Product Service (Code jo304 (Complaint Info Product Service [Description [Multi-Level Mkig\Pyramids\Chain [Letters [Complaint Info Law Violation Code (Complaint info Law Violation [Description [Complaint Info Statute Code [Complaint Info Statute Description [Complaint Info Topic Code (Complaint Info Topic Description [Purchased product that had cocoa [powder in it unknowingly, do not land can not consume products with \cocoa powder.Purchased product jwith cocoa powder in it lunknowingly. Caffeine or any cocoa |(Complaint info Comments related products make me sick [Been trying to see if | could get |refund or exchange. When | call | \get transferred around and lultimately get hung up on. — Additional Comments: | would like jeither product refunded or lexchanged for another produc. (Complaint info CRA Dispute Flag [Complaint info CRA Dispute [Responded [Complaint Info CRA Dispute Resolved [Complaint Info Fair Resolution Flag Yes (Complaint Info Fair Resolution [Description [ASSUMED RESOLVED. The [business addressed the issue, but ithe consumer has not verified with ithe BBB that the complaint is isettled nor requested additional [BBB assistance [Record 69 of 102 Reference Number jag703336 (Created Date lorraer2013 (Complaint Source [BBB CA San Jose (Originator Reference Number __ [1216020030782 [Language [English [Contact Type |Complaint [Data Source [Organization DNc?S™~SCS [Entered By BB [Entered Date lo7ra6r2013 (Updated B: (Updated Date [Agency Contact [Extemal Agency [Complaint Date (o7i262013 {Transaction Date [Member of armed forces or dependant? (Consumer First Name iov6) (Consumer Middle Name (Consumer Last Name iov6) (Consumer Salutation (Consumer Address, Line 1 io(6) [b(6)[Consumer Address, Line 3 —___| (Consumer Address, City INORTH HILLS (Consumer Address, State Code CA (Consumer Address, State Name _|(Califomia (Consumer Address, Country Code [USA (Consumer Address, Country Name [UNITED STATES [Consumer Address, ZIP Code [D(6) (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code (Consumer Home Phone, Area (Code (6) (Consumer Home Phone, Number [n(6) (Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code [n(6) (Consumer Work Phone, Number [0(6) (Consumer Work Phone, Extension [Consumer Fax, Country Code [Consumer Fax, Area Code: [Consumer Fax, Number [Consumer Cell Phone, Country (Code (Consumer Cell Phone, Area Code: [Consumer Cell Phone, Number (Consumer Emall [p(6) [Consumer Age range [Consumer Military Status ‘Consumer Military Station (Consumer Complaining \CompanylOrg (Consumer Military Service Branch (Consumer Consent for volunteer youp contact? (Company Name [Herbalife Intemational of America, Inc. (Company Address, Line 1 [00 W Olympic Blvd Ste 406 Company Address, Line 2 (Company Address, Line 3 (Company Address, City [LOS ANGELES (Company Address, State Code [CA (Company Address, State Name __|(Califomia[Company Address, County Code_| usa (Company Address, County Name [UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code (Company Phone, Area Code [sto (Company Phone, Number [a109600 (Company Phone, Extension (Company Email (Company Web: [nttp:www.herbalife.com (Company Subject ID Type Code 1y Subj vl [Company Subject ID Type Name (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name (Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments [Complaint Info initial Contact, [Method [Complaint info nial Contact Date (Complaint Info Initial Response [Method (Complaint Info Initial Response (Date (Complaint Info Amount Requested [Method [Complaint Info Amount Requested \Value (Complaint Info Amount Paid [Method (Complaint Info Amount Paid Value [$80.00 (Complaint Info Product Service (Code jo304 (Complaint Info Product Service [Multi-Level Mkig\Pyramids\Chain [Description [Letters (Complaint Info Law Violation Code [(Complaint Info Law Violation Description [Complaintinie Staite Code [Complaint Info Statute Description [Complaint info Topic Code | [Complaint Info Topic Description (Complaint info Comments I contacted Herbalife regarding their {30 day money gurantee promise on fall products. | purchased 3 bottles of] [Herbalife supplements from one of Itheir Herbalife distributors: (50 6:25/13 after seeing no Iresulis from the Herbalife tea and Ishakes she was selling to me daily for $5.00 each, she strongly recommended I purchase 1 month Isupply (1 bottle of each) of the following Herbalife dietary ‘supplements: CELL ACTIVATOR, [CELL U LOSS, and MULTI IVITAMINA. She said taking these [products will gurantee I lose the |weight | wasn't losing from the {Herbalife tea and shake. She sold Ime all 3 botties for $80.00 As lpreviously mentioned I was buying ishakes from her daily everyday for jweeks before buying the pills and Icash was the only form of payment las she has no cash register or system in place at her place lof business used to sell Herbalife jproducts. I never received a receipt for any purchases, shakes or pills. When | returned the bottles to my {distributor requesting my money Iback on 7/18/13 because | had lost ino weight and products were no 'g004, she said could not refund me Ibecause | had used the products. | told her Ineed a copy of the receipt Iso | could contact Herbalife directly labout their 30 day money back Igurantee. She said she ran out of [receipt paper and could not give me lone. | contacted Herbalife same day 17/18/13 via email regarding the issue | was having getting my Iefund from distributor. Herbalite refunds dept Marquita Mclaren lemailed me back with all necessary (documents I needed to send herlback within 5 days to process my Irefund. | since have left her lcountiess voice messages and lemails without any reply back. | Isent all documents via fax to her for Imy refund on 7/22/13 (copy of fax {confirmation can be provided) | Ihave yet heard back from anyone. [Leading to believe this company is, fa pyramid scam and the company is, lavoiding my calls/emails. | want my full refund as im within my rights to lask for one as I'm within the lcompanys 30 Day Money Back \Gurantee lpromise.Product_Or_Service: {Herbalife dietary supplements (3 jbotties) —- Additional Comments: [DesiredSettlementiD: RefundFull f $80.00 paid - Herbalife distributor. Paid (on: 06/25/13 Refund request made: joznants [Complaint I [Complaint info CRA Dispute [Responded [Complaint Info CRA Dispute [Resolved [Complaint Info Fair Resolution Flag Yes [ASSUMED RESOLVED. The [business addressed the issue, but (Complaint info Fair Resolution {the consumer has not verified with [Description the BBB that the complaint is settled nor requested additional [BBB assistance [Record 70 of 102 ] [Reference Number jag703779 (Created Date |froioai2013, ] [Originator Reference Number [1260020047257 ] [Language [English (Contact Type (Complaint | (Data Source Organization |) DNC? In [Entered By |BBBSANCA-USER Entered Date frov04/2013 ] Updated By |[Updated Date | [Agency Contact [Extemal Agency (Complaint Date fioio4i2013 [Transaction Date [Member of armed forces or dependant? (Consumer First Name inv6) (Consumer Middle Name [Consumer Last Name lie) (Consumer Salutation [Consumer Address, Line 1 [n(6) |Consumer Address, Line 2 [Consumer Address, Line 3 [Consumer Address, City WENATCHEE WA [Consumer Address, State Code _ WA |Consumer Address, State Name _ Washington (Consumer Address, Country Code _|USA [Consumer Address, Country Name. [UNITED STATES [Consumer Address, ZIP Code b6) (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country [Code (Consumer Home Phone, Area (Code [Consumer Home Phone, Number (Consumer Work Phone, Country (Code [Consumer Work Phone, Area Code [b(6) (Consumer Work Phone, Number _[b(6) (Consumer Work Phone, Extension |Consumer Fax, Country Code (Consumer Fax, Area Code [Consumer Fax, Number (Consumer Cell Phone, Country (Code (Consumer Cell Phone, Area Code (Consumer Cell Phone, Number [Consumer Email (p(6) (Consumer Age range (Consumer Miltary Status (Consumer Military Station [Consumer Complaining[CompanylOrg es (Consumer Military Service Branch (Consumer Consent for volunteer yroup contact? ee Herbalife nemetonal ofAmeria, [Company Address, Line 1 [800 W Olympic Bivd Ste 406 (Company Address, Line 2 (Company Address, Line 3 (Company Address, City [LOS ANGELES [Company Address, State Code _|CA (Company Address, State Name _|Califomia (Company Address, County Code _|USA (Company Address, County Name_|UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code |Company Phone, Area Code [310 | |Compeny Phone, Number [4108600 | [Company Phone, Extension [Company Email (Company Website Iitp:imww.herbalife.com (Company Subject ID Type Code [Company Subject ID Type Name (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name. (Company Subject ID Issuing [Country Code (Company Subject ID Issuing (Country Name [Company Rep First Name (Company Rep Middle Name (Company Rep Last Name [Company Rep Salutation (Company Rep Comments (Complaint info Initial Contact [Method [Complaint Info Initial Contact Date (Complaint nfo initial Response [Method (Complaint Info Initial Response\Date (Complaint info Amount Requested ‘Method (Complaint Info Amount Requested Value [Complaint info Amount Paid [Method (Complaint info Amount Paid Value (Complaint Info Product Service (Code jo304 \Complaint Info Product Service [Description [Multi-Level Mktg\Pyramids\Chain Letters (Complaint info Law Violation Code (Complaint Info Law Violation [Description [Complaint info Statute Code [Complaint info Statute Description [Complaint info Topic Code (Complaint Info Topic Description (Complaint Info Comments Ihave asked numerous times to not ibe called by this number: 503-849- '5865 regarding Metabolife. | |wamed them that | would contact, lyou to stop this and nothing has Ihelped. Ido not know ifitis a legit Ibusiness or not but | do not need to Ibe harassed 15x throughout the day, land night! — Additional Comments: [DesiredSettiementiD: Other (requires explanation)To not be [called ever again and for them to be investigated to see if this number Ishould even be harassing people. [Complaint Info CRA Dispute Flag [Complaint Info CRA Dispute Responded (Complaint Info CRA Dispute [Resolved [Complaint Info Fair Resolution Flag [No |Complaint Info Fair Resolution [Description INVALID. The consumer complaint is incomplete or unintelligble and ithe consumer cannot be reached, o {he consumer and the business did inot have a marketplace transaction. [Record 71 of 102 — | [Reference Number [49703783\Cteated Date {to/1072013 (Complaint Source BBB CA San Jose iota Reterence '12160020048571 ‘Language English (Contact Type (Complaint [Data Source (Organization DNC? N [Entered By BBBSANCA-USER [Entered Date ho102013 [Updated By [Updated Date [Agency Contact [Extemal Agency [Complaint Date [10/10/2013 Transaction Date [Member of armed forces or dependant? [Consumer First Name io(6) [Con me (Consumer LastName |b(6) (Consumer Salutation (Consumer Address Line 1 b(6) [Consumer Address, Line 2 |b(6) (Consumer Address Line 3 [Consumer Address, City _ [TAMPA |Consumer Address, State [Code |Consumer Address, State Name Coumy cose (USA FL Florida (Consumer Address, IGoinhy Name UNITED STATES (Consumer Address, ZIP (Code (Consumer Address, ZIP [Code Extension (Consumer Home Phone, (Country Code (Consumer Home Phone, \Area Code (Consumer Home Phone, Number [Consumer Work Phone, (6)[Country Code J [Consumer Work Phone, [Area Code: pel (Consumer Work Phone, Number [Consumer Work Phone, [Extension (Consumer Fax, Country (Code (Consumer Fax, Area Code J [Consumer Fax, Number (Consumer Cell Phone, (Country Code (Consumer Cell Phone, \Area Code (Consumer Cell Phone, Number [Consumer Email b(6) (Consumer Age range (Consumer Miltary Status (Consumer Military Station (Consumer Complaining (CompanylOrg (Consumer Military Service Branch (Consumer Consent for volunteer group contact? [Company Name Herbalife Intemational of America, Inc. (Company Address, Line 1 [800 W Olympic Blvd Ste 406 (Company Address, Line 2 (Company Address, Line 3 [Company Address, City __|LOS ANGELES (Company Address, State Code ica (Company Address, State Name (Company Address, County (Code USA. (Company Address, County cone UNITED STATES (Company Address, ZIP (Code (Company Address, ZIP (Code Extension [Company Phone, Country (6) (California[Code I | [Company Phone, Area eee 310 (Company Phone, Number 4109600 (Company Phone, Extension] (Company Email (Company Website iiip:IAwww herbalife com ‘Company Subject ID Type (Code (Company Subject ID Type Name (Company Subject ID Issuing State Code (Company Subject ID Issuing State Name (Company Subject ID Issuing Country Code (Company Subject ID Issuing Country Name (Company Rep First Name (Company Rep Middle Name [Company Rep Last Name [Company Rep Salutation [Company Rep Comments (Complaint info initial [Contact Method (Complaint Info Initial (Contact Date (Complaint Info initial Response Method (Complaint Info Initial [Response Date (Complaint Info Amount [Requested Method (Complaint Info Amount Requested Value [Complaint Info Amount Paid] ‘Method [Complaint Info Amount Paid] ‘Value (Complaint Info Product ‘Service Code (Complaint Info Product ‘Service Description (Complaint Info Law (0304 ‘Multi-Level Mktg\Pyramids\Chain Letters[Violation Code fd [Complaint Info Law \Violation Description (Complaint Info Statute (Code (Complaint Info Statute [Description [Complaint nfo Topic Code (Complaint info Topic [Description (Complaint Info Comments Tonered my prosusieTOeTZ WOS ago |have yet to receive them. On the web page itclearly states product will be delivered the following day... 's day 10 still Ihave. Fothing. otd ating ana got he compary voice mal bu never recelve a cal fel" Inave been scammers want my yack. ..Order_Number: ORDER ID : Additional Comments: [DesiredSettlementiD: Refund! still have not Irecy lease call }600To: eon |support@herbalproductshop.comSubject: i Contireton Dear f=] ‘his is confirmation of your payment to Herbal Product Shop. (support@herbalproductshop.com) ORDER | JaMOUNT: 34 S00RDER ID ROER DATE: 1 October 2013 Frou have questions about tis ovr, lease respond directly to this email or click on the link b (Complaint Info CRA [Dispute Flag ‘Complaint info CRA (Dispute Responded (Complaint Info CRA Dispute Resolved (Complaint Info Fair [Resolution Flag Yes (Complaint Info Fair [Resolution Description [ASSUMED RESOLVED. The business addressed the issue, but the consumer has inot verified with the BBB that the complaint is settied nor requested additional BBB assistance. [Record 72 of 102 J [Reference Number [49703877|Created Date \o3i18/2013 (Complaint Source [BBB CA San Jose [Originator Reference Number [1216002000811 [Language [English (Contact Type (Complaint [Data Source (Organization DNC? IN [Entered By [BBBSANCA-USER Entered Date josi1g/2013 [Updated By (Updated Date [Agency Contact [Extemal Agency [Complaint Date foav1e/2013 [Transaction Date [Member of armed forces or dependant? (Consumer First Name ine) (Consumer Middle Name [Consumer Last Name love) (Consumer Salutation (Consumer Address, Line + io(6) (Consumer Address, Line 2 (Consumer Address, Line 3 (Consumer Address, City [LEANDER |Consumer Address, State Code __|TX (Consumer Address, State Name [Texas |Consumer Address, Country Code [USA (Consumer Address, Country Name |UNITED STATES (Consumer Address, ZIP Code _[b(6) [Consumer Adaress ZIP Code [Extension [Consumer Home Phone, County [Code [Consumer Home Phone, Area S ns bce) [Consumer Home Phone, Number —[b(@) (Consumer Work Phone, Country (Code [Consumer Work Phone, Area Code ioe) [Consumer Work Phone, Number ioe) (Consumer Work Phone, Extension (Consumer Fax, Country Code (Consumer Fax, Area Code(Consumer Fax, Number (Consumer Cell Phone, Country (Code (Consumer Gell Phone, Area Code (Consumer Cell Phone, Number [Consumer Email (p(6) (Consumer Age range (Consumer Miltary Status [Consumer Military Station (Consumer Complaining (CompanylOrg [Consumer Mitary Service Branch [Consumer Consent for volunteer \group contact? [Herbalife Intemational of America, (Company Name bo [Company Address, Line 1 [800 W Olympic Bivd Ste 406 [Company Address, Line 2 LL ~+ (Company Address, Line 3 (Company Address, City [LOS ANGELES (Company Address, State Code __|CA (Company Address, State Name _|Califomia (Company Address, County Code _|USA (Company Address, County Name [UNITED STATES [Company Address, ZIP Code ] (Company Address, ZIP Code [Extension (Company Phone, Country Code ] (Company Phone, Area Code s10 ] (Company Phone, Number (4109600 [Company Phone, Extension (Company Email (Company Website [nttp:/www.herbalife.com [Company Subject ID Type Code [Company Subject Type Name (Company Subject ID Issuing State [Code (Company Subject ID Issuing State Name (Company Subject ID Issuing \Country Code (Company Subject ID Issuing (Country Name[Company Rep First Name —___| [Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint ino initial Contact [Method [Complaint Info Initial Contact Date (Complaint Info Initial Response [Method (Complaint Info Initial Response [Date (Complaint info Amount Requested (Method (Complaint Info Amount Requested Value (Complaint Info Amount Paid [Method (Complaint Info Amount Paid Value [$199.95 (Complaint Info Product Service (Code jo304 (Complaint Info Product Service [Description [Multi-Level Mkig\Pyramids\Chain [Letters [Complaint nfo Law Violation Code (Complaint Info Law Violation (Description (Complaint Info Statute Code [Complaint Info Statute Description [Complaint Info Topic Code (Complaint Info Topic Description [around October 14, 2012, l inquired to the website Work-At-Home.com. [On October 18, 2012, lwas |contacted by Paul Housch about this company. After receiving 2 training packages in less than a lweek fora possible sales position lon-iine, | thought, and after careful \determination, | realized that | did Inot want to purchase or become @ Isales person for Herbalife, also known as 'work-at-home.com’. This is the cover name they use for Herbalife. Imade it known to Paul 'Housh, my so-called point of (contact and distributor, and also known to me as my Mentor from {Herbalif, that no longer wanted to(Complaint Info Comments |continue with the program. At that time | was instructed to retum the training packages that were sent to Ime in the mail. followed his instructions and retumed both to the respective addresses he gave me lon the 19th of October and was told {hat | would have a refund within [30-60 days. Two months went by land | neither heard or received lanything from Paul Housch or a refund from Herbalife | then started icontacting by email and phone labout once every two weeks and {got the run around about you need {to send this email or you need to Ill this person, but needless to Isay, 6 months later, no results lexcept for one email from the [Herbalife company stating they jwere going to return 25% of what | [paid to them. After that email, Paul 'sent me a follow-up email for me to Isend him my name and address so Ihat he could send me a check to reimburse me the full 100% of what I paid to get into the company. Then lanother 2 weeks went by and still Inothing. | feel the Better Business [Bureau is my last resort to try to get reimbursed for my monies Iwas icheated out of and some |compensation for the aggravation | Ihave gone through with this scam Icompany for the past 6 months! IPlease help in any way that you ‘can to expose this business, so that Ino one else can be affected the way, Iwas, Thank lyoulroduct_Or_Service: Work \From Home Training Package (1 of !2)Order_Number: Transaction ID |= Additional Comments: [DesiredSettlementiD: 'Refund$220.00 reimbursement Icheck for two training packages that) jwere retumed to ‘Herbalife’. One [package was for $200 and the other, |was $20. (Complaint Info CRA Dispute Flag (Complaint Info CRA Dispute Responded [Complaint Info CRA Dispute[Resolved | I [Complaint Info Fair Resolution Flag les (Complaint Info Fair Resolution [Description RESOLVED. The consumer has \verified that the complaint has been [settled to his/her satisfaction. [Record 73 of 102 |Reference Number [49703878 (Created Date foari5r2013 (Complaint Source [BBB CA San Jose [Originator Reference Number [1216002000761 [Language [English (Contact Type [Complaint ] [Data Source [Organization J onc? In’ | [Entered By BBBSANCA-USER [Entered Date foannsr2013 (Updated By (Code (Updated Date [Agency Contact |External Agency [Complaint Date loartsr2013 Transaction Date [Member of armed forces or (dependant? (Consumer First Name in(6) (Consumer Middle Name (Consumer Last Name be) (Consumer Salutation ‘Consumer Address, Line 1 lo) ] (Consumer Address, Line 2 J (Consumer Address, Line 3 | (Consumer Address, City [LELAND (Consumer Address, State Code __ [NC (Consumer Address, State Name _[North Carolina [Consumer Address, Country Code [USA [Consumer Address, Country Name |UNITED STATES [Consumer Address, ZIP Code __[b(6) (Consumer Address, ZIP Code [Extension ‘Consumer Home Phone, Country (Code [Consumer Home Phone, Area faig)[Consumer Home Phone, Number |b (Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code [b(6) (Consumer Work Phone, Number ioe) (Consumer Work Phone, Extension (Consumer Fax, Country Code (Consumer Fax, Area Code (Consumer Fax, Number (Consumer Cell Phone, Country (Code (Consumer Cell Phone, Area Code [Consumer Gell Phone, Number [Consumer Email ove) (Consumer Age range (Consumer Military Status [Consumer Military Station (Consumer Complaining (CompanylOrg [Consumer Military Service Branch [Consumer Consent for volunteer \group contact? (Company Name. [Herbalife Intemational of America, inc. (Company Address, Line 1 [a0 W Olympic Bivd Ste 406 [Company Address, Line 2 (Company Address, Line 3 (Company Address, City [LOS ANGELES (Company Address, State Code _|CA (Company Address, State Name _|Califomia (Company Address, County Code _|USA |Company Address, Country Name [UNITED STATES. (Company Address, ZIP Code (Company Address, ZIP Code [Extension [Company Phone, Country Code (Company Phone, Area Code [310 (Company Phone, Number [4109600 [Company Phone, Extension (Company Email (Company Website [ntipzwww.herbalife.com (Company Subject ID Type Code [Company Subject ID Type Name.(Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing \Country Code (Company Subject ID Issuing (Country Name [Company Rep First Name [Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments | [Complaint info initial Contact, ‘Method [Complaint Info Initial Contact Date (Complaint info Initial Response [Method (Complaint Info Initial Response [Date (Complaint Info Amount Requested [Method (Complaint Info Amount Requested \Value (Complaint Info Amount Paid [Method (Complaint Info Amount Paid Value_| (Complaint Info Product Service (Code [Complaint Info Product Service [Description [$399.00 j0304 [Multi-Level Mkig)Pyramids\Chain Letters J [Complaint Info Law Violation Code | [Complaint Info Law Violation [Description (Complaint Info Statute Code (Complaint Info Statute Description [Complaint info Topic Code (Complaint Info Topic Description (Complaint info Comments II WAS TOLD THAT IF | WAS NOT |SATIFIED THAT MY MONEY WOULD BE REFUNDED , | PAID THEM $399.00 | SENT MY REFUND REQUEST BEFORE |THE 90 DAYS ,THAT WAS IN |FEBUARY, IHAVE HEARD INOTHING FROM THEM. ALLI(Complaint Info CRA Dispute Flag WANT IS MY MONEY BACK. THANK YOU — Additional |Comments: DesiredSettiomentiD: |Refund$399.00 AND THE $49.95 [Complaint Info CRA Dispute [Responded (Complaint Info CRA Dispute [Resolved (Complaint Info Fair Resolution Flag) les (Complaint Info Fair Resolution [Description [Record 74 of 102 [ASSUMED RESOLVED. The lbusiness addressed the issue, but ithe consumer has not verified with {the BBB that the complaint is settled nor requested additional |BBB assistance. [Reference Number [49768200 (Created Date in12672013 (Complaint Source [Federal Trade Commission (Originator Reference Number [Language [English [Contact Type |Complaint | [Data Source (Consumer DNc? IN (Entered By ISTAYLORROBINS ] [Entered Date [11/26/2013 I (Updated By URUANO [Updated Date [12/02/2013 | (Agency Contact Phone ] [Complaint Date fra02/2013 | Transaction Date [Member of armed forces or IN (dependant? (Consumer First Name ioe) (Consumer Middle Name [Consumer Last Name [b(6) J (Consumer Salutation [Consumer Address, Line 1 lb6) | (Consumer Address, Line 2 inv6) (Consumer Address, Line 3 (Consumer Address, City [Cudahy J (Consumer Address, State Code __|CA J[Consumer Address, State Name |jcatitornia (Consumer Address, Country Code USA (Consumer Address, County Name |UNITED STATES (Consumer Address, ZIP Code __|b(6) (Consumer Address, ZIP Code jg [Extension (Consumer Home Phone, Country (Code. (Consumer Home Phone, Area oe ib) (Consumer Home Phone, Number __|b(6) (Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code | (Consumer Work Phone, Number [Consumer Work Pt Exter (Consumer Fax, Country Code [Consumer Fax, Area Code [o(6) (Consumer Fax. Number [n(6) (Consumer Cell Phone, Country (Code (Consumer Gell Phone, Area Code [Consumer Cell Phone, Number [Consumer Email (Consumer Age range [Consumer Military Status (Consumer Military Station (Consumer Complaining |Company/Org (City of Cudahy California [Consumer Military Service Branch [Consumer Consent for volunteer {group contact? [Company Name [Herbalife [Company Address, Line 1 [Company Address, Line 2 (Company Address, Line 3 (Company Address, City (Company Address, State Code (Company Address, State Name (Company Address, County Code [usa (Company Address, County Name [UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code[Extension ___| (Company Phone, Country Code (Company Phone, Area Code (Company Phone, Number (Company Phone, Extension (Company Email (Company Website (Company Subject ID Type Code (Company Subject ID Type Name (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name (Company Rep First Name (Company Rep Middle Name [Company Rep Last Name. (Company Rep Salutation [Company Rep Comments (Complaint Info Initial Contact, [Method |Unknown (Complaint nfo Initial Contact Date (Complaint Info Initial Response [Method |Unknown (Complaint Info Initial Response [Date (Complaint Info Amount Requested [Method (Complaint Info Amount Requested \Value '$0.00 (Complaint Info Amount Paid [Method |Unknown (Complaint Info Amount Paid Value [$0.00 (Complaint Info Product Service (Code jo304 (Complaint Info Product Service [Description Multi-Level Mkig\Pyramids\Chain Letters [Complaint info Law Violation Code [ppm (Complaint Info Law Violation [Description [Deception/Misrepresentation (Complaint Info Statute Code iP (Complaint Info Statute Description IFTC Act Sec 5 (BCP)[Complaint Info Topic Code [Complaint info Topic Description [CMS# 14009110: MAIL 11/26/2013: [The consumer is writing on behalf lofthe nearly 23,000 Latino iesidents of Cudahy, Ca. reiterating {heir earlier request to investigate |Herbalife. There have been lalarming reports recently that highlight Herbalife's practices and |suggest that they may in fact {coincide with a pyramid scheme. [Furthermore, Herbalife unfairly targets ethnic minorities; 'specifically the Latino community Iho are Spanish speaking, have lite to no education and have no lability to assess risk management, [The majority demographics in the lconsumer’s community are Latino land they have a high concentration lofimmigrants, consequently, this is Inot the first time that we have Ispoken out against Herbalife. On (October 18, the consumer joined a {coalition of several Latino, lcommunity and faith-based lorganizations to speak out about ithe damage Herbalife is having on their families. The consumer is Isupported by national organizations lsuch MANA, National Consumers [League (NCL), ... Just last year, [Herbalife reported net sales of more | than $4 billion and a net income of '$477.19 million. 99 per cent of {Herbalife distributors barely make a living wage and have had no voice land no protection from the law .CMS#14009168 UPDATE 12/02/2013 MAIL:Consumer sent in ladditional material regarding the |compiaint against Herbalife (Complaint Info Comments JRUANO (Complaint info CRA Dispute Flag (Complaint Info CRA Dispute Iv [Responded [Complaint info CRA Dispute Iw Resolved [Complaint Info Fair Resolution Flag (Complaint Info Fair Resolution Description[Record 75 of 102 [Reference Number [49768235 (Created Date [11/26/2013 | (Complaint Source [Federal Trade Commission [Originator Reference Number [Language [English (Contact Type [Complaint (Data Source |Consumer |DNC? IN [Entered By [STAYLORROBINS [Entered Date fr1/26/2013 [Updated By [STAYLORROBINS [Updated Date har2m013 \Agency Contact |Phone [Complaint Date henz2013 {Transaction Date [Member of armed forces or i dependant? (Consumer First Name ib(6) J (Consumer Middle Name (Consumer Last Name by (Consumer Salutation (Consumer Address, Line 4 iov6) [Consumer Address, Line 2 \p(6) [Consumer Address, Line 3 (Consumer Address, Ci [Los Angeles. [Consumer Address, State Code [ca |Consumer Address, State Name. [Califomia [Consumer Address, Country Code [usa [Consumer Address, Country Name UNITED STATES (Consumer Address, ZIP Code __[b(6) (Consumer Address, ZIP Code jg [Extension (Consumer Home Phone, Country [Cox (Consumer Home Phone, Area cede jp(6) [Consumer Home Phone, Number _[b(6) (Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code[Consumer Work Phone, Number —___| (Consumer Work Phone, Extension (Consumer Fax, Country Code (Consumer Fax, Area Code [n(6) (Consumer Fax, Number [D(6) (Consumer Gell Phone, Country (Code (Consumer Cell Phone, Area Code [Consumer Cell Phone, Number (Consumer Email [Consumer Age range [Consumer Military Status [Consumer Miltary Staton |Consumer Complaining (Company/Org \Congress of Racial Equality - CA (Consumes ilitary Service Branch (Consumer Consent for volunteer \group contact? (Company Name [Herbalife [Company Address, Line 1 [Company Address, Line 2 [Company Address, Line 3 |Company Address, City (Company Address, State Code [Company Adcress, Slate Name lusA (Company Address, County Code (Company Address, County Name [UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code (Company Phone, Area Code (Company Phone, Number (Company Phone. Extension (Company Email [Company Website (Company Subject ID Type Code [Company Subject ID Type Name (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name [Company Subject ID Issuing[Country Code —___| [Company Subject ID Issuing (Country Name. (Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint Info Initial Contact, (Method |Unknown [Complaint info Initial Contact Date (Complaint info Initial Response [Method jUnknown (Complaint nfo initial Response (Date (Complaint info Amount Requested [Method (Complaint Info Amount Requested Value {$0.00 (Complaint Info Amount Paid [Method |Unknown (Complaint Info Amount Paid Value [$0.00 (Complaint Info Product Service (Code jo304 (Complaint Info Product Service (Description [Multi-Level Mktg\Pyramids\Chain [Complaint info Law Violation Code [Complaint info Law Violation [Description [Complaint Info Statute Code [Complaint Info Statute Description [FTC Act Sec 5 (BCP) (Complaint Info Topic Code (Complaint Info Topic Description [CMs# 14009134: MAIL 11/26/2013 [The consumer's organization is |committed to protecting our Imembers and our community in Imany ways. One of these ways in {the pursuit of our mission to protect ithe litte person from the big person, Iwhich is why they are calling on the. [AG's Office with a request to initiate lan investigation of Herbalife. Itis jparticular concem that Herbalife loperates as a pyramid scheme, lunfairly targeting ethnic minorities. |Herbalife’s pyramid scheme is(Complaint Info Comments illegal, because members are lincentivized to recruit rather than {cell product, leaving those at the jbottom with no way to succeed Iselling the product. Herbalife lunfairly targets minorities and is in Violation of the 1986 injunction. The injunction requires Herbalife to \erfy retail sales and other {documentation to prove the lcompany's sales to distributors and icustomers. They are urging the 'Santa Cruz District Attomey to lenforce the 1986 injunction against {Herbalife and demand release of these records. CMS# 14009214: UPDATE: MAIL 12/09/2013: The Iconsumer sent in another copy of ithe Herbalife complaint. |SROBINSON (Complaint Info CRA Dispute Flag (Complaint Info CRA Dispute 5 [Responded (Complaint info CRA Dispute Li Resolved (Complaint info Fair Resolution Fi (Complaint info Fair Resolution [Description [Record 76 of 102 Reference Number j4768270 [Created Date [11/26/2013 (Complaint Source [Federal Trade Commission (Originator Reference Number |Language |English |Contact Type [Complaint [Data Source [Consumer DNC? IN [Entered By |STAYLORROBINS [Entered Date f1172672013 [Updated B [STAYLORROBINS [Updated Date [Agency Contact [Complaint Date [1209/2013 [Transaction Date |Member of armed forces or In \dependant?[Consumer First Name | |v (Consumer Middle Name (Consumer Last Name be) (Consumer Salutation (Consumer Address, Line 4 ioe) [Consumer Address, Line 2 [Consumer Address, Line 3 (Consumer Address, City [Lynwood (Consumer Address, State Code _|CA (Consumer Address, State Name _|Califomia [Consumer Address, Country Code _|USA [Consumer Address, Country Name [Consumer Address, ZIP Code [UNITED STATES io(6) (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code (Consumer Home Phone, Area (Code jb(6) [Consumer Home Phone, Number [p(6) (Consumer Work Phone, Country (Code [Consumer Work Phone, Area Code [Consumer Work Phone, Number [Consumer Work Phone, Extension (Consumer Fax, Country Code [Consumer Fax, Area Code [b(6), [Consumer Fax, Number [b(6) (Consumer Cell Phone, Country (Code [Consumer Gell Phone, Area Code |Consumer Cell Phone, Number (Consumer Email lo) [Consumer Age range (Consumer Miltary Status [Consumer Military Station (Consumer Complaining (CompanylOrg (city of Lynwood [Consumer Military Service Branch (Consumer Consent for volunteer youp contact? (Company Name [Herbalife J (Company Address, Line 1[Company Address, Line 2 —___| [Company Address, Line 3 (Company Address, City (Company Address, State Code (Company Address, State Name [Company Address, County Code [usa (Company Address, County Name [UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension [Company Phone, Country Code (Company Phone, Area Code [Company Phone, Number [Company Phone, Extension [Company Email |Company Website [Company Subject ID Type Code (Company Subject ID Type Name. (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing \Country Code (Company Subject ID Issuing (Country Name (Company Rep First Name [Company Rep Middle Name (Company Rep Last Name ompany Rep Saluta ompany Rep Comments (Complaint info Initial Contact [Method lUnknown [Complaint Info Initial Contact Date (Complaint nfo Initial Response [Method |Unknown (Complaint nfo initial Response Date (Complaint Info Amount Requested [Method (Complaint Info Amount Requested \Value '$0.00 [Complaint Info Amount Paid [Method |Unknown[Complaint info Amount P (Complaint Info Product Service [Code (Complaint Info Product Service [Description [Multi-Level Mkig\Pyramids\Chain [Letters (Complaint info Comments [Complaint Info Law Violation Code |DDM eect Law Violation |Deceptiontvisrepresentation [Complaint Info Statute Code IP [Complaint Info Statute Description FTC Act Sec 5 (BCP) ] (Complaint info Topic Code [Complaint Info Topic Description _| } [CMs# 14009135: MAIL 11/26/2013 [The consumer's organization is jwriting to request that the Attorney |General Office enforce the 1986 injunction against Herbalife that jwas initiated by the District |Attorney. Herbalife operates as a lpyramid scheme and unfairly targets ethnic minorities, ispecifically the Latino community. |Herbalife's pyramid scheme is legal, because members are jincentivized to recruit rather than sell product, leaving those at the ibottom with no way to succeed Iselling the product. Herbalife lunfairly targets minorities and is in Violation of the 1986 injunction. The. injunction requires Herbalife to Werify retail sales and other {documentation to prove the {company’s sales to distributors and jcustomers. They are urging the \Santa Cruz District Attorney to lenforce the 1986 injunction against [Herbalife and demand release of these records (Complaint Info CRA Dispute Flag (Complaint Info CRA Dispute [Responded IN [Complaint info CRA Dispute fy Resolved [Complaint Info Fair Resolution Flag [Complaint info Fair Resolution [Description [Record 77 of 102[Reterence Number \ lagaaz077, (Created Date frzi022013 (Complaint Source [Federal Trade Commission [Originator Reference Number [Language [English (Contact Type (Complaint (Data Source (Consumer DNC? IN [Entered By [SMORGANBAILEY [Entered Date fizio22013 [Updated By [SMORGANBAILEY. [Updated Date [12/04/2013 [Agency Contact [Phone [Complaint Date [12/04/2013 [Transaction Date [Member of armed forces or ly dependant? (Consumer First Name in(6) (Consumer Middle Name [b@) (Consumer Last Name inv6) (Consumer Salutation (Consumer Address, Line 1 by (Consumer Address, Line 2 (Consumer Address, Line 3 (Consumer Address. City [Los Angelos (Consumer Address, State Code __|CA [Consumer Address, State Name _ [California |Consumer Address, Country Code [USA [Consumer Address, Country Name |UNITED STATES [Consumer Address, ZIP Code __[b(6) (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code. (Consumer Home Phone, Area oe lb) [Consumer Home Phone, Number __|b(6) [Consumer Work Phone, Country (Code [Consumer Work Phone, Area Code [Consumer Work Phone, Number (Consumer Work Phone, Extension (Consumer Fax, Country Code[Consumer Fax, Area Code (Consumer Fax, Number (Consumer Cell Phone, Country [Code (Consumer Cell Phone, Area Code (Consumer Cell Phone, Number [Consumer Email (Consumer Age range [Consumer Military Status (Consumer Military Station (Consumer Complaining (CompanylOrg [Consumer Military Service Branch [True Way Missionary Baptist, [Church [Consumer Consent for volunteer (group contact? [Company Name (Company Address, Line 1 [Herbalife [Company Address, Line 2 (Company Address, Line 3 (Company Address, City (Company Address, State Code (Company Address, State Name (Company Address, County Code [usa [Company Address, County Name [UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension [Company Phone, Country Code _| (Company Phone, Area Code [Company Phone, Number [Company Phone, Extension [Company Email |Company Website [Company Subject ID Type Code (Company Subject ID Type Name (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code |Company Subject ID Issuing (Country Name[Company Rep First Name | Pd [Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint ino initial Contact [Method |Unknown [Complaint Info Initial Contact Date (Complaint Info Initial Response [Method |Unknown (Complaint Info Initial Response [Date (Code (Complaint nfo Amount Requested IMethod (Complaint info Amount Requested Value [0.00 [Complaint info Amount Paid porele lUnknown (Complaint info Amount Paid Value [60.00 [Complaintinfo Product Service |oyqy (Complaint Info Product Service [Description [Multi-Level Mkig\Pyramids\Chain [Letters [Complaint Info Law Violation Code [ODM (Complaint Info Law Violation scr [Description [Deception Misrepresentation [Complaint Info Statute Code re [Complaint Info Statute Description [FTC Act Sec 5 (BCP) [Complaint Info Topic Code (Complaint Info Topic Description (Complaint info Comments IMAIL: Consumer is writing on lbehalf of his church requesting that Ihe FTC investigate the deceptive ipractice of a mult-leveling Imarketing company - Herbalife. [Details are attached. (Complaint Info CRA Dispute Flag (Complaint Info CRA Dispute Responded [Complaint Info CRA Dispute [Resolved (Complaint Info Fair Resolution Flag] (Complaint Info Fair Resolution [Description [Record 78 of 102[Reference Number [49832093 |Created Date [r2102/2013 (Complaint Source [Federal Trade Commission (Originator Reference Number [Language [English (Contact Type [Complaint [Data Source (Consumer onc? In’ [Entered By SMORGANBAILEY [Entered Date fizio2i2013 (Updated By [SMORGANBAILEY [Updated Date [12/04/2013 [Agency Contact Phone [Complaint Date [12/04/2013 Transaction Date [Member of armed forces or 5 (dependant? |Consumer First Name lo(6) (Consumer Middle Name [Consumer Last Name io(6) (Consumer Salutation (Consumer Address, Line 1 b@) (Consumer Address, Line 2 in(6) [Consumer Address, Line 3 (Consumer Address, City [Los Angeles (Consumer Address, State Code __|CA (Consumer Address, State Name _|Califomia [Consumer Address, Country Code [USA [Consumer Address, Country Name |UNITED STATES |Consumer Address, ZIP Code I) (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code [Consumer Home Phone, Area Ley (Consumer Home Phone, Number _[b(6) |Consumer Work Phone, Country (Code [Consumer Work Phone, Area Code [Consumer Work Phone, Number [Consumer Work Phone, ExtensionConsumer Fax, Country Code _| [Consumer Fax, Area Code [Consumer Fax, Number (Consumer Cell Phone, Country (Code (Consumer Gell Phone, Area Code (Consumer Gell Phone, Number (Consumer Email (Consumer Age range (Consumer Military Status [Consumer Military Station (Consumer Complaining [Operation HOPE, The Giobal \CompanylOrg [Leader for Financial Dignity [Consumer Military Service Branch (Consumer Consent for volunteer youp contact? (Company Name [Herbalife (Company Address, Line 1 |Company Address, Line 2 | [Company Address, Line 3 | [Company Address, City [Company Address, State Code |Company Address, State Name (Company Address, County Code _|USA Company Address, Country Name [UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code [Company Phone, Area Code (Company Phone, Number (Company Phone, Extension [Company Email (Company Website (Company Subject ID Type Code J Company Subject ID Type Name | (Company Subject ID Issuing State [Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code [Company Subject ID Issuing[County Name (Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint Info Initial Contact, (Method |Unknown [Complaint info Initial Contact Date (Complaint Info Initial Response [Method |Unknown (Complaint info Initial Response [Date (Complaint info Amount Requested [Method (Complaint info Amount Requested Value [$0.00 (Complaint Info Amount Paid [Method |Unknown (Complaint Info Amount Paid Value [$0.00 (Complaint Info Product Service (Code jo304 (Complaint Info Product Service (Description. [Multi-Level Mktg\Pyramids\Chain [Letters [Complaint info Law Violation Code [ppm (Complaint Info Law Violation [Description [Deception/Misrepresentation [Complaint Info Statute Code iP [Complaint Info Statute Description [FTC Act Sec 5 (BCP) (Complaint Info Topic Code [Complaint info Topic Description (Complaint info Comments [MAIL: Consumer is writing on Ibehaif of an organization requesting Ithat the FTC investigate the \deceptive practice of a mult- leveling marketing company - [Herbalife. MAIL: Consumer sent a {duplicate letter regarding the same hing. Details are attached. (Complaint Info CRA Dispute Flag [Complaint info CRA Dispute Responded (Complaint Info CRA Dispute [Resolved (Complaint Info Fair Resolution Flag. [Complaint Info Fair Resolution[Description [Record 79 of 102 [Reference Number lagesz792 (Created Date ‘f2io22013 mplaint Source (Originator Reference Number [Language [English (Contact Type (Complaint (Data Source (Consumer DNC? IN [Entered By [STAYLORROBINS [Entered Date [12/02/2013 (Updated By ISTAYLORROBINS |Updated Date [12/05/2013 [Agency Contact [Phone [Complaint Date 2052013 Transaction Date [Member of armed forces or Ly dependant? [Consumer First Name be) (Consumer Middle Name (Consumer Last Name in(6) (Consumer Salutation (Consumer Address, Line 1 [o(6) (Consumer Address, Line 2 (Consumer Address, Line 3 [Consumer Address, City [South Gate (Consumer Address, State Code __|CA [Consumer Address, State Name _|California (Consumer Address, Country Code [Consumer Address, Country Name [usa [UNITED STATES [Consumer Address, ZIP Code __[b(6) [Consumer Address, ZIP Code rg) [Extension ‘Consumer Home Phone, Country (Code (Consumer Home Phone, Area he bb) (Consumer Home Phone, Number _|b(6) [Consumer Work Phone, Country (Code [Consumer Work Phone, Area Code(Consumer Work Phone, Number [Consumer Work Phone, Extension (Consumer Fax, Country Code (Consumer Fax, Area Code (Consumer Fax, Number (p(6) (Consumer Cell Phone, Country (Code (Consumer Cell Phone, Area Code (Consumer Cell Phone, Number [Consumer Email [o(6) [Consumer Age range [Consumer Military Status [Consumer Military Station (Consumer Complaining [CompanylOrg (City of South Gate |Consumer Military Service Branch (Consumer Consent for volunteer \group contact? [Company Name [Herbalife (Company Address, Line 1 (Company Address, Line 2 (Company Address, Line 3 (Company Address, City (Company Address, State Code [Company Address, State Name (Company Address, County Code lusA (Company Address, County Name [UNITED STATES (Company Address, ZIP Code [Company Address, ZIP Code [Extension (Company Phone, Country Code iny Phone, Area Code [Company Phone, Number [Company Phone, Extension [Company Email (Company Website (Company Subject ID Type Code (Company Subject ID Type Name (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing[Country Code —___| [Company Subject ID Issuing (Country Name. (Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint Info Initial Contact, [Method |Unknown [Complaint info Initial Contact Date (Complaint info Initial Response [Method jUnknown (Complaint nfo initial Response (Date (Complaint info Amount Requested [Method [Complaint info Amount Requested Value {$0.00 (Complaint Info Amount Paid [Method |Unknown (Complaint Info Amount Paid Value [$0.00 (Complaint Info Product Service (Code jo304 (Complaint Info Product Service (Description [Multi-Level Mktg\Pyramids\Chain (Complaint Info Law Violation Code [Complaint info Law Violation [Description [Complaint Info Statute Code [Complaint Info Statute Description [FTC Act Sec 5 (BCP) (Complaint Info Topic Code (Complaint Info Topic Description [CMs# 14009161: MAIL 12/02/2013: [The consumer an elected representative of the City of South \Gate, which is 95% Latinos. [Herbalife operates as a pyramid Ischeme and unfairly targets ethnic Iminorities, specifically the Latino lcommunity. The company predatory lpractices offer an ‘excellent Ibusiness opportunity” but in fact icost their families thousands of Ihard-eamed dollars. The {company's recruitment practices targets ethnic minorities, like those(Complaint info Comments living in South Gate, with lite to no business experience or ability to lasses risk. And clearly, the efforts lpaying off— for Herbalife only. {Sales within the Latino community late responsible for more than 60% lof Herbalife's billions in sales inationwide; however, 80 percent of \istributors are making nothing, [Repeatediy, former Herbalife {distributors explain how they were fiust trying to eam a living” or supplement their retirement or limited income" when they signed lon, butin the end, they lose thousands. [Complaint nfo CRA Dispute Flag (Complaint Info CRA Dispute Responded (Complaint Info CRA Dispute [Resolved (Complaint Info Fair Resolution Flag (Complaint Info Fair Resolution [Description [Record 80 of 102 Reference Number [49832806 ] (Created Date [2102/2013 [Complaint Source [Feder mr (Originator Reference Number (Language [English (Contact Type (Compiaint ] Data Source [Consumer [onc? IN [STAYLORROBINS ] [Entered By [Entered Date [12/02/2013 Updated B: [STAYLORROBINS [Updated Date 1205/2013 [Agency Contact [Phone [Complaint Date [r2iosi2013 [Transaction Date ] [Member of armed forces or L dependant? | (Consumer First Name be (Consumer Middle Name | ] (Consumer Last Name bre) |Consumer Salutation [Consumer Address, Line 1 [Consumer Address, Line 2 [Consumer Address, Line 3 (Consumer Address, City [Los Angeles (Consumer Address, State Code CA (Consumer Address, State Name _|Califomia (Consumer Address, Country Code [USA (Consumer Address, Country Name [UNITED STATES [Consumer Address, ZIP Code [Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code (Consumer Home Phone, Area (Code (Consumer Home Phone, Number [Consumer Work Phone, Country (Code [Consumer Work Phone, Area Code (Consumer Work Phone, Number [Consumer Work Phone, Extension [Consumer Fax, Country Code [Consumer Fax, Area Code [Consumer Fax, Number (Consumer Cell Phone, Country (Code [Consumer Cell Phone, Area Code (Consumer Gell Phone, Number (Consumer Email (Consumer Age range |Consumer Military Status [Consumer Military Station (Consumer Complaining (CompanylOrg [African Methodist Espiscopal (Church [Consumer Military Service Branch (Consumer Consent for volunteer youp contact? (Company Name [Herbalife (Company Address, Line 1 (Company Address, Line 2 (Company Address, Line 3 (Company Address. City[Company Address, StateCode | [Company Address, State Name (Company Address, County Code USA (Company Address, County Name [UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code (Company Phone, Area Code (Company Phone, Number [Company Phone, Extension (Company Email [Company Webs (Company Subject ID Type Code: [Company Subject ID Type Name _| (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name [Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation [Company Rep Comments (Complaint info Initial Contact, [Method [Complaint Info initial Contact Date _| (Complaint info Initial Response [Method |Unknown |Unknown (Complaint Info Initial Response Date (Complaint Info Amount Requested [Method [Complaint Info Amount Requested Value pom (Complaint Info Amount Paid Come [Unknown ‘Complaint nfo Amount Paid Value [$0.00 [Complaint nfo Product Service [yayq [Code(Complaint info Product Service [Description [Multi-Level Mktg\Pyramids\Chain lLetters (Complaint Info Law Violation Code [oom (Complaint Info Law Violation [Description |Deception/Misrepresentation [Complaint Info Statute Code (Complaint Info Statute Description ip [FTC Act Sec 5 (BCP) (Complaint Info Topic Code [Complaint info Topic Description (Complaint Info Comments [CMS# 14000157: MAIL 12/02/2013: [The organization became aware of the very troubling business practice lby Herbalife while working in the |community. Herbalife operates as a lpyramid scheme and deceitfully targets ethnic minorities. Herbalife [pyramid schemes are illegal Ibecause members are incentivized Io recruit rather than sell products. [Most of the members of Herbalife lare at the bottom and struggling to leam anything, ifat all. Herbalife Ireported net sales in 2012 were |more than $4 billion and a net income of $477.19 milion, yet the imedian income for sales leaders lare almost zero. The CEO made {$10 million last year; more than 99 ipercent of the distibutors make less, than living wage. In fact, many end lup losing thousands in the process (Complaint Info CRA Dispute Flag (Complaint Info CRA Dispute Responded (Complaint info CRA Dispute [Resolved [Complaint Info Fair Resolution Flag \Complaint Info Fair Resolution [Description Record 81 of 102 [Reference Number [aggo46s1 } (Created Date [12/04/2013 [Complaint Source [Federal Trade Commission (Originator Reference Number [Language [English (Contact Type [Complaint (Data Source (Consumer(onc? IN [Entered By UCHASE1 [Entered Date fizioai2013, (Updated 6: UCHASE1 (Updated Date hznze013| [Agency Contact iPhone [Complaint Date fi2nzi2013 | {Transaction Date [Member of armed forces or ly dependant? (Consumer First Name [ov6) [Consumer Middle Name [o(6) (Consumer Last Name io(6) [Consumer Salutation Consumer Address, Line 1 [Consumer Address, Line 2 [Consumer Address, Line 3 (Consumer Address, City (Consumer Address, State Code (Consumer Address, State Name (Consumer Address, Country Code _|USA (Consumer Address, Country Name [UNITED STATES [Consumer Address, ZIP Code (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code. (Consumer Home Phone, Area (Code (Consumer Home Phone, Number (Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code (Consumer Work Phone, Number (Consumer Work Phone, Extension (Consumer Fax, Country Code [Consumer Fax, Area Code [Consumer Fax, Number (Consumer Cell Phone, Country (Code (Consumer Cell Phone, Area Code: [Consumer Cell Phone, Number |Consumer Email[Consumer Age range [Consumer Military Status [Consumer Miltary Station (Consumer Complaining |CompanyOrg (Consumer Military Service Branch (Consumer Consent for volunteer (group contact? (Company Name [Herbalife (Company Address, Line 1 (Company Address, Line 2 (Company Address, Line 3 (Company Address, City (Company Address, State Code (Company Address, State Name (Company Address, Country Code [usa [Company Address, Country Name [UNITED STATES [Company Address, ZIP Code [Company Adcress, ZIP Code [Extension [Company Phone, Country Code (Company Phone, Area Code (Company Phone, Number (Company Phone, Extension (Company Email (Company Website (Company Subject ID Type Code (Company Subject ID Type Name (Company Subject ID Issuing State (Code [Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code [Company Subject ID Issuing (Country Name (Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint Info Initial Contact, (Method |Unknown[Complaint Info Initial Contact Date _| Pd (Complaint info Initial Response [Method |Unknown (Complaint Info Initial Response Date (Complaint Info Amount Requested [Method (Complaint Info Amount Requested \Value {$0.00 [Complaint Info Amount Paid [Method [Complaint info Amount Paid Value_| |Unknown {$0.00 [Complaint Info Product Service (Code jo304 (Complaint Info Product Service [Description [Multi-Level Mkig\Pyramids\Chain [Lottors (Complaint Info Law Violation Code [oom (Complaint Info Law Violation [Description [Deception/Misrepresentation [Complaint Info Statute Code (Complaint Info Statute Description _| (Complaint info Topic Code P |FTC Act Sec 5 (BCP) ] ] [Complaint Info Topic Description (Complaint info Comments [cms# 14009152 Consumer states [Herbalife operates as a pyramid ischeme and deceitiully targets lethnic minorities and their "get rich" [promise is a threat to the well being lof hardworking families, Consumer Istates members are incentivized to recruit rather than sell the product land virtually do not eam anything. UPDATE 12/12/2013 See attached letter for full details JCHASE (Complaint Info CRA Dispute Flag (Complaint Info CRA Dispute Responded [Complaint Info CRA Dispute Resolved [Complaint Info Fair Resolution Flag | (Complaint Info Fair Resolution [Record 82 of 102 Reference Number [49895035 ] (Created Date [12/04/2013[Complaint Source Federal Trade Commission [Originator Reference Number ‘Language [English (Contact Type (Compiaint (Data Source (Consumer DNG? N [Entered By UCHASE [Entered Date fizio4i2013 (Updated 8 UCHASET (Updated Date fi2nzi2013 [Agency Contact [Phone [Complaint Date [12/12/2013 Transaction Date [Member of armed forces or L (dependant? |Consumer First Name ive) (Consumer Middle Name (Consumer Last Name inv6) (Consumer Salutation (Consumer Address, Line 1 [Consumer Address, Line 2 (Consumer Address, Line 3 (Consumer Address, City (Consumer Address, State Code (Consumer Address, State Name (Consumer Address, Country Code _|USA [Consumer Address, Country Name [UNITED STATES [Consumer Address, ZIP Code (Consumer Address, ZIP Code [Extension (Consumer Home Phone, County (Code (Consumer Home Phone, Area (Code (Consumer Home Phone, Number [Consumer Work Phone, Country (Code [Consumer Work Phone, Area Code [Consumer Vierk Phone, Runber [Consumer Work Phone, Extension [Consumer Fax, Country Code [Consumer Fax, Area Code (Consumer Fax, Number(Consumer Cell Phone, Country (Code [Consumer Cell Phone, Area Code (Consumer Cell Phone, Number [Consumer Email (Consumer Age range (Consumer Military Status (Consumer Military Station (Consumer Complaining |CompanylOrg [Consumer Military Service Branch [Ruach Christian Fellowship [Consumer Consent for volunteer \group contact? [Company Name. (Company Address, Line 1 [Herbalife [Company Address, Line 2 [Company Aderess, Line 3 [Company Address, City (Company Address, State Code (Company Address, State Name (Company Address, Country Code lusa (Company Address, Country Name [UNITED STATES. (Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code (Company Phone, Area Code [Company Phone, Number | [Company Phone, Extension [Company Email [Company Website [Company Subject ID Type Code [Company Subject ID Type Name. (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing [Country Code (Company Subject ID Issuing (Country Name (Company Rep First Name[Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint Info Initial Contact, [Method fale {Unknown [Complaint info initial Contact Date (Complaint info initial Response |yngnown, (Complaint Info Initial Response [Date (Complaint Info Amount Requested [Method (Complaint Info Amount Requested Value [Complaint Info Amount Paid [Method [Complaint Info Amount Paid Value (Complaint Info Product Service (Code {$0.00 |Unknown {$0.00 jo304 (Complaint Info Product Service [Description [Complaint Info Law Violation Code [Multi-Level Mkig\Pyramids\Chain [Letters [ppm (Complaint Info Law Violation [Description (Complaint Info Statute Code [Complaint info Statute Description [Deception/Misrepresentation IP ] |FTCActSec5(@CP) (Complaint Info Topic Code (Complaint Info Comments [céis#14009159 Consumers \writing on behalf of his church |community. They have a complaint labout the company Herbalife, who hey say is a "getrich" quick lpyramid scheme. They found the (details of Herbalie's illegal pyramid lastounding, with a reported net Isales of $4 billion and a net income lof $47 million, yet over 99% of Ipeople who were lured into |Herbalife's pyramid scheme made less than living wage last year. (Consumers requesting the FTC initiate an investigation into {Herbalife and their illegal business ipractices. UPDATE 12/12/2013 [See attached letter for full details CHASE. (Complaint Info CRA Dispute Flag|Complaint Info CRA Dispute Responded [Complaint Info CRA Dispute [Resolved [Complaint Info Fair Resolution Flag (Complaint Info Fair Resolution [Description [Record 83 of 102 [Reference Number [49926489 |Created Date [12/05/2013 (Complaint Source [Federal Trade Commission (Originator Reference Number [Language [English (Contact Type [Complaint [Data Source (Consumer [pnc? In’ [Entered By (CJAUREGUI [Entered Date fi2i05i2013 (Updated By ISTAYLORROBINS [Updated Date [12/09/2013 [Agency Contact [Mait [Complaint Date [12/09/2013 Transaction Date fior2ei2013 [Member of armed forces or 5 (dependant? |Consumer First Name lo(6) (Consumer Middle Name (Consumer Last Name io(6) (Consumer Salutation (Consumer Address, Line 1 b@) (Consumer Address, Line 2 (Consumer Address, Line 3 (Consumer Address, City [Lynwood (Consumer Address, State Code __|CA (Consumer Address, State Name _|Califomia [Consumer Address, Country Code [USA [Consumer Address, Country Name [UNITED STATES [Consumer Address, ZIP Code ioe) (Consumer Address, ZIP Code [Extension (Consumer Home Phone, County (Code|Consumer Home Phone, Area (Code po (Consumer Home Phone, Number [p(6) (Consumer Work Phone, Country (Code [Consumer Work Phone, Area Code (Consumer Work Phone, Number (Consumer Work Phone, Extension (Consumer Fax, Country Code (Consumer Fax, Area Code love) [Consumer Fax, Number [b(6) (Consumer Cell Phone, Country (Code (Consumer Cell Phone, Area Code (Consumer Cell Phone, Number (Consumer Email ove) (Consumer Age range (Consumer Miltary Status (Consumer Military Station (Consumer Complaining (CompanylOrg (city of Lynwood [Consumer Military Service Branch (Consumer Consent for volunteer \group contact? (Company Name [Herbalife [Company Address, Line 1 (Company Address, Line 2 [Company Address, Line 3 (Company Address, City (Company Address, State Code (Company Address, State Name [Company Address, Country Code lusA (Company Address, County Name [UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code (Company Phone, Area Code [Company Phone, Number (Company Phone, Extension (Company Email [Company Website [Company Subject ID Type Code|Company Subject ID Type Name. (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing \Country Code (Company Subject ID Issuing (Country Name [Company Rep First Name [Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint Info Initial Contact, [Method junknown (Complaint Info Initial Contact Date frorze2013 | (Complaint Info Initial Response [Method |Unknown (Complaint info Initial Response [Date (Complaint Info Amount Requested [Method (Complaint Info Amount Requested \Value 's0.00 (Complaint Info Amount Paid [Method INot Reported (Complaint Info Amount Paid Value [$0.00 [Complaint Info Product Service (Code jo304 (Complaint Info Product Service [Description (Complaint Info Law Violation Code [Multi-Level Mkig\Pyramids\Chain [Letters [ppm (Complaint Info Law Violation [Description (Complaint Info Comments (Complaint info Statute Code ie (Complaint Info Statute Description FTC Act See 5 (BCP) [Complaint info Topic Code [Complaint info Topic Description [cMis#14009179 12/06/2013 MAIL: (Consumer mailed in a complaint requesting that we investigate [Herbalife as pyramids schemes are illegal, due to their unfair targeting lof ethnic minorities, and false claims in advertising.[Complaint info CRA Dispute Flag _| (Complaint Info CRA Dispute [Responded nN [Complaint info CRA Dispute Iv Resolved [Complaint nfo Fair Resolution Flag (Complaint info Fair Resolution (Description [Record 84 of 102 [Reference Number [49926507 (Created Date [121052013 (Complaint Source [Federal Trade Commission |Criginator Reference Number [Language |[Engtish (Contact Type (Complaint [Data Source |Consumer DNC? IN [Entered By (CJAUREGUI [Entered Date [12/05/2013 [Updated By |ABANKS [Updated Date [12/06/2013 [Agency Contact Phone [Complaint Date [12/06/2013 [Transaction Date fai 12013 [Member of armed forces or In dependant? (Consumer First Name ib(6) (Consumer Middle Name (Consumer Last Name in(6) (Consumer Salutation (Consumer Address, Line 1 in(6) (Consumer Address, Line 2 (Consumer Address, Line 3 (Consumer Address, City [Los Angeles (Consumer Address, State Code __|CA (Consumer Address, State Name |Califomia |Consumer Address, Country Code [USA [Consumer Address, Country Name |UNITED STATES (Consumer Address, ZIP Code __|b(6) [Consumer Address, ZIP Code [Extension [Consumer Home Phone, Country(Code (Consumer Home Phone, Area (Code (Consumer Home Phone, Number (Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code (Consumer Work Phone, Number (Consumer Work Phone, Extension (Consumer Fax. Country Code [Consumer Fax, Area Code (Consumer Fax, Number (Consumer Gell Phone, Country (Code (Consumer Cell Phone, Area Code (Consumer Gell Phone, Number (Consumer Email (Consumer Age range [Consumer Military Status [Consumer Miltary Station (Consumer Complaining (CompanylOrg |Christ Liberation Ministries [Consumer Military Service Branch (Consumer Consent for volunteer \group contact? [Company Name [Herbalife (Company Address, Line 1 [Company Address, Line 2 (Company Address, Line 3 (Company Address, City (Company Address, State Code |Company Address, State Name (Company Address, County Code [usa (Company Address, County Name [UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code (Company Phone, Area Code (Company Phone, Number [Company Phone. Extension (Company Email [Company Website[Company Subject ID Type Code | I (Company Subject ID Type Name. (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name [Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint info initial Contact [Method lUnknown [Complaint Info initial Contact Date fna11/2013 (Complaint Info Initial Response [Method |Unknown (Complaint info initial Response Date (Complaint Info Amount Requested [Method (Complaint Info Amount Requested \Value '$0.00 (Complaint info Amount Paid [Method (Complaint Info Amount Paid Value |Not Reported [$0.00 (Complaint Info Product Service (Code 1704 (Complaint Info Product Service [Health Care: Diet (Complaint Info Comments [Description [Producis\Centers\Pians [Complaint Info Law Violation Code |[DDM eae ee viteton [Deception/Misrepresentation [Complaint Info Statute Code. Ie. (Complaint Info Statute Description [FTC Act Sec 5 (BCP) \Complaint Info Topic Code | (Complaint info Topic Description | [cuis#14009160 12/05/2013 IMAIL:Consumer mailed in a {complaint against Herbalife for |recrutiting vuinerable members of his community into their pyramia ischeme. He explains they are{targeting ethnic minorities. (Complaint info CRA Dispute Flag (Complaint Info CRA Dispute Iv Responded [Complaint Info CRA Dispute Resolved IN [Complaint nfo Fair Resolution Flag]| (Complaint info Fair Resolution [Description [Record 85 of 102 Reference Number jaso26528 (Created Date fi2i05/2013 [Complaint Source [Federal Trade Commission ] (Originator Reference Number Language [English [Contact Type |Complaint (Data Source (Consumer DNC? IN [Entered By [CJAUREGUI [Entered Date [12/05/2013 [Updated B [Updated Date Agency Contact [Mait [Complaint Date [1205/2013 [Transaction Date ii1182013 [Member of armed forces or ly dependant? [Consumer First Name io(6) (Consumer Middle Name ib(6) (Consumer Last Name [oe (Consumer Salutation (Consumer Address, Line 1 inv6) (Consumer Address, Line 2 inv6) (Consumer Address, Line 3 [Consumer Address, City Jackson Heights [Consumer Address, State Code__ [NY [Consumer Address, State Name _|New York |Consumer Address, Country Code [USA (Consumer Address, Country Name |UNITED STATES (Consumer Address, ZIP Code __[b(6) (Consumer Address, ZIP Code [Extension(Consumer Home Phone, Country ICode |Consumer Home Phone, Area (Code pe) (Consumer Home Phone, Number _[b(6) (Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code (Consumer Work Phone, Number (Consumer Work Phone, Extension [Consumer Fax, Country Code (Consumer Fax, Area Code be (Consumer Fax, Number be (Consumer Cell Phone, Country (Code. (Consumer Cell Phone, Area Code (Consumer Cell Phone, Number [Consumer Email [Consumer Age range [Consumer Military Status [Consumer Military Station (Consumer Complaining (CompanylOrg [Queens Communit House [Consumer Military Service Branch (Consumer Consent for volunteer \group contact? (Company Name. [Herbalife [Company Address, Line 1 (Company Address, Line 2 (Company Address, Line 3 (Company Address, City [Company Address, State Code (Company Address, State Name [Company Address, Country Code [usa (Company Address, County Name [UNITED STATES [Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code (Company Phone, Area Code (Company Phone, Number [Company Phone, Extension [Company Email[Company Website —___| (Company Subject ID Type Code (Company Subject ID Type Name (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing \Country Code [Company Subject ID Issuing (Country Name [Company Rep First Name (Company Rep Middle Name [Company Rep Last Name (Company Rep Salutation [Company Rep Comments (Complaint info Initial Contact, [Code comple {Unknown [Complaint Info Initial Contact Date [11/18/2013 |Complaint Info Initial Response ‘Method \Unknown Complaint info Initial Response Date (Complaint info Amount Requested (Method [Complaint info Amount Requested Value 0.00 (Complaint Info Amount Paid corns INot Reported [Complaint Info Amount Paid Value [$0.00 [Complaint nfo Product Service [x7y4 (Complaint Info Product Service [Health Care: Diet [Description [Products\Centers\Pians [Complaint info Law Violation Code [ODM pein [DeceptionMisrepresentation (Complaint Info Statute Code P (Complaint Info Statute Description [FTC Act Sec 5 (BCP) (Complaint Info Topic Code | (Complaint Info Topic Description [cMs#140081680 12/05/2013 MAIL. (Consumer mailed in a complaint lagainst Herbalife as they take. ladvantage of people in her(Complaint info Comments |community by targeting minorities land immigrants. According to |consumer the company makes false, lpromises about the money people lcan make. (Complaint Info CRA Dispute Flag (Complaint Info CRA Dispute [Responded (Complaint Info CRA Dispute Resolved [Complaint Info Fair Resolution Flag) [Complaint info Fair Resolution [Description [Record 86 of 102 Reference Number [ag927003 (Created Date f12i062013 (Complaint Source [Federal Trade Commission (Originator Reference Number Language |English | [Contact Type [Complaint | |Data Source |Consumer onc? IN [Entered By RUANO [Entered Date fi2i062013 [Updated By |LSENIOR [Updated Date fizi092013 [Agency Contact [Phone [Complaint Date fizi092013 [Transaction Date [Member of armed forces or ly dependant? (Consumer First Name inv6) (Consumer Middle Name (Consumer Last Name ioe) (Consumer Salutation | [Consumer Address, Line 4 io) ] |Consumer Address, Line 2 [Consumer Address, Line 3 [Los Angeles [Consumer Address, State Code _|CA (Consumer Address, State Name _|Califomia (Consumer Address, County Code _|USA[Consumer Address, County Name | UNITED STATES [Consumer Address, ZIP Code [b(6) [Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code (Consumer Home Phone, Area (Code jp(6) Consumer Home Phone, Number [o(6) [Consumer Work Phone, Country (Code [Consumer Work Phone, Area Code (Consumer Work Phone, Number (Consumer Work Phone, Extension (Consumer Fax, Country Code [Consumer Fax, Area Code [b(6) (Consumer Fax, Number [n(6) (Consumer Cell Phone, Country (Code [Consumer Cell Phone, Area Code (Consumer Cell Phone, Number [Consumer Email (Consumer Age range [Consumer Military Status [Consumer Military Station (Consumer Complaining [CompanylOrg [National Action Network Los |Angeles (Consumer Military Service Branch [Consumer Consent for volunteer igroup contact? [Company Name. [Herbalife [Company Address, Line 1 [Company Address, Line 2 [Company Address, Line 3 (Company Address, City (Company Address, State Code (Company Address, State Name (Company Address, County Code lusa (Company Address, Country Name [UNITED STATES. (Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code|Company Phone, Area Code —___| (Company Phone, Number (Company Phone, Extension (Company Email (Company Website (Company Subject ID Type Code (Company Subject ID Type Name (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name [Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation [Company Rep Comments (Complaint Info Initial Contact, [Method |Unknown [Complaint info Initial Contact Date (Complaint Info Initial Response [Method |Unknown (Complaint Info Initial Response [Date (Complaint Info Amount Requested [Method (Complaint Info Amount Requested Value ‘$0.00 (Complaint Info Amount Paid (Method jUnknown (Complaint Info Amount Paid Value [$0.00 (Complaint Info Product Service (Code jo304 (Complaint Info Product Servic [Description Multi-Level Mkig\Pyramids\Chain Letters (Complaint Info Law Violation Code DM ] (Complaint info Law Violation [Description [Deception/Misrepresentation [Complaint info Statute Code iP [Complaint Info Statute Description [FTC Act Sec 5 (BCP) (Complaint Info Topic Code (Complaint Info Topic Descriotion i I(Complaint info Comments [cMs# 14009181 12/06/2073 MAIL: |Consumer mailed in a complaint lagainst Herbalife for recruiting jvulnerable members of his lcommunity into their pyramid Ischeme. He explains they are targeting ethnic Iminorities. Fulfillment was sent to [Resolved {consumer JRUANO. [Complaint Info CRA Dispute Flag [Complaint info CRA Dispute Iv [Responded [Complaint info CRA Dispute ly (Complaint Info Fair Resolution Flag (Complaint Info Fair Resolution [Description [Record 87 of 102 [Reference Number (Created Date (Complaint Source | [Originator Reference Number | [Language | fage43089 [12/06/2013 | [Federal Trade Commission ] |English } [Contact Type [Complaint [Data Source [Consumer [pNc? IN. [Entered By |ABANKS [Entered Date [12/06/2013 (Updated B: Updated Date [Agency Contact [Phone (Complaint Date [12/06/2013 | [Transaction Date [Member of armed forces or (dependant? (Consumer First Name Ib(6) [Consumer Middle Name | [Consumer Last Name [Consumer Salutation | Consumer Address, Line 1 | (Consumer Address, Line 2 [Consumer Address, Line 3 (Consumer Address, City[Consumer Address, State Code _| ____| (Consumer Address, State Name (Consumer Address, Country Code |USA (Consumer Address, Country Name |UNITED STATES (Consumer Address, ZIP Code (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code (Consumer Home Phone, Area (Code (Consumer Home Phone, Number (Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code |Consumer Work Phone, Number [Consumer Work Phone, Extension (Consumer Fax, Country Code (Consumer Fax, Area Code [Consumer Fax, Number (Consumer Cell Phone, Country (Code (Consumer Gell Phone, Area Code (Consumer Cell Phone, Number [Consumer Email IConsumer Age range (Consumer Miltary Status [Consumer Military Station (Consumer Complaining (CompanylOrg [Consumer Military Service Branch (Consumer Consent for volunteer \group contact? [Company Name. [Herbalife (Company Address, Line 1 (Company Address, Line 2 (Company Address, Line 3 (Company Address, City (Company Address, State Code (Company Address, State Name (Company Address, County Code _|USA (Company Address, County Name _|UNITED STATES (Company Address, ZIP Code [Rauch Christian Fellowship|Company Address, ZIP Code [Extension [Company Phone, Country Code (Company Phone, Area Code (Company Phone, Number (Company Phone, Extension (Company Email (Company Website (Company Subject ID Type Code (Company Subject ID Type Name [Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name (Company Rep First Name [Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint Info Initial Contact, [Method |Unknown (Complaint Info Initial Contact Date (Complaint Info Initial Response [Method |Unknown (Complaint Info Initial Response [Date (Complaint Info Amount Requested [Method (Complaint info Amount Requested Value ($0.00 (Complaint Info Amount Paid [Method INot Reported (Complaint Info Amount Paid Value [$0.00 (Complaint Info Product Service (Code \4006 (Complaint info Product Service [Description [Business Opportunities\Work-At |Home Plans (Complaint Info Law Violation Code [ppm (Complaint Info Law Violation [Description [Deception/Misrepresentation (Complaint Info Statute Code IP[Complaint Info Statute Description [FTC Act Sec 5 (BCP) [Complaint Info Topic Code. [Complaint info Topic Description (Complaint Info Comments [Mail: Consumeris writing on behalf lof their company Ruach Christian |Fellowship, regarding their {complaint against Herbalife. |Complaintant states that people in their community, which includes all lover Los Angeles area, have lexpressed their concern with |Herbalife's get rich-quick Pyramid Ischeme. Complaintantis hoping the, [FTC will open an investigation regarding this matter. the details of {Herbalife's pyramid scheme are lastounding, Last year Herbalife reported net sales of more than $4 billion and a net income of $477.19 Imillion, yet 40% of Herbalife lemployees are supervisors, who leamed an average compensation lof $637. Over 99% of people who jwere lured into Herbalife's Pyramid ‘Scheme last year made less than a living wage. Members are lencouraged to recruit instead of Iselling the products and that leaves {those at the bottom with no recruits. [Complaint Info CRA Dispute Flag _| (Complaint Info CRA Dispute Responded (Complaint Info CRA Dispute Resolved (Complaint Info Fair Resolution Fi (Complaint Info Fair Resolution [Description [Reference Number [Record 88 of 102 [ag96oa39 (Created Date [Complaint Source ‘fi2i092013 [Federal Trade Commission (Originator Reference Number [Entered By Language ‘[English (Contact Type [Complaint [Data Source [Consumer | DNC? IN iLSENIOR |[Entered Date jr2io92013 (Updated 6 [LSENIOR (Updated Date fa2ii2/2013 lAgency Contact iPhone [Complaint Date fi2n2i2013 [Transaction Date [Member of armed forces or Iv dependant? (Consumer First Name iov6) (Consumer Middle Name [Consumer Last Name [n(6) |Consumer Salutation (Consumer Address, Line 1 io(6) |Consumer Address, Line 2 [Consumer Address, Line 3 [Consumer Address, City [South Gate (Consumer Address, State Code [CA (Consumer Address, State Name _|Califomia (Consumer Address, Country Code USA (Consumer Address, Country Name |UNITED STATES ‘Consumer Address, ZIP Code __|b(6) (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country (Code (Consumer Home Phone, Area (Code [Consumer Home Phone, Number _[b(6) (Consumer Work Phone, Country (Code [Consumer Work Phone, Area Code Consumer Work Phone, Number (Consumer Work Phone, Extension [Consumer Fax, Country Code Ibe) (Consumer Fax, Area Code io(6) [Consumer Fax, Number Iie) (Consumer Gell Phone, Country (Code (Consumer Gell Phone, Area Code (Consumer Cell Phone, Number [Consumer Email io(6) [Consumer Age range [Consumer Military Status|Consumer Military Station (Consumer Complai (CompanylOrg (City of South Gate City Council (Consumer Military Service Branch (Consumer Consent for volunteer yroup contact? (Company Name [Herbalife (Company Address, Line 1 (Company Address, Line 2 (Company Address, Line 3 (Company Address, City (Company Address, State Code [Company Address, State Name [Company Address, County Code (Company Address, County Name [Usa [UNITED STATES (Company Address, ZIP Code [Extension [Company Phone, Country Code (Company Phone, Area Code (Company Phone, Number [Company Phone, Extension (Company Email (Company Website (Company Subject ID Type Code (Company Subject ID Type Name (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name [Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint Info Initial Contact, nal |unknown (Complaint Info Initial Contact Date (Complaint Info Initial Response |. nowy IMethod(Complaint Info Initial Response (Date (Complaint Info Amount Requested [Method (Complaint Info Amount Requested \Value (Complaint Info Amount Paid. (Code el \Unknown [Complaint Info Amount Paid Value ‘Complaint info Product Service |gggq (Complaint Info Product Service [Description [Multi-Level Mkig\Pyramids\Chain |Lettors (Complaint Info Law Violation Code [ppm (Complaint info Law Violation [Description [Deception/Misrepresentation [Complaint info Statute Code iP [Complaint info Statute Description [FTC Act Sec 5 (BCP) [Complaint Info Topic Code [Complaint Info Topic Description (Complaint Info Comments [CMs: 14009156. Mail: Consumer reports the he is an elective representative of a city comprised of Inearty 95 percent Latino and that, [Herbalife operates as a pyramid Ischeme and unfairly targets ethnic Iminorties. Consumer indicates [Herbalife targets those with no business experience or ability to lasses risk and 80% of distributors imake nothing. (Complaint Info CRA Dispute Flag (Complaint info CRA Dispute [Responded (Complaint info CRA Dispute Resolved (Complaint Info Fair Resolution Flag (Complaint Info Fair Resolution [Description [Record 89 of 102 [Reference Number [agoeo445 (Created Date frzio92013 (Complaint Source [Federal Trade Commission (Originator Reference Number Language [English|Contact Type [Complaint (Data Source (Consumer DNC? IN [Entered By [STAYLORROBINS [Entered Date fizi09i2013 (Updates 8 [STAYLORROBINS [Updated Date h2n22013 [Agency Contact iPhone [Complaint Date fi2n2i013 [Transaction Date [Member of armed forces or ly \dependant? (Consumer First Name io(6) |Consumer Middle Name loi6) [Consumer Last Name \o(6) |Consumer Salutation [Consumer Address, Line 1 [b6) (Consumer Address, Line 2 (Consumer Address, Line 3 (Consumer Address, City lLos Angeles (Consumer Address, State Code [CA (Consumer Address, State Name _|Califomia (Consumer Address, Country Code _|USA (Consumer Address, Country Name [UNITED STATES (Consumer Address, ZIP Code (b(6) (Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country \Code (Consumer Home Phone, Area (Code [p(6) (Consumer Home Phone, Number ove) (Consumer Work Phone, Country (Code (Consumer Work Phone, Area Code [Consumer Work Phone, Number (Consumer Work Phone, Extension [Consumer Fax, Country Code [Consumer Fax, Area Code [Consumer Fax, Number (Consumer Cell Phone, Country (Code [Consumer Cell Phone, Area Code|Consumer Cell Phone, Number. (Consumer Email [Consumer Age range (Consumer Miltary Status [Consumer Military Station (Consumer Complaining \CompanylOrg [Greater True Light Missionary (Baptist [Consumer Military Service Branch (Consumer Consent for volunteer \group contact? (Company Name [Herbalife (Company Address, Line 1 (Company Address, Line 2 [Company Address, Line 3 (Company Address. City [Company Address, State Code (Company Address, State Name (Company Address, Country Code [usa (Company Address, County Name |UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension (Company Phone, Country Code (Company Phone, Area Code [Company Phone, Number (Company Phone, Extension (Company Email [Company Website | (Company Subject ID Type Code [Company Subject ID Type Name (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code (Company Subject ID Issuing (Country Name (Company Rep First Name (Company Rep Middle Name (Company Rep Last Name (Company Rep Salutation Cor Rep Commer(Complaint info Initial Contact, [Method |Unknown [Complaint Info Initial Contact Date (Complaint Info Initial Response [Method |Unknown (Complaint info Initial Response Date (Complaint Info Amount Requested [Method (Complaint Info Amount Requested Value [Complaint Info Amount Paid [Method (Complaint Info Amount Paid Value (Complaint Info Product Service (Code ‘$0.00 |Unknown {$0.00 jo304 (Complaint Info Product Service Description [Multi-Level Mkig\Pyramids\Chain [Lottors [Comp it Info Law Violation Code | (Complaint Info Law Violation Description [Complaint Info Statute Code | [Complaint Info Statute Description (Complaint info Topic Code | (Complaint Info Topic Description _| [ppm [Deception/Misrepresentation | [FTC Act Sec 5 (BCP) (Complaint info Comments [CMS# 14009212: MAIL 12/09/2013: [The consumer sent in a copy of the letter to CA Atlomey General Office, thas come to the consumer's lattention that Herbalife has illegally targeted ethnic minorities to keep heir pyramid scheme in business. [The company is using false ladvertising techniques. The {company goes after those with litle {to no business experience or ability to assess risk. Sales within the [Latino community are responsible for more than 60% of Herbalife's Inationwide sales, according to the {company's last disclosure on this issue. The 1986 injunction was Ibrought in a case by the Santa Cruz_| (district Attorney against Herbalife, requiring the company to verify retails sales and other {documentations to prove the {company's sales to distributors and lcustomers. Since the injunction, 27lyears ago, the company has failed {to collect any of the necessary \documentation. [Complaintino GRA Dispute Fag (Complaint Info CRA Dispute Responded (Complaint Info CRA Dispute [Resolved (Complaint Info Fair Resolution Flag) (Complaint Info Fair Resolution [Description [Record 90 of 102 [Reference Number [49969630 [Created Date (Complaint Source | [12/09/2013 | [Federal Trade Commission [Originator Reference Number [Language [English (Contact Type [Complaint (Data Source [Consumer DNC? IN [Entered By iLSENIOR [Entered Date fiziog2013 (Updated 8 ILSENIOR (Updated Date fi2i2i2013 | [Agency Contact iPhone [Complaint Date fi2n2i2013 Transaction Date [Member of armed forces or q (dependant? [Consumer First Name ine) [Consumer Middle Name |Consumer Last Name ive) (Consumer Salutation (Consumer Address, Line 4 ioe) (Consumer Address, Line 2 (Consumer Address, Line 3 (Consumer Address, City [Los Angeles (Consumer Address, State Code [CA (Consumer Address, State Name _|Califomia (Consumer Address, Country Code _|USA (Consumer Address, Country Name [UNITED STATES (Consumer Address, ZIP Code [o(6)|Consumer Address, ZIP Code [Extension (Consumer Home Phone, Country [Code [Consumer Home Phone, Area (Code pte) [Consumer Home Phone, Number ioe) [Consumer Work Phone, Country (Code [Consumer Work Phone, Afea Code [Consumer Work Phone, Number (Consumer Work Phone, Extension (Consumer Fax, Country Code (Consumer Fax, Area Code be) (Consumer Fax, Number [b(6), (Consumer Gell Phone, Country (Code (Consumer Gell Phone, Area Code (Consumer Cell Phone, Number [Consumer Email (Consumer Age range (Consumer Miltary Status [Consumer Military Station (Consumer Complaining (CompanylOrg [National Action Network Los lAngeles (Consumer Military Service Branch [Consumer Consent for volunteer {group contact? [Company Name [Herbalife (Company Address, Line 1 [Company Address, Line 2 |Company Address, Line 3 [Company Address, City |Company Address, State Code (Company Address, State Name (Company Address, County Code USA (Company Address, County Name [UNITED STATES (Company Address, ZIP Code (Company Address, ZIP Code [Extension |Company Phone, Country Code [Company Phone, Area Code [Company Phone, Number|Company Phone, Extension —___| (Company Email (Company Website (Company Subject ID Type Code (Company Subject ID Type Name (Company Subject ID Issuing State (Code (Company Subject ID Issuing State Name (Company Subject ID Issuing (Country Code [Company Subject ID Issuing (Country Name (Company Rep First Name (Company Rep Middle Name [Company Rep Last Name (Company Rep Salutation (Company Rep Comments (Complaint Info Initial Contact, [Method |Unknown (Complaint Info Initial Contact Date (Complaint Info Initial Response [Method |Unknown (Complaint info initial Response (Date (Complaint info Amount Requested (Method (Complaint Info Amount Requested Value ($0.00 (Complaint Info Amount Paid [Method jUnknown (Complaint Info Amount Paid Value {$0.00 (Complaint info Product Service (Code jo304 (Complaint Info Product Service [Description [Multi-Level Mkig\Pyramids\Chain lLetters (Complaint Info Law Violation Code [ppm (Complaint Info Law Violation [Description [Deception/Misrepresentation [Complaint Info Statute Code ip (Complaint Info Statute Description [FTC Act Sec 5 (BCP) [Complaint info Topic Code (Complaint info Topic Description [CMS:14009184. Mail: Consumer reports HerbaLife as having not|complied with 1986 injunction \where in they had to produce the Inecessay documents verifying retail cdma its Conimenss sales, sales to distributors and icustormers. Consumer reasons that [Herbalife is victimizing minorities with a pyramid scheme wherein lonly the top positions make a profit land the bottom make almost Inothing. [Complaint Info CRA Dispute Flag [Complaint info CRA Dispute qi [Responded [Complaint Info CRA Dispute Iv Resolved [Complaint Info Fair Resolution Flag (Complaint info Fair Resolution (Description IDT COMPLAINT [Record 91 of 102 J Reference Number [46500441 ] [Originator Reference Number ] |Language [English Icomplaint Source [FTC Online Complaint Assistant \(OT) (Contact Type [Complaint J [Data Source [Agency Contact Method internet [Entered By [FTCCISFTCUSER [Entered Date (o6i132013 [Updated By Updated Date Theft Via Interet? iv [Member of armed forces or idependant? Consumer Business Name (Consumer First Name io(6) (Consumer Middle name (Consumer Last Name iov6) (Consumer Address, Line 1 io(6) (Const e2 [Consum Ci [Consumer Address, State Code _INY[Consumer Address, State Name _|New York (Consumer Address, Country Code_|USA (Consumer Address, County Name |UNITED STATES (Consumer Address, ZIP Code _|b(6) (Consumer Address, ZIP Code [Extension (Consumer Lived Here Since (Consumer Home Phone, Area (Code (Consumer Home Phone, Number _|b(6) [Consumer Work Phone, Area Code |b(6) (Consumer Work Phone, Number _|b(6) (Consumer Work Phone, Extension (Consumer Gell Phone, Area Code (Consumer Cell Phone, Number (Consumer Fax, Area Code Consumer Fax, Number [Consumer Email ive) [Consumer Date Of Birth lo) (Consumer Driver License /1D Issued State [Consumer Soldier Status. [Consumer Soldier Station (Consumer Military Service Branch (Consumer At Time of Fraud First Name (Consumer At Time of Fraud Middle Name (Consumer At Time of Fraud Last Name [Consumer At Time of Fraud |Address, Line 1 [Consumer At Time of Fraud \Address, Line 2 [Consumer At Time of Fraud \Address, City [Consumer At Time of Fraud |Address, State Code [Consumer At Time of Fraud \Address, State Name [Consumer At Time of Fraud \Address, Country Code [Consumer At Time of Fraud ‘Address, Country Name (Consumer At Time of Fraud Ine) INY, New York\Address, ZIP Code | [Consumer At Time of Fraud \Address, ZIP Code Extension (Consumer At Time of Fraud Phone, \Area Code (Consumer At Time of Fraud Phone, Number (Consumer At Time of Fraud Lived [Here Since [Consumer At Time of Fraud Lived {Here Until |Reported By Company Name [Reported By First Name Reported By Middle Name [Reported By Last Name [Reported By Address, Line 1 [Reported By Address, Line 2 [Reported By Address, City [Reported By Address, State Code |Reported By Address, State Name [Reported By Address, Country (Code Reported By Address, Country Name [Reported By Address, ZIP Code [Reported By Address, ZIP Code [Extension [Reported By Home Phone, Area (Code Reported By Home Phone, Number [Reported By Work Phone, Area (Code [Reported By Work Phone, Number [Reported By Work Phone, [Extension [Reported By Cell Phone, Area (Code [Reported By Cell Phone, Number [Reported By Fax, Area Code |Reported By Fax, Number [Reported By Email ‘Theft Activity First Noticed Date [02/13/2013 [Theft Activity First Occurred Date [02/13/2013 [Theft Activity Number of Misuses (#(Accounts Affected) ‘Theft Activity Total Amount (Obtained Value (by Subject) ‘Theft Activity Total Amount Lost Value (by Victim) ‘Theft Activity Did You Authorize ‘Anyone To Use Your 1D? ‘Theft Activity Did You Receive Benefits? ‘Theft Activity Are You Willing To [Press Charges? [Theft Activity Inaccurate Personal Information 1 ‘Theft Activity Inaccurate Personal Information 2 ‘Theft Activity Inaccurate Personal Information 3 ‘Theft Activity Credit inquiries — (Company 1 (Company 2 ‘Theft Activity Credit Inquiries — ‘Theft Activity Credit Inquiries — (Company 3 ‘Theft Activity NonMonetary Harm, [Harm Code Hos}47 ‘Theft Activity NonMonetary Harm, [other (describe in comment ffetd)|Time Lost to Resolve Harm Description [Problems (specify amount in lcomment) ‘Theft Activity NonMonetary Harm, [7 boxes of supplements delivered [Comments to my door that Ihave not ordered | [A few months ago, l received a letter and ID card saying that | am Inow a cistributor for Herbalife. [Having not at all heard of Herbalife Inor signed up to be a distributor, | (disregarded the letter. About a Imonth later, Iwas delivered 7 large Iboxes of Herbalife through Fedex {to my address. The name laddressed on the box is extremely Iclose to mine in spelling. !tumed Ihe delivery woman away with the 7. large boxes of supplements since | lplaced no such order. When I called| |Herbalife, I was told that that was Inot the frst order placed to my laddress, and that more were to lcome. I related my issue to the imanager, Urenia to whom I spoke(Theft Activity Comments |with, and demanded to be given the Iname of the "sponsor" who hired Ime as distributor. However, even jwith my pressing suspicion of ldentity thef, they would not provide Ime with means to contact this Isponsor. They did say they would Inotiy this sponsor that | was trying to get a hold of himmher. Weeks later, Ihave yet to receive contact Irom this "sponsor" of mine. | have Istrong reason to believe that |Herbalife's employment policies involve fraudulent processes and {heir tack of assistance in this issue lleads me to believe that their lbusiness practices are dishonest [Due to their lack of investigation in this matter, Ihave also taken |measures to report them to BBB land plan to file a report with my local police. [Theft Activity Additional Comments [Theft incident Theft Type Code le ‘Theft incident Theft Type [Description [Theft incident SubType Code \Other Identity Theft lar. Theft Incident SubType Description [Employment TheR incidentincident-Dateof ean 43 2913 Theft [Associated Institution institution [oyro, Type [Associated Institution institution catia Name [Associated Instituion Contact yrenig [Person [Associated Institution Address, Line I lo50 West 190th [Associated Institution Address, Line 2 ‘Associated Institution Address, City [Torrance ‘Associated Institution Address, [State Code Ica [Associated Institution Address, \State Name \California [Associated Institution Address, (Country Code USA\Associated Institution Address, [Extension [County Name UNITED STATES, [Associated Institution Address, ZIP ona lo0502 (Associated Institution Address, ZIP (Code Extension [Associated Institution Phone, Area |oag (Code [Associated Institution Phone, Lsa74 Number [Associated Institution Phone, ly [Associated Institution Notified? [Associated Institution Written \Notified? [Associated Institution Have Dispute? ‘Associated Institution Product, (Service Code [Associated Institution Product ‘Service Description [Associated Institution Statute Code ‘Associated Institution Statute [Description ‘Associated Institution Violation (Code [Associated Institution Violation [Description [Associated Institution Email [Associated Institution Web URL |www-herbalife.com [Suspect Alias, First Name [n(6) (Suspect Alias, Middle Name (Suspect Alias, Last Name [o(6) [Suspect Alias, Company Name [Herbalife (Suspect Contact Address, Line 1 (b(6) [Suspect Contact Address, Line 2 [Suspect Contact Address, City [Suspect Contact Address, State (Code [Suspect Contact Address, State Name (Suspect Contact Address, Country (Code usa (Suspect Contact Address, Country UNITED STATES Name\Suspect Contact Address, ZIP (Code [Suspect Contact Address, ZIP [Code Extension [Suspect Contact Phone, Area Code| [Suspect Contact Phone, Number (Suspect Contact Phone, Extension [Suspect Contact, Email [Suspect Victim Relationship (Suspect Method of Obtainment (Code ist [Suspect Method of Obtainment [Description [Mail theft or fraudulent address Ichange \Suspect Suspect Additional Information [Sponsored me as distibutor and lordered 7 boxes to be delivered to Imy address - all of which were done, |without my approval or knowledge. (Credit Bureaus Credit Bureau Name (Credit Bureaus Credit Bureau \Notified? (Credit Bureaus Credit Bureau Fraud Alen’? (Credit Bureaus Credit Bureau [Report Ordered? (Credit Bureaus Credit Bureau Have (Dispute? (Credit Bureaus Credit Bureau Law \Violation Codes (Credit Bureaus Credit Bureau Law \Violation Description \Law Enforcement Entities [Department Name \Law Enforcement Entities Contact Person (Law Enforcement Entities Address, [State Code \Law Enforcement Enlities Address, ‘State Name |Law Enforcement Eniities Phone, \Area Code \Law Enforcement Enlities Phone, Number [Law Enforcement Entities Notified \Local Law Enforcement? [Law Enforcement Entities Report (Taken?[Law Enforcement Eniities Report Number |Law Enforcement Entities Report {Taken Date \Law Enforcement Entities Verified Report? IN DNC COMPLAINT [Record 92 of 102 Reference Number lar779109 [Complaint Source [National Do Not Call Registry [Phone In Registry? (Consumer First Name ly io(6) |Consumer Middle Name [Consumer Last Name (D(6) [Consumer Address, Line 1 pe) (Consumer Address, Line 2 (Consumer Address, City | [HIALEAH [Fu (Consumer Address, State Name [Florida (Consumer Address, ZIP Code __|b(6) (Consumer Phone, Area Code __[b(6) (Consumer Phone, Number iov6) (Company Name [Herbalife [Company State [Fu [Company Phone, Country Code _|1 (Company Phone, Area Code [786 [Company Phone, Number [2854401 ] [Other Information Created Date [08/11/2013 ] [Other Information Complaint Date [08/11/2013 ] (Other Information Product Service [Description \National Do Not Call Registry [Other information Organization [Other Information Complaint (Channel [National Do Not Call Registry Web (Other Information Transaction Date fosi1 112013 (Other Information Transaction Time (08:00:00 (Other Information Comments THEY ARE CONSTANTLY SENDING TEXT MESSAGES, IDAY AND NIGHT. | asked them [PLEASE removed me from the list [BUT they HAVE CONTINUED. [Other Information Existing Business[Relationship es | (Other Information Pre-Recorded |, Message (Other Information Requested Entity to Stop Calling [Record 93 of 102 |Reference Number [44018030 (Complaint Source [National Do Not Call Registry Phone In Registry? ly. (Consumer First Name (Consumer Middle Name |Consumer Last Name [b(6) (Consumer Address, Line 1 (Consumer Address, Line 2 (Consumer Address, City (Consumer Address, State IH (Consumer Address, State Name [Hawaii [Consumer Address, ZIP Code |Consumer Phone, Area Code Inve) [Consumer Phone, Number io(6) [Company Name |Herbalife Intemational [Company State laz (Company Phone, Country Code (Company Phone, Area Code l4a0 [Company Phone, Number [3265653 (Other Information Created Date [02/25/2013 [Other Information ComplaintDate [02/25/2013 [Other Information Product Service [Description [National Do Not Gall Registry [Other information Organization [National Do Not Call Registry (Other Information Complaint (Channel Web (Other Information Transaction Date fozi25:2013 (Other Information Transaction Time [12.00:00 (Other Information Comments [Unsolicited Call and Text Message [Received. [Other Information Existing Business| [Relationship INo [Other Information Pre-Recorded (Message INo (Other Information Requested Entity to Stop Calling INo[Record 94 of 102 [Reference Number I |4o4a3072 (Complaint Source [National Do Not Gall Registry [Phone in Registry? ly [Consumer Address, ZIP Code [Consumer First Name Ib(6) (Consumer Middle Name J (Consumer Last Name ioe) ] [Consumer Address, Line 1 lie) (Consumer Address, Line 2 [Consumer Address, City fairfax [Consumer Address, State IVA. [Consumer Address, State Name [Virginia ] io(6) [Consumer Phone, Area Code _[b(6) [Consumer Phone, Number be) (Company Name [herb [Company State (Company Phone, Area Code (Company Phone, Number (Other Information Created Date [1110772013 (Other Information Complaint Date [11/07/2013 (Other Information Product Service [Description [National Do Not Call Registry (Other Information Organization [National Do Not Call Registry [Other Information Complaint (Channel Web [Other Information Transaction Date Information Transaction Time. [11/0672013 ] [23:00:00 ] (Other Information Comments [A man called my house at almost Imicnight last night from Herbalife. 1 lasked them to stop calling me and {take me off their calling list. They {called again this morning at 9:36. | Ihave done absolutely no business lwith Herbalife. No phone number |showed up, ust their name. Today, here was nobody on the other ine. [Other Information Existing Business| [Relationship INo (Other information Pre-Recorded (Message INo (Other Information Requested Entity to Stop Calling lYes[Record 95 of 102 ] |Reference Number [ag7 16892 [Complaint Source [National Do Not Gall Registry [Phone In Registry? ly (Consumer First Name in(6) (Consumer Middle Name (Consumer Last Name in(6) [Consumer Address, Line 4 in(6) (Consumer Address, Line 2 (Consumer Address, Cit ‘[Cutver cit (Consumer Address, State [ca (Consumer Address, State Name _|Califomia [Consumer Address, ZIP Code _|b(6) [Consumer Phone, Area Code [D(6) [Consumer Phone, Number be [Company Name. [Somebody "not from Herbalife” _| [Company State [TF (Company Phone, Country Code (Company Phone, Area Code is00 (Company Phone, Number (e4s9064 (Other Information Created Date [09/21/2013 (Other Information Complaint Date 09/21/2013 (ter rfomaton Product Seric®aionai Do Not Call Rensty [Other Information Organization [Other Information Complaint [Channel [National Do Not Call Registry Web Other Information Transaction Date losi21/2013 [Other Information Transaction Time | [14:00:00 (Other Information Comments [Claimed to be doing marketing research. | have only one question, What do you think of Herbalife.” \Seemed pretty put out that we didn't Ibelieve he wasn't working for [Herbalife [Other Information Existing Business [Relationship INo (Other information Pre-Recorded (Message INo (Other Information Requested Entity {to Stop Calling Yes [Record 96 of 102[Reference Number [47038520 [Complaint Source [National Do Not Call Registry [Phone In Registry? ly. [Consumer First Name (oi) |Consumer Middle Name (Consumer Last Name ib(6) (Consumer Address, Line 1 in(6) (Consumer Address, Line 2 [Consumer Address, City [nuntington park (Consumer Address, State [ca (Consumer Address, State Name _||Califomia (Consumer Address, ZIP Code __|b(6) (Consumer Phone, Area Code _|b(6) (Consumer Phone, Number io(6) [Company Name |nerbalife (Company State [Company Phone, Country Code ] (Company Phone, Area Code la77 (Company Phone, Number [5658456 (Other Information Created Date [07/08/2013 [Other Information Complaint Date [07/08/2013 [Other Information Product Service [Description |National Do Not Call Registry (Other Information Organization [National Do Not Call Registry [Other Information Complaint (Channel Web (Other Information Transaction Date lo7/08r2013 (Other Information Transaction Time [18:00:00 i (Other Information Comments [They call every day and there is no loption to remove my number from Itheir list its so annoying to listen to that person is consuming my phone. time [Other Information Existing Business [Relationship INo (Other information Pre-Recorded (Message ives [Other Information Requested Entity {to Stop Calling lYes [Record 97 of 102 [Reference Number [47973134 (Complaint Sourc e [National Do Not Call Registry[Phone in Registry? lv (Consumer First Name [ove (Consumer Middle Name (Consumer Last Name ine) (Consumer Address, Line 4 ioe) [Consumer Address, Line 2 (Consumer Address, City [EDGEWOOD (Consumer Address, State ky [Consumer Address, State Name [Kentucky [Consumer Address, ZIP Code __|b(6) [Consumer Phone, Area Code [b(6) |Consumer Phone, Number lie) [Company Name HERBALIFE |Company State [TF [Company Phone, Country Gode [Company Phone, Area Code [800 (Company Phone, Number [2515850 [Other Information Created Date _[08/20/2013 (Other Information Complaint Date [08/20/2013 (Other information Product Service [Description \National Do Not Call Registry (Other information Organization —_[National Do Not Call Registry [Other Information Complaint (Channel [Other Information Transaction Date [08/20/2013 (Other Information Transaction Time [18:00:00 J WHY CAN'T THE FCC STOP [ROBO CALLS? Web (Other Information Comments (Other Information Existing Business| Relationship Fie Other Information Pre-Recorded ly es Message lotne inormaton Requested Ently to Stop Calling Record 98 of 102 [Reference Number [48274216 (Complaint Source |National Do Not Call Registry iPhone In Registry? ly [Consumer First Name (Consumer Middle Name [Consumer Last Name ove) [Consumer Address, Line 1[Consumer Address, Line 2 (Consumer Address, City (Consumer Address, State Inv (Consumer Address, State Name [Nevada (Consumer Address, ZIP Code (Consumer Phone, AreaCode __|b(6) (Consumer Phone, Number iov6) (Company Name [Herbalife (Company State (Company Phone, Country Code [Company Phone, Area Code (Company Phone, Number [Other Information Created Date [09/03/2013 ] Other Information ComplaintDate [09/03/2013 (Other Information Product Service [Description |National Do Not Call Registry [Other infomation Organization [National Do Not Call Registry (Other Information Complaint (Channel Web (Other Information Transaction Date [osi03r2013 [Other Information Transaction Time [19:00:00 (Other Information Comments [Automated Fake opinion survey, factually an herbalife ponzi scheme (Other Information Existing Business [Relationship INo [Other Information Pre-Recorded Message les [Other information Requested Entity to Stop Calling INo [Record 99 of 102 |Reference Number [agesoses: [Complaint Source [National Do Not Call Registry [Phone In Registry? ly. [Consumer First Name (Consumer Middle Name (Consumer Last Name [b(6) (Consumer Address, Line 1 (Consumer Address, Line 2 (Consumer Address, City (Consumer Address, State (Consumer Address, State Name linois [Consumer Address, ZIP Code[Consumer Phone, Area Code jb (Consumer Phone, Number [oe (Company Name [Herbalife (Company State loc (Company Phone, Country Code (Company Phone, Area Code [202 (Company Phone, Number (e8a0778 [Other Information Created Date [09/26/2013 [Other Information Complaint Date _|09/26/2013 (Other Information Product Service [Description \National Do Not Call Registry [Other Information Organization [National Do Not Call Registry [Other Information Complaint (Channel Web Other Information Transaction Date ooe2013 [16:00:00 [Other Information Comments [Other Information Existing Business [Relationship INo (Other information Pre-Recorded (Message ives [Other Information Requested Entity to Stop Calling INo [Record 100 of 102 [Reference Number [49763703 (Complaint Source [National Do Not Call Registry [Phone in Registry? lv [Consumer First Name [Consumer Middle Name I [Consumer Last Name io) [Consumer Address, Line 1 (Consumer Address, Line 2 | (Consumer Address, City [Consumer Address, State Ica (Consumer Address, State Name _|Califomia (Consumer Address, ZIP Code (Consumer Phone, Area Code __|b(6) (Consumer Phone, Number io) [Company Name [Herbalife Inete (Company State [cA [Company Phone, Country Code [Company Phone, Area Code [310[Company Phone, Number [5573902 [Other Information Created Date 11/20/2013, [Other Information Complaint Date 11/20/2013 [Other Information Product Service ational Do Not Call Registy [Description [Other information Organization __|[National Do Not Gall Registry (Other Information Complaint web (Channel [Other Information Transaction Date [11/20/2013 (Other Information Transaction Time [00:00:00 [This company has called multiple times a day for the past few days. [They call about every 1/2 hour, so lperhaps 20 times a day. We have Inot picked up the phone and they \do notleave a message (Other Information Comments [Other Information Existing Business Relationship [No [Omer Information Pre-Recorded | yag Message (Other information Requested Entity |, to Stop Calling ‘As a Consumer Sentinel Network member, you must properly protect any information printed, downloaded, or otherwise removed from the Network as stated in OMB Memo M06-16. Please delete or destroy this information within 90 days unless its use is stil required for law enforcement purposes. When destroying the information you should bum, pulverize, or shred. the information saved in paper format and destroy or erase information that has been saved electronically so that it cannot practicably be read or reconstructed. Proper erasure of electronic information must include the overwriting or "wiping" ofthe information from the electronic media on which itis stored. NEattlay, SCoNsUMER = SENTINED=worx ~ Law enforcement snr for coum complete DNC COMPLAINT [Record 101 of 102 [Reference Number (46855747 (Complaint Source [National Do Not Call Registry [Phone In Registy/? ly (Consumer First Name lo(6) (Consumer Middle Name (Consumer Last Name ib(6) (Consumer Address, Line 1 |Consumer Address, Line 2 (Consumer Address, City (Consumer Address, State [ca (Consumer Address, State Name _|Califomia (Consumer Address, ZIP Code (Consumer Phone, Area Code __|b(6) [Consumer Phone, Number [b(6) [Company Name [Herbalife [Company State Ica. [Company Phone, Country Code [Company Phone, Area Code i213 (Company Phone, Number fa1a1362 (Other information Created Date [06/28/2013 (Other Information Complaint Date [06/28/2013 (Other Information Product Service [Description [National Do Not Call Registry [Other Information Organization [National Do Not Gall Registry (Other Information Complaint (Channel Web (Other Information Transaction Date losi21/2013 [Other Information Transaction Time [12:00:00 (Other Information Comments [Caller was asked to stop calling, yet Ishe continues to call and has made [6 additional calls since them. (Other Information Existing Business Relationship nia! other information Pre-Resorded hy, Message [Other information Requested Entity{to Stop Calling [Record 102 of 102 [Reference Number [47779209 | (Complaint Source |[National Do Not Gall Registry [Phone in Registr ly. (Consumer First Name in(6) |Consumer Middle Name [Consumer Last Name [b(6) [Consumer Address, Line 1 Ibe) [Consumer Address, Line 2 [Consumer Address, City IALEAH [Consumer Address, State FL [Consumer Address, State Name _|Florida (Consumer Address, ZIP Code __[b(6) (Consumer Phone, Area Code __|b(6) [Consumer Phone, Number 6) (Company Name [Herbalife (Company State FL [Company Phone, Country Code __|1 | (Company Phone, Area Code [305 (Company Phone, Number [3182656 (Other information Created Date [08/11/2013 (Other Information Complaint Date _ [08/11/2013 [Other Information Product Service [Description [National Do Not Call Registry (Other Information Organization [National Do Not Call Registry [Other Information Complaint (Channel Web (Other Information Transaction Date fos 172013 (Other Information Transaction Time [00:00:00 (Other Information Comments [THEY ARE CONSTANTLY SENDING TEXT MESSAGES, IDAY AND NIGHT. | asked them [PLEASE removed me from the list [BUT they HAVE CONTINUED. (Other Information Existing Business| Relationship lYes [Other Information Pre-Recorded Message INo (Other Information Requested Entity to Stop Calling Ives‘As a Consumer Sentinel Network member, you must properly protect any information printed, downloaded, or otherwise removed from the Network as stated in OMB Memo M-06-16, Please delete or destroy this information within 90 days unless its use is stil required for law enforcement purposes, When destroying the information you should bum, pulverize, or shred. the information saved in paper format and destroy or erase information that has been saved electronically so that it cannot practicably be read or reconstructed. Proper erasure of electronic information must include the overwriting of "wiping" ofthe information from the electronic media on which itis stored.Chender, Julian M. fon = 0th. ety From: Apache server Sent: Friday, July 19, 2013 10:45 AM name = Sandy Chin staddr 888 Seventh Avenue city = NewYork state = NY zipcode 10019 telno = 212.484.2716 faxno email schin@visiumfunds.com coinfo = Dear sir or madam, | would like to request a copy of any investigatory records of Herbalife specifically between the period of January 1, 2013 to July 19, 2013. EdSciName = describe = Private Corporation or Law Firm privatelawname = Visium Asset Management medianame = money = Upto $100 B13 = SubmitUnited States of America FEDERAL TRADE COMMISSION WASHINGTON, D.C. 20580 Sandy Chin Visium Asset Management 888 Seventh Avenue, a New York, NY 10019 JUL 23 Zuid Re: FOIA-2013-01147 Herbalife Dear Ms. Chin: This is in response to your request dated July 19, 2013 under the Freedom of Information Act seeking access to all investigative records pertaining to Herbalife between January 1, 2013 and July 19, 2013. In accordance with the FOIA and agency policy, we have searched our records as of July 19, 2013, the date we received your request in our FOIA office. Our search of the FTC’s records did not identify any record that would respond to your request. If you are not satisfied with this response to your request, you may appeal by writing to Freedom of Information Act Appeal, Office of the General Counsel, Federal Trade Commission, 600 Pennsylvania Avenue, N.W., Washington D.C. 20580, or by facsimile at (202) 326-2477 within 30 days of the date of this letter. Please enclose a copy of your original request and a copy of this response. If you have any questions about the way we have handled your request or about the FOIA regulations or procedures, please contact James Witherington at 202-326-3661. Dione J. Stearns Assistant General CounselPeterson, Mark D. Card - 2013-0/22% Peterson, Mark Do AEB From: Apache server ‘Sent: ‘Tuesday, August 06, 2013 1:55 PM name = Henry Becker RECE a a ie city ‘Southlake AUG 86 2013 sete ° faxno email coinfo = Herbalife-I would like a list or simply the number of complaints filed against this company in the past 5 years. 1 would also like to know the number of support letters you have received on Herbalife's behalf. Thank you very much for your time. describe = Individual EdSciName privatelawname = medianame = money = Contact me if above $200 Bis = SubmitUnited States of America FEDERAL TRADE COMMISSION WASHINGTON, D.C. 20580 He Becker See Aug 16 avis Re: FOIA-2013-01228 Herbalife Dear Mr. Becker: This is in response to your request dated August 06, 2013 under the Freedom of Information Act seeking access to the number of complaints filed against Herbalife along with the number of support letters received on Herbalife’s behalf in the last 5 years. In accordance with the FOIA and agency policy, we have searched our records, as of August 06, 2013, the date we received your request in our FOIA office. ‘We have located 1 responsive records. You are granted full access to the responsive records, which are enclosed. Based on the fee provisions of the FOIA, 5 U.S.C. § 552(a)(4)(A), and the Commission's Rules of Practice, 16 CFR § 4.8 et seq., as amended, I am also enclosing an invoice for the charges we incurred for this partial response to your request. Failure to pay this bill promptly will result in our refusal to provide copies of accessible documents in response to future requests. If not paid within 30 days, this bill will accrue interest penalties as provided by Federal Claims Collection Standards, 31 C.F.R. § 900-904, as amended. If you are not satisfied with this response to your request, you may appeal by writing to Freedom of Information Act Appeal, Office of the General Counsel, Federal Trade Commission, 600 Pennsylvania Avenue, N.W., Washington D.C. 20580 or by facsimile at (202) 326-2477, within 30 days of the date of this letter. Please enclose a copy of your original request and a copy of this response. If you have any questions about the way we are handling your request or about the FOIA regulations or procedures, please contact James Witherington at 202-326-3661. Assistant General CounselSearch Results Page bof | we ee “ atte % ere sae Steousuwes 2 BE ENTINE ero: sf eee Une raeevi one retin MURR ESSTGLEE? gabe OEEHTEISE Pe taetins 238 Search Results sien ie iste say tatoo ena Darrel SSSA Oia al atom crasicna nda Gherncou toes home laulone kas Prine bateiz0' “Hemi interaalonel Of America, lnc. ‘Heroalfe intima onal Of Ameen Herat iternavona OF Aenarica oe ‘Onine Business Syston /nersalts 38 Herbalife ind, Dist patica Maina 2 [a Horbatfe OF Caneda Lie, 2 1B” Mahisbeam Nulnion Chab ~Uerbaile @ 16 E Homa 4 ‘Global Media Sohations 8 ao ca ae eM tts. consmmersentinel.gov! fayouts/Print TVSearchResults.aspx. 2013Kelly, Andrea, From: ‘Apache httpd Sent: Monday, August 12, 2013 1:56 PM FOIA - 2012- 0 ‘ny = home r “3s OLAS staddr = 3 times square FEDERAL TRAD sth city new york |ECE state ny avg 12 zipcode 10036 2 telno = Abrahamian faxno = email atossa.abrahamian@thomsonreuters.com coinfo = Dear FOIA officer,1'm writing to request records of all communication (emails, letters, call logs, text messages, etc) on the subject of the direct-selling nutritional company Herbalife between the FTC and the following ‘groups or individuals:a. New York hedge fund manager William Ackman and all individuals working for or associated with his firm, Pershing Square Capitalb. Representative Linda Sanchez (D-IL)and anyone working for her or with herc. The National Consumer's Leagued. The Hispanic Federatione. Herbalife or any firms or individuals acting on behalf of Herbalife. This includes the P.R. firm Joele Frank, the company's Board of Directors, any major shareholders in the ‘company, and investor Carl Icahn.Kindly expedite this request for news purposes. Given all the noise and uncertainty the media about Herbalife's products and business model, as well as the infighting among investors, we believe a greater understanding of the FTC's actions with regard to the company are of great public interest.Call anytime if you have questions.Thanks,Atossa Abrahamian EdSciName = privatelawname = 3 times square describe News Media medianame ‘Thomson Reuters ‘money Contact me if above $100 B13 SubmitUnited States of America FEDERAL TRADE COMMISSION WASHINGTON, D.C. 20580 Atossa Abrahamian Thomson Reuters 3 Times Square, 5 Hb auld New York, NY 10036 AUG 1b Re: FOIA-2013-01247 Herbalife Dear Ms. Abrahamian: This is in response to your request dated August 12, 2013, under the Freedom of Information Act seeking access to FTC correspondence relating to Herbalife that was released in FOIA 2013-01138. ‘We have located 269 pages of responsive records. I am granting partial access to the accessible records. Portions of these pages fall within the exemptions to the FOTA’s disclosure requirements, as explained below. ‘Some responsive records contain staff analyses, opinions, and recommendations. Those portions are deliberative and pre-decisional and are an integral part of the agency's decision making process. They are exempt from the FOIA's disclosure requirements by FOIA Exemption S5USC. § 552(b)(5). See NERB v. Sears, Roebuck & Co., 421 U.S. 132 (1975). If you have any questions about the way we handled your request or about the FOIA regulations or procedures, please contact James Witherington at 202-326-3661. CF Sind Assistant General Counsel Enclosed: CD RomPage | of 2 Federal Trade Commission 600 Pennsyivania Avenue, N.W. Washington, DC 20580 x Organization Logo Report Date :07/22/2013 Time :11:40:08 AM Requests Report Received between 01/01/2012 and 07/17/2013 Select Options Group By - Sort By Request ID ( Ascending) Fiter ay Received Mode 2 all Review Status Pall Deseription/Sub Request 2 *Herbalife® Requests handled by (Action Office) = HQ) Action Oifice (Request) all Select Fields Request 1D Received Date Requester Name Requester Category Organization Request Description Requestzo | ReceNed | Reauesrer | Requester | organization Request Description Fova-2072-00806 parie/2072 Frayter, News Media NBC evbaire Fou zo1z-o11a7 priero12 Private FE Herbalife intemationa, Ine. [ncividual FoR 202 o1ese Par 72072 RB pre F ierbalfe individual FOIk-2073-00280 272672072 [relarier, News Media New Vork Post Fevbalfe FOTA-2073-00321 9170972013} F ‘onsumer Camplaints rez lerbalife FOIA-2073-00339 01/14/2013 Jacobovitz, Commercial (Capstone LLC Herbalife (organization FOIA-2073-00341_o1/1472013, Private E Herbalife individual FOIA-2013-00376 fI/i7/2013, Private F ierbalife International dividual FOIA-2073-00398 01/25/2013 [Law Firm Height Analytics Herbalife, etc FOIA-2073-00416 )01/2972013 Bole, Andrew [Commercial [Esopus Creek Herbalife [organization [Advisors FOTA-2073-00417 01/29/2013 Paftary, Krish|commercial New Mountain Herbalife ganization __|Capital \ForA-2073-00426 11/30/2013 avis, Peter News Media |The New York Herbalife Times FOIA-2073-00428 01/30/2013 fang, Carol_News Media jdealReporter_ Werbalife FFo1A-2013-00434 01/31/2013 [celarier, News Media |New York Post Herbalife ichelle FOIA-2073-00436 1/31/2013 Wise, Aubrey [Commercial [One East ierbale [organization [Partners hitos://foiaxpress.fic.nov/folaxpress/Reposta/Costom/afkPriniCustomizedRenorteapx?bipei.... /222013.Page 2 of 2 Jrota-2013-00456 12/04/2013 pier, Jason [Commercial _flanie Capital Herbalife, Avon, and GNC [organization FOTA2073-00084 2707/2073 elarer, News Media New York Post Perbalie Investigations ichelle FOUA201S-00568 22772073 Polley, ——ftaw Frm Bullvan & Plerbalfe Lead Generation Firms even [Cromwell LP FOTA2075-00780 4705/2075 Wise, Aubrey [Commercial [One East Herbalife lorgenization Partners Frora-2013-007a1 4710/2073 [eavis, Peter ens Media [The New York — flerbalife records from FOIA- [Times bo13-00568 FOWA-2013-00752 PariS/2073 pluchanie, — [law Fm Height Analytics Perbalfe nstine FDIRzoTsa07es Parior0Ts potey.__fawtim Bulan & Harolfe tad Generaon Fs even [eeomivell LLP Fo1A-2073-00827 4725/2013 Sampson, [aw Firm Hunton & Herbalife International Inc,, iyle fitliams: telaleuca, Inc., Puritan's Pride, nc, etal FFo1a2075-00849 5706/2073 Levine, [Commercial Sores Fund Herbalife fashall__[Organization Management FOW-2073-07002 8711/2073 fcelarier, News Media New York Post Hierballfe Lever ichelle FOTA 2013-07086 [7022073 Polley, flaw Frm Bulivan & Herbalife datibutors, ta) ven [cromivell LP ForRzoTs-o1s8 prniTaoTs Private F Ferbalve, al dividual bitpe:/ffoiaxpres ‘Total No of Requests : 27 fic. zov/foinxpress/ReporteéChatons/atkPriniCustomizedReport:nwx bine... T222013138 19" Steat NW, Sute 1995 @ _ hispanicfederation ew vou 1006 Zax be bree eue oo Mots Get ecteas sine ‘wer hispanicfederation.org May 17,2013 FederalTrade Commission The Honorable Edith Ramirez Re cei ved Chairwoman MAY 28 2013 Federal Trade Commission 600 Pennsylvania Avenue, NW Chairwoman Ramirez Washington,DC 20580 Dear Chairwoman Ramirez: Since its inception in 1980, Hispanic Federation, has as its core mission to empower and advance the Hispanic community. It provides grants to aboard network of Latino non-profit agencies serving the most vulnerable members of the Hispanic community and advocates nationally with respect to the vital issues of education, health immigration, economic empowerment,civic engagement and the environment. ‘As part of our work on economic empowerment we have worked with small businesses to make them Viable and prosperous. We have worked with member agencies that provide loans to entrepreneurs who otherwise would not have the needed capitalto jump start their business dreams. We have offered seminars on mortgage assistance, development of credit and warned our community about amyriad of schemes created to defraud Latinos, especially the most vulnerable in our community. Through our financial literacy workshops, leaders in our network and some of our elected officials we have learned about the proliferation of get rich quick schemes that focus on Latinos and especially our immigrants. We write to you to urge the Federal Trade Commissionto conduct an investigation of the multi-level marketing company known as Herbalife. It is our understanding that the company's marketing materials promise richness for afew hours of work from home. You can imagine that for immigrants, particularly those who are underemployed or have no papers. this promise can seem like their ticket to achieving the American Dream. We understand, however,that when you add expenses to acquire the product, lists and marketing materials, most distributors appear to actually lose money. A particular concern to us about Herbalife is whether distributors make money selling products or recruiting others to selkproducts: The latter is an indicator of a pyramid scheme. Reading the recent debate on this issue;Herbalife's statements to explain its compensation structure are contradictory. We Urge you to focus on this issue:are distributors incentivized to sell product or to recruit new distributors into a pyramid.‘Through our work over 23 years we have learned that most mult-level marketing companies are legitimate businesses. They in fact compensate distributors for selling products. In fact, many of these ‘companies have provided new immigrants and other Latinos a real opportunity to move forward and earn a decent living for them and their families. From what we have learned about Herbalife, anecdotally and through our work,we have serious concerns about their business practices and we urge ‘you to look into this matter. ‘Thank you for your attention. Sincerely, wo 7 C Jose Calderon President Taking Hispanic causes toheartUNITED STATES OF AMERICA FEDERAL TRADE COMMISSION WASHINGTON, O-, 20580 Tune 20, 2013 The Honorable Linda T. Sanchez House of Representatives Washington, DC 20515 Dear Representative Sanchez: Thank you for your recent letter regarding your concems about Herbalife, Ltd.'s business practices. You noted the allegations raised by the National Consumers League and the Hispanic Federation that Herbalife is an illegal pyramid scheme, and requested that the Federal Trade Commission (*FIC” or “ Commission”) investigate the company. As you know, the Commission has been directed by Congress to actin the interest of all ‘consumers to prevent deceptive or unfair acts or practices, pursuant to the Federal Trade ‘Commission Act, 15 U.S.C. §§ 41-58. In interpreting Section 5 of that statute, 15 U.S.C. § 45, the Commission has determined that a representation, omission, or practice is deceptive if (I) it is likely to mislead consumers acting reasonably under the circumstances; and (2) itis material; that is, likely to affect consumers’ conduct or decisions with respect to the product at issue, ‘The Commission takes seriously the harm illegal pyramid schemes have on consumers and has used its authority under Section 5 of the FTC Act in appropriate cases. For example, since 1996, the FTC has brought 15 cases alleging that purportedly legitimate multi-level marketing companies were in fact pyramid schemes in masquerade. Most recently, the FTC filed a case against Fortune Hi-Tech Marketing, Inc. and related entities. See FTC v. Fortune Hi-Tech Marketing, Inc. et al., 13-CV-578 (N.D. Il. Jan. 24, 2013). The FTC alleged, among other things, that the defendants operated an illegal pyramid scheme and falsely claimed consumers would ear significant income for selling various products and services. In reality, the FTC charged that nearly all consumers who signed up with the scheme lost more money than they ever made. The FTC further alleged that to the extent consumers could make any income, it was ‘mainly for recruiting other consumers. In addition, just last year, the FTC won a vietory in another case: FTC v. BurnLounge, Inc. et al, No. 2:07-03654 (C.D. Cal. June 6, 2007). The FTC sued BurnLounge, Inc. and its top promoters for operating a deceptive pyramid scheme, making deceptive eamings claims, and failing to disclose that most consumers who participated in the pyramid scheme would notThe Honorable Linda T. Sanchez *, Page 2 - receive substantial income, but instead would lose money. More than 56,000 consumers fell victim to the scheme. In March 2012, a judge for the Central District of California entered a final judgment and order against BumLounge, Inc. and several of its promoters. The final order requires the defendants to pay close to $17 million for consumer redress. The final order also prohibits the defendants from engaging in pyramid, Ponzi, or chain letter schemes or any Schemes in which compensation for recruitment is unrelated to the sale of product to customers who are not participants. Among other things, the order also bars misrepresentations about multi-level marketing operations or business ventures. The case is currently on appeal to the United States Court of Appeals for the Ninth Circuit. Thave forwarded your letter to the appropriate staff in the FTC’s Bureau of Consumer Protection. In determining whether to take enforcement or other action in any particular situation, the Commission may consider a number of factors, including the type of violation alleged; the likelihood of preventing future unlawful conduct and securing redress or other relief; and the nature and amount of consumer injury at issue and the number of consumers affected. However, a number of statutory provisions and the Commission Rules of Practice prevent me from discussing what action, if any, the Commission may take in any particular situation, Complaints from consumers can provide valuable information that we frequently use to identify deceptive and unfair practices in the marketplace. Therefore, please encourage yout ‘constituents to file their complaints with the FTC, in English or in Spanish, by visiting the FTC’s online Complaint Assistant, available at htips://ficcomplaintassistant.gow/ or by calling 1-877- FTC-HELP (1-877-382-4357), T appreciate your concerns about this matter and your commitment to protecting all consumers, especially the most vulnerable in our population. If you or your staff has additional questions or comments, please feel free to contact me or have your staff contact Jeanne Bumpus, the Director of our Office of Congressional Relations, at (202) 326-2946. Sincerely, Cace_P ir Edith Ramirez ~5 Pe be oFrice: COMMITTEE On ETHICS Linda T. Sinchez 2479 RAYAURN BULOING nowt 38TH DISTRICT, CALIFORNIA coumarTee on MAYS AND MEANS: WaskincToN, pe 2031s Congress of the United States re oe oistRIcr office: 17906 cRUSADER AVENUE House of Representatives omisecme : 2219 8 5 8 Washington, DC 2055 se Beets he gor 14008387 g 3 S72 Edith Ramirez, Chairwomans aAvR Federal Trade Comission E28 600 Pennsylvania Avenue, NW Bai ‘Washington, DC 20580 eSB BN 38 2 2 June 5, 2013 Dear Chairwoman Ramirez: 1 am writing to express my concem about the marketing and business practices of Herbalife, Ltd In particular, I am troubled by allegations that this company may be harming consumers ~ especially those from our country’s most vulnerable populations. There have been extensive media reports and allegations about Herbalife’s business practices, ‘On March 12, 2013, the National Consumers League wrote a letter urging the FTC to conduct an investigation into the possibility that Herbalife is a complex pyramid scheme.' More recently, on May 17, 2013, the Hispanic Federation also wrote a letter urging an FTC investigation.’ Both groups have voiced concems over whether Herbalife’s distributors are primarily incentivized by recruiting others, or by selling the Herbalife product. Additionally, as the National Consumers League letter states, “Low-income consumers, as well as African-Americans and Hispanics, were found to be especially vulnerable to pyrami ‘business opportunities.”* -schemes masquerading as legitimate home-based {As Ihave learned more about this issue from my constituents and from outside groups, I believe it is the Federal Trade Commission's (FTC) responsibility to examine these allegations. Given the FTC's mission to investigate claims of fraud and potential pyramid schemes, I encourage you to investigate this matter. I have confidence that such an investigation will provide clarity to consumers and I expect you will aggressively pursue it in a timely manner. * sally Greenberg, National Consumers League to Edith Ramirer, Federal Trade Commission, 13 March 2023, http://www nelnet.org/images/POF/FTC%20Letters6200n%20Herbalife.pdf * Jose Calderon, Hispanic Federation to Edith Ramirez, Federal Trade Commission, 17 May 2013, bhutp://www seribd.com/doc/142602752/The-Honorable-Edith-Ramirez-FTC * Sally Greenberg, National Consumers League to Edith Ramiree, Federal Trade Commission, 13 March 2023, http://www nelnet.org/images/PDF/FTC%20Letter%s200n%20Herbalife.pdfIf I can be of additional assistance, please do not hesitate to contact Mike McGourty of my staff at 202-225-6676 or michael megourty@mail house.gov. Thank you for your attention to this important matter. Sincerely, Congresswoman Linda T. Sanchez Member of Congress (CA-38)March 2013 February 18, 2013 - sun tiweth f53 SoM uve Th FS a456783 3455785 February 24, 2013 Www Iss 141536 " DRBDARS iw as 24-2526 27 28 BERT BB Mon: 18 Tuesday, February 19 oye on ReSpONNE an Respotine Wednesday, February 20 Thursday, February 21 [Non Responsive [Ron Responsive Friday, February 22 Sunday, February 24 Greisman, Lois T TASIIONS 11:56 AMMarch 04, 2013 - March 10, 2013 March 20135 SuMo TuWe Th Fr Sa spit 2013 SuMo TuWe Th Fr Sa ia 123456 3455785 78 SnD 10112213 141516 141516 17 18 19 20 17 1819 20 212223 © 21 22 23-24 25 26.27 2425 26 7 282950 28.2930 Monday, March 04 Tuesday, March 05 on Responsive ZGOpm--F00pm Sullivan Be Cromwell represents Pershing Square; ‘Ackman et al want to meat with us -- call Christine at # below (Meeting wail beheld in 298) -Greisman, Lois C Ton Responsive Wednesday, March 06 on Respansive Friday, March 08 jan Raspanaive fron Responstve Saturday, March 09 [Ron Responsive Greisman, Lois T TASIIONS 11:56 AMMarch 11, 2013 - eee Sees March 17, 2013 Ce mee eee ae Monday, March 11 Tuesday, March 12 Wednesday, March 13 Thursday, March 14 pRorReSponse 10:00am - 11:00am Herbalife Conference Cal) - Todaro, Chvistine pm - 5:15pm Meeting: Herbalife (Chuck’s Ofice) - Harwood, Charles & Friday, March 15 Saturday, March 16 [Non Rosponst Sunday, March 17 Greisman, Lois T THaSIIOIS 1135 AMGreisman, Lois C Tuesday, February 05, 2013 11:59 AM Arnmertnan, Janet; Todaro, Christine; Vander Nat, Peter 1; Vaca, Monica € Subject: FW: Herbalife Attachments: Herbalife pat [cexe) From: Baker, Steven Sent: Thursday, January 10, 2013 2:23 PM To: Greisman, Lois C.; Vaca, Monica E, Cc: Kossow, Todd M.; Atleson, Michael; O'Toole, David A. Subject: RE: Herbalife Ge) Steve From: Greisman, Lois C. Sent: Thursday, January 10, 2013 4:21 PM To: Baker, Steven; Vaca, Monica E. Cc: Kossow, Todd M.: Atleson, Michael; O'Toole, David A. Subject: RE: Herbalife (eye) From: Baker, Steven Sent; Thursday, January 10, 2013 11:00 AM To: Greisman, Lois C.; Vaca, Monica £. Ce: Kossow, Todd M.: Atlesan, Michael; O'Toole, David A, Subject: Herbalife [coX5) Steve C. Steven Baker Director, Midwest RegionFederal Trade Commission 55 West Manroe, Suite 1825 Chicago, 1 60603, (312)960-5628Vera, Elena R. From: Vander Nat, Peter J Sent: Tuesday, January 15, 2013 1:04 PM To: Ippolito, Pauline M Subject: RE: Herbalife Tracking: Recipient Delivered: 1/25/2088 108 FMA Fppokt, Pauline Wa do what we can. Thanks too. From; Ippolito, Pauline M. Sent: Tuesday, January 15, 2013 12:00 PM To: Vander Nat, Peter}. Subject: RE: Herbalife Pater, Thanks for the quick response. Pauine From: Vander Nat, Peter J. Sent: Thursday, January 10, 2013 9:31 PM To: Greisman, Lois C. Cc: Ippolito, Pautine M. Subject: Herbalife Lois, Go)[yy Peter (Pauline, | am ce’ing you on this since the query to me was passed on through your email.)Vander Nat, Peter J Thursday, lanuaty 16, 2013 11:26 AM Ippolito, Pauline M Pappalardo, Janis K Re: Wall Street Erupts Over Charges of Multi-tevel Marketing Fraud ppolta, Pauline M hhursday, January 10, 2013 10:58 AM ander Nat, Peter J. "appaiardo, Janis K. Subject: FW: Wall Street Erupts Over Charges of Multi-level Marketing Fraud Peter, [(o5) Pauline From: Greisman, Lois C, Sent: Thursday, January 10, 2013 10:28 AM To: Ippolito, Pauline Mt. Subject: Fw: Wall Street Erupts Over Charges of Multi-level Marketing Fraud {stopped by before but you were not in. Can you give me a call when you return re below? From: PyramidSchemeAlert.org [mailto:info@pyramidschemealert,org} Sent: Wednesday, January 09, 2013 11:10 PM To: Greisman, Lois C. Subject: Wall Street Erupts Over Charges of Mutti-level Marketing Fraud ‘This Update is Available a5 a Webpaye for Linking Webpage Version of this update ee 3 Pyramid Scheme Alert Pyramid Scheme Alert is a non-partisan, non-profit, all-volunteer consumer education group. 1Contact Robert L. FitzPatrick, Pres. at info@pyramidschemealert Website Update - January 2013 Update Al Brevious ‘ditions Are Available for Viewing Herbalife is Focus Wall Street Erupts Over Claims of MLM Fraud Ater years of willful ignorance or neglect about a business sector worth $17 billion in stock value and that has solicited money from virtually every household in America, Wail Street has suddenly taken notice of multi-level marketing (MLM). One major hedge fund manager, William Ackman of Pershing Square Capital, has blown the whistle on one iconic member of the MLM field. Ackman charged that Herbalife international is not a business, but a harmful fraud. He charged that its true stock value is zero. Herbalife's stock quickly plunged inte volatility in the : ensuing debate. Wail Street Leader, Wiliam Ackman, Says Merbaiife Is an litegat Whatever this heated controversy brings forth, finally Pyramid Scbeme there is a teal focus on and investigation of what previously was kept in the dark. Those who had dared to raise questions were personally vilified or sued by MLM lawyers or even harassed by government regulators. The MLM industry is one of the largest influence-buyers and lobbyists in Washington. Ackmatn stated that his position against Herbalife is "patriotic" hased on the enormous harm that Herbalife does to the country and the public, especially those who are financially struggling. He has purchased a “short position (if Herbalife's stock value gaes down, he makes money) and he said he will donate all personal gains to charity. e William Ackman's in-depth analysis of Herbalife. What's Your Herbalife Story? Herbatife is at the center of headline news stories. Major investors are calling Herbalife a "pyramid scheme” and 2 money trap. The news media are investigating. You can help regulators, attorneys, and investors better understand this controversial company by adding your experience and opinion. Please let us hear from you,+ Are you an Herbalife distributor? Supervisor? + Have you ever been involved in Herbalife as a distributor in the past? + Did you personally retail the products? Did you recruit others to jain up? mat Us Your + Did you try to sell or recruit and but were not Herbalife Story successful? Why? + Did you make a lot of money? Lose money? + Did you buy "leads"? Go to conferences? + Why did you join up? Make money? Retail products? Get the products yourself at a discount? + Are you stil buying the products even if you are no longer a distributor? + Would you recommend others to join up too? Email us with your story, comments, thoughts. Your voice makes a difference! SEC Staff Reportedly Opens Investigation of Herbalife fa morney ain The business media is reporting that the staff of the U. Securities and Exchange Commission, the watchdog over the stock matket, is opening an investigation of the multi-level marketing company, Herbalife. Hedge Fund manager, William Ackman of Pershing Squarte, publicly laid out charges against Herbalife, which | may have prompted the investigation. Earlier questions, claims and complaints about deception and fraud from consumers, a Belgian court ruling that Herbalife is an legal pyramid, two class action lawsuits against Herbalife for fraud, and the findings of other fraud investigators, regarding Herbalife have been ignored by the SEC and FTC. Among the charges made by William Ackman: + Herbalife is an unsustainable pyramid scheme in which funds are gained by constantly recruiting salespeople + Salespeople are the main source of Herbalife's sales, not consumers. + Herbalife's products - diet shakes - are purchased because they are bundled with a deceptive income promise. Standing alone, the products are over- priced, unknown and unadvertised and are no different from many other less- expensive and more conveniently available products. They would not sel without the income scheme attached, + Virtually no one whe signs up under Herbalife's pay plan ever makes a profit + The commissions on saies to the new recruits are transferred and concentrated to a tiny few at the very top. + Most people fail and quit the Herbalife scheme in tess than a year, after suffering financial losses, but are convinced that their failure is their own fault, not that of the flawed and deceptive scheme. 3Business Media Investigating MLM Stock analysts, business writers and television financial networks are focusing on MLM. They are going undercover to MLM recruitment meetings. They are looking at MLM payouts, interviewing distributors and asking the big question, where does MLM money came from, distributors or end-user reail buyers? Retail defines a sales company, recruiting distributors is the hallmark of an “eridiess chain" fraud, Business Media have seen that MLM deception, secrecy and manipulations are bad for Wall Sireat. Will the mainstream media recognize the harm to Main Street? CNBC Documentary on MLM: "Seffing the American Dream" Click on the Image to See the Documentary Donations Make It Possible a] Pyramid Scheme Alert is all-volunteer and non-profit, but it stil has many costs to maintain its website, to help with lega! detense, publicize its research and analysis and to assist thousands of individuals worldwide. PSA's costs are covered by contributions from courageous private citizens. You can support PSA's work by making a donation. Special Reports for Consumers. What About This Gne? Now Available! Free! The new audio and written report published by Pyramid Scheme Alert is the product of years of research and direct experience of analysts, former insiders of multi-level marketing companies and veterans of direct selling. The audio is a down- to-earth, conversational dialogue. that hits the key points for evaluating ciici-an ahe income opportunities and avoiding pyramid scams. The companion written age © report outlines the information for easy reference. tone This One? The Main Streer Bubble: (free) The financial bubble is composed of inPage | of 16 Untitled Page Svonetven 2 “SENTINED=eor« ew eforcoment s snurce for consumer complaints SPRINT Consumer Sentinel Network Complaints. k Compl Originator Language: English ‘Source: Consumer ‘Comments: I contacted a rep from herbalife to find out more about compary. | told them | wanted to knaw more a out ‘company She gave me background information and asked me how | wanted to pay | told her I didnt have a ‘reait card with me she insisted she wil pat with her car and I could right her a check. She leit out major details | had to find out myself such as yearly fees the cost of website she also claimed a25 discount, yet ater tax and shipping eat up discount its not worth it. called an hour after | let, asked her to cancel and was tod its non Fetundable | researched the company and tound similar stories to mine although | cidnt invest a lot ot money . | was told produats are reundable so why isnt thatthe caso. | fee! she left out a great detail of cost promised a 25 Prevent discount tha s taking by taxes and shipping . Most importantly an hour after handing her a check | was {oid its non refundable . So now | wish not to deal with company at all and wish to have money returned ‘Was the complaint resolved’ Data Reference: Entered By: FTCCIS-FTCUSER Entry Date: 3/28/2013 Updated By: Updated Dat ‘Complaint FTC Oniine Complaint Assistant (CIS) Product Service Health Care: Dietary Supplements\Herbal 4 Code: Remedios '368.00 Payment Check ‘Agency iniemet Method: Conta ‘Complaint 3728/2013 ‘Transaction 2/27/2013 Boe! wa tla Comat Vaied Gorin ita in Person respon Sine Re: Nala Telephone Wechanse Oder Fle | Law Vitalon: Never Recied Wachandsa Terie Oigut wih cre urea Teepe esos sassclon Heme fe aimed rosa ean a ER mar Caraaing compar Last ame: | St bites: fwww.commexseniine. pov. layoute/PtiniitecandD cinils. aexxocumeniNambe=:.. “F/i8/2013.Untitled Page Miltary Service Branch: Soldier Station: : Herbal Lite Subject iD Issuer State: Representative Jessica Willams Name: bites: dwww.comeexneniine poe! layouls/PtiniitecundDcinjls nen MdocumentNambe: Soldier Status: Subject State/Prov: Country: United Statos URL: Www. herbalife.com Title: Supervisor Page 2 of 16 TN8/2013Untitled Page |Record #97 Consumer Sentinel Nowork Complaints Reference 43614109 ‘Number: Language: English Source: Consumer ‘Comments: Consumer claims she received a telemarketing ise, offering their services. Consumer has req tails continue. When Consumer stayed on thei Fogistered on the DNC registry. Consumer was ‘Was the complaint resolved?: Data Roferenc Entered By: BARRIOS Updated By: DBARRIOS Page 3 of 16 Originator Reference Number: | Contact Type: Complaint L Nc? ¥ call from a Herbal Life representative, ooking or somebody vested them to remove her number from thelr calling lists bul the ine to speak to someone, they cursed at her. Consumer is. referred Io local AG. [Entry Date: 27142018 | Updated Date: 21472019 ‘Complaint FTC Call Center Product Service Telemarketing, Other Code: Source: ‘Amount $0.00 ‘Amount Paid: $0.00 Requested: Payment Unknown ‘Agency Phone Method: Contact! ‘Complaint 2714/2013 Date: “Transaction 9/12/2012 Da I Contact: Phone Call: MobileiGall ‘Statute/Rule: Telemarketing Sales Puls Initial Answer cold cal Response: Law Violation: TSR: Threais, improper language TSR: DNG: Ignoring Your Prior Request to that Specter "8A BNC Volaing the Roi opie: Boot Gall | blapute wih ‘crodt Bureau”. Dispute with N Dispute with N creat Bureau crea Bureau” espana? esolved to satistocto Member at No armed trees ot epondont, Consumer information Consurer Complaining | Last Name [Address 2: T South Caoina | UwTeD states | Work Number: | ext ge Range: 80-38 iia Serie Soller Status: Solder Station: Subject ‘Subject: Herbal Life ‘Area Code: 702 bites: fwww.comeexneniine poe! layouts/PtintitecandDcinils. nen documentNambers TN8/2013Untitled Page Ext: Subject ID Issuer State: Representative Name: bites: fwww.comeexseniine. pow! layoute/Etiniitecandi ctails. 20x MdocumeniNamnte Subject iD ‘Type: Subject iD Issuer Country: Tile: Page 4 of 16 TN8/2013Untitled Page |Record # 10 / Consumer Sentinel Notwork Complaints Reference 43461473, ‘Number: Language: Source: ‘Comments: Was the complaint Entered By: FTCCIS-FTCUSER Updated By: ‘Complaint FTC Online Complaint Assistant (GIS) ‘Source Engish Consumer Page 5 of 16 Originator Reference Number: |Contact Type: Complaint I DNC? N My complaint isthe way thal they use dubious language to advertise joining their business. There was never any mention ofthe fact thatthe company is Herbal Life. It's referred to a& an"On Line Business System". | thought that | was going to jin an on line business doing things on line Alter had paid my money, then listened to @ Telephone orientation that then mentions Herbal Life.Had | known this upfront, | never would have paid the money Here is thelr web address, tp:monicahyat.heonlinebusiness.com ‘Amount $389.00 Requested: Payment Crecit Card Method: ‘Complaint 26/2013 Date: Initial Contact: | Iniiated Contact ‘Statute!Rule: FTC Aci Soc 5 (BCP) Topic: Dispute with Complaint Resolution: ‘Agency Iniemet Contact: ‘Transaction 12/20/2012 Da Initial Internev=-mall Response: |" Law Violation: DeceptioniMisrepresentation | Dispute with ‘Credit Bureau?: Dispute with Credit Bureau - Resolved to Satistactio Member of No armed forces or lepondnt ‘Consume information Consumer Complaining Company/Org: First Nam [cast ware: RSI] Address 1: | Address: City: Hemet | ‘Stat > Pa] County: UNITED STATES Home Number: Work Number: Fax Number: oat tary Service Soldier Stat ranch: Soldier Station: ‘Subject: Herbal Life Gio Scott And Monica Hyatt Subject ‘State/Prov: Ontario, Canada Country: Canada [ [ I URL: 4 ‘Area Code: 877 Phone Number: 7539234 Ext: Subject ID ‘Type: bites: dwww.comeexneniine poe! layouls/PtiniitecundDcinjls nen MdocumentNambe: TN8/2013Untitled Page Page 6 of 16 Subject ID Subject ID Issuer State: Issuer Country: Representative Scott Hyatt Title: Unknown ‘Name: bites: fwww.comeexseniine. pow! layoute/Etiniitecandi ctails. 20x MdocumeniNamnte TN8/2013Untitled Page |Record # 11 / Consumer Sentinel Notwork Complaints Reference 43417404, ‘Number Language: English Source: Consumer ‘Comments: The consumer got involved in stocks, and notices comply Was the complaint resolved?: Entered By: JGOSBY Page 7 of 16 Originator Reference Number: | Contact Type: General Complaint L DNC? N ed stock called Herbal Life is false. The consumer did not Updated By: ‘Complaint FTC Gall Cenior Product Service Other (Noe in Comments) Source: | Code: ‘Amount $0.00 ‘Amount Paid: $0.00 Requested: Payment Unknown ‘Agency Phone “Method: contact! ‘Complaint 27472013 “Transaction 11/1/2012 Date: Da Initial Contact: in Person Initial Unknown |__ Response: Law Violati ‘Other (Note the Violation in the Comment ‘StatulefRule: FTC Aci Sec § BCP) Fe) Tople Dispute wih ‘credit Bureau? Dispute with N Dispute wth N Credit Burea credit Bureau ~ esponded?: Resolved to Salstacton?: Member of No armed forces of ‘ependent?: ‘Consumer Information Consumer Complaining companyiorg: | | | State: [—Gountry: UNITED STATES | Work Number: Miltary Service Branch: Soldier Station: ‘Subject: Herbal Life ‘Address: City: ZP: Email: ‘Area Code! Ext ‘Subject ID Issuer State: a a United States TN8/2013 econ cinils. nex MdocemeniNumbe:Untitled Page Page 8 of 16 Representative Bill Ackman Title: Name: hitee/wwo.comeeenl TN8/2013 nel. eow/_layouts/PrintitecondDctails.aeox tiocamentNiumbeUntitled Page Page 9 of 16 P Identity Theft Comp! (Record ¥8 dently The Complaints ts FIC Reference 44020900 Contact Type: Compiaint Originator ‘Number: Reference ‘Number Complaint FTC Online Complaint Source: Language: English ‘Source: Assistant (DT) ‘Agency Contact internet Entered Date: 3/6/2013 6:49:07 AM Eniored By: FTOCIS FTCUSER Method: Complaint Details Verified 107 Updated Date: Updated B Comptaint?: | ‘Number of First Occurred 8/4/2012 First Noticed ‘Accounts, Date: Date: 6/13/2012 Atfected: Total Amount Total Amount Theft Via Yes Obtained Lost. Internet: by Subject by Victim: Did You ‘Are You Receive Any Willing to ‘Anyone Benefits?: Press to Use Your: Charges?: 10? : Tnacourate CHASE FINANCE Inacourate CITIBANK Inacourate UPS FEDERAL CREDIT Credit Report Credit Report Credit Report UNION Info.t: Info.2: | Into, Credit Inquiry HAIR MASTER Credit inquiry 09/11/1969 Credit Inquiry 13408 DESMOND ST, 1 2 = PACOIMA, CA 91331 Member of No DDeniad Credit or Other Financial Servicos (Other (Gescribe in comment fel) Harassed by Debi Collector or Creditor MY US POSTAL MAIL WAS CHANGED TO AN ADDRESS WHERE | DO NOT RESIDE. | CANNOT GET. INTO MY BANK ACCOUNTS EMAIL AND ONLINE ACCOUNTS AND MY INFORMATION CHANGED. MY AOL| WAS TAKEN OVER THROUGH PARENTAL RIGHTS, GABLE ACCOUNTS OPENED IN MY NAME. ‘Comments: |EDIT UNION ACCT I WAS LIVING A |SAN GABRIEL nN ‘S MY PHYSICAL. ‘ADDRESS CHANGED TO HER PHYSICAL ADDRESS @| PACOIMA, CA. SHE TOOK (OVER ALL MY BANK ACCOUNTS, IN JULY AUGUST ANO SEPTEMBER OF 2011 SHE WROTE CHECKS IN MY NAME TO WALGREENS, SO CAL GAS CO, HOME SHOPPING NETWORK AND WELLSFARGO THAT WAS OVER 3,000.00 PLUS OVER DRAFT FEE'S. SHE ALSO HAS USED HER FAMILY MEMBERS NAMES. "TO MAKE FAKE ACCOUNTS TO GO ONLINE TO HARASS ME BY SENDING EMAIL MESSAGES TO AGGRIVATE ME. BY TAKING MY MAIL SHE WAS ALSO ABLE TO GO AND HAVE HERSELF ADDED TO MY ‘AUTO INSURANGE THROUGH METLIFE AND I HAVE A BILL IN COLLECTION FOR 500.00. SHE WENT ON MY UPS FEDERAL CREDIT UNION BANK ACCOUNT AND WENT ONLINE AND RESIGISTERED MY ACCOUNT WITH HER INFORMATION OF HE! ‘ALL PASSWORDS AND. NOTIFICATIONS ARE FORWARDING TO HER| ‘5 PER CUSTOMER, REPRESENTATIVE AT THE CREDIT UNION PI MENT WITH HER INFORMATION ONT TRAN A GREDIT ci |ACK ROUND CHRgpik AND IT STATED PROPERTY FOUND IN MY NAME ANI INO HER SISTER! ARE REALTORS ‘SO | AM CONCERNED AS TOF STIONS AND HER ILLEGAL ACTIONS AS TO MY IDENTITY THEFT, ‘Additional Comments: Last Nam Middle ‘Address 1: Gily: BLOOMINGTON StaieProvince: Calflora bites: fwww.commexseniine. pov. layoute/PtiniitecandD cinils. aexxocumeniNambe=:.. “F/i8/2013.Untitled Page Page 10 of 16 courey: UNTEDSTATES | Uved Here 12012 ores aon Stee Licwneat oTenes os Work Phone ome Cane ne Cell Number: Pay Email: ina Sven Solder act = Soule a Eipest ‘ns Fc fa Ting wise Name(s): Name(s) Name(s): Company Name(s); jndependant Herbal Life Distributor aero area ca Fecara pois State: 7 Country: United States erate Taare was a ae ae a er To | — ead Talanstip: fies Kaun Agata wor Tavaaen | — Weed ot TE WEES ators a rene SoraningDeSimOWNG uy fe ON, Green eee ee ‘CONTROL OF MY BANK ACCOUNTS. RECEIVE (CABLE AND. PURCHASED PROPERTY| INMY NAME AS WELL A. Incidents incident Theft Type: Intemot or E-Mail- Internet Account | Date of 8/4/2012 Takeover Thett: [Associated institution Name: AMERICA ONLINE Type: Senice Provider ‘Address 1: 22000 AOL WAY ‘Address ‘Slate: Virginia ‘Country: UNITED STATES Email: CUSTOMERSUPPORT@AOL.COM URL: WWW.AOL.COM Notified?: Written Notified?: Law Enforcement Contact ‘State/Province: Person: bites: fwww.commexseniine. pov. layoute/PtiniitecandD cinils. aexxocumeniNambe=:.. “F/i8/2013.Untitled Page Page 11 of 16 Phone: Notified Law No Report Number: Entorcement?: Report Report Taken Number: Date: ‘Credit Bureau CB 1 - Name: Notifieg?: Fraud Alert on Credit Report File?: Ordered?: Have Violation(s) Dispute?: P Do Not Call Complaints [Rocord #1 /Do Not Cal Complaints ] Reference 46920137 | Peng njves Number: Registry?: ‘Complaint 7/2/2013 Product Service National Oo Not Gall Registy Date: ‘Codk ‘Complaint National Do Not Call Registry ‘Complaint iniemet Source: Channel: ‘Transaction 7/2/2018 ‘Transaction 1:00.00 PM Date: Time: Existing No Business Rolationship?: Requested No contity to stop calling?: ‘Comments: Calla siaied they were with Herbal Life and when advised that have never done Business with them che said well "you were selectee™ Advised callr that I was onthe federal donot eal registry and she hung up. aur nano TT] | Address | State/Prov: Oklahoma eee subj Company Fea Le aa RR mt Coan os [Phone aor) 26 bites: fwww.commexseniine. pov. layoute/PtiniitecandD cinils. aexxocumeniNambe=:.. “F/i8/2013.Untitled Page Page 12 of 16 (Record #2 /Do Not Call Complaints Reference 45888551 Is Phone in Ves, ‘Number: Registry?: ‘Complaint 7/1/2013 (oe ‘Service National Do Not Call Registry Date: ‘Complaint National Do Not Gal Registry Compan ene! ‘Soures Channel: “Transaction 7/1/2013 ‘Transaction 2:00:00 PM Date: Time Existing No re-recorded No Business ‘message?: Relationship?: Requested No entity to stop calling? ‘Comments: gota call, they had my name, asked i| wanted "male enhancement products” and I said no. Asked tobe taken ff thei st, But he insisted on asking me more questions Consumer {California (916) 4680185 bites: dwww.comeexneniine poe! layouls/PtiniitecundDcinjls nen MdocumentNambe: TN8/2013Untitled Page Page 13 of 16 (Record #3 /Do Not Call Complaint Reference 45952548 Is Phone in Ves, ‘Number: Registry?: ‘Complaint 5/15/2013 (oe ‘Service National Do Not Call Registry Date: ‘Complaint National Do Not Gal Registry Compan ene! ‘Soures Channel: “Transaction 5/15/2013 ‘Transaction 7:00:00 PM Date: Time Existing No re-recorded No Business ‘message?: Relationship?: Requested No entity to stop calling? ‘Comments: | was called and no one answered after calling me. I called the number back to find out who called and she said ‘Susan fom Herbail Life. | asked to be removed from her ist, | did not have any association with Herbal Life. She hung up on me with no comment. When I called back someone answered in Spanish. | communicated that ‘Susan called and | wished to be removed from her calling ist. He said okay. Coreuner reo ast Nae ip [Address 2: a |__ State/Prov: California Phone Numbe sume Company ral il ra Country Cod [Phone Numbe bites: dwww.comeexneniine poe! layouls/PtiniitecundDcinjls nen MdocumentNambe: TN8/2013Untitled Page Page 14 of 16 ~ Is Phone in Ves, Regi ‘Complaint 4715/2013 Product Service National 00 Not Gall Registxy Date: ‘Cod ‘Complaint National Do Not Gal Registry ‘Complaint internet ‘Soures Channel: “Transaction 4/15/2013 “Transaction 10'00:00 AM Date: Tim Existing No re-recorded No Business ‘message?: Relationship?: Requested Yes entity to stop calling? ‘Comments: This is a business and we received a call and they hung up. | called them back and asked to be put on do not tall lst. They hung up. | called back and asked tobe put on the do not eal ist and Allen just kept talking I Told him twice and hung up on them. = [Last Nam | Address ho sate pay ‘hone nur: [St] mee ‘Company Herbal Life?? [ [Louisiana Phone Number: (504) 3024505 bites: fwww.commexseniine. pov. layoute/PtiniitecandD cinils. aexxocumeniNambe=:.. “F/i8/2013.Untitled Page Page 15 of 16 Is Phone in Ves, Regi ‘Complaint 3722/2013 Product Service National 00 Not Gall Registxy Date: ‘Cod ‘Complaint National Do Not Gal Registry ‘Complaint internet ‘Soures Channel: “Transaction 3/22/2013 “Transaction 10'00:00 AM Date: Tim Existing No re-recorded No Business ‘message?: Relationship?: Requested Yes entity to stop calling? ‘Comments: This company is absolutely harassing me, they challenged me fo come to ther office personally if wanted 10 stop receiving calls and antagonize me, unuiling to take me off their ist or slop calling me early in the AM, or at all. contacted the company’s support line and they told me there was nothing they could do te help but agreed |uitn me that | am being harassed. I believe this branch is located outside of Walden, CA. | oe Name City: Santee | Ez Phone Numbe Subject ‘Company Herbal Life Name! Country Cod [Phone Numb bites: fwww.commexseniine. pov. layoute/PtiniitecandD cinils. aexxocumeniNambe=:.. “F/i8/2013.Untitled Page Page 16 of 16 (Record #7/Do Not Call Complaints Reference 44733303 ‘Number: Complaint 3721/2013 Date: ‘Complaint National Do Not Gal Registry ‘Soures “Transaction 3/21/2013 Date: | Existing No Business Relationship’ Requested No entity to stop calling?: Is Phone in Ves, Rogistry?: Product Service National 00 Not Gall Registxy ‘Cod ‘Complaint internet Chane ‘Transaction 1:00:00 PM Time: re-recorded No ‘message?: ‘Comments: ‘This number calls and never leave's a message. lis someone named Olga Consumer Last Name: Not Provided ‘Address ‘State/Prov: indiana [Diga Kirsanova Herbal Life ‘State: Michigan Phone Number: (283) 4952558 bites: fwww.commexseniine. pov. layoute/PtiniitecandD cinils. aexxocumeniNambe=:.. “F/i8/2013.FORTUNE. HI-TECH MARKETING Side-By-Side: A Comparison of Fortune Hi-Tech Marketing and Herbalife March 14, 2013 we “ Pershing Square Capital Management, L.P. &Disclaimer Pershing Square Capital Management, LP. ("Pershing Square") is an investment adviser to funds that are in the business of buying and selling securities and other financial instruments. Porshing Square currently has a short position in Herbalife Ltd. ("Herbalife") common stock. We do not own any options on Herbalife common stock. Pershing Square will profit if the trading price of Herbalife common stock declines and will ase money ifthe trading price of common stock of Herbalife increases. Pershing Square may change its views aboutoor its investment positions in Herbalife at any time, for any reason or no reason. Pershing Square may buy, sell, cover or ‘otherwise change the form or substance of its Herbalife investment. Pershing Square disclaims any obligation to notify the market of any such changes. ‘The information and opinions expressed inthis presentation in Pershing Square's “Who wants to be a Millionaire?” and on the website vw. facisaboutl {the “Presentation”) is based on publicly available information about Herbalife. Pershing Square recognizes that there may be non-public information in the possession of Herbalife or others that could lead Herbalife or others to disagree with Pershing Square's analyses, conclusions and opinions. ‘The Presentation includes forward-looking statements, estimates, projections and opinions prepared with respect to, among other things, certain legal and regulatory issues Herbalife faces and the potential impact of those issues on its future business, financial condition and results of operations, as well as, more generally, Herbalife’ anticipated operating performance, access to capital markets, market conditions, assets and liabilities, Such statements, estimates, projections and ‘opinions may prove to be substantially Inaccurate and are inherently subject to significant risks and uncertainties beyond Pershing Square's contro. Although Pershing Square believes the Presentation is substantially accurate in all material respects and does not omitto state material facts necessary to make the statements therein not misleading, Pershing Square makes no representation or warranty, express or implied, as to the accuracy or completeness of the Presentation ‘or any other written or oral communication it makes with respect to Herbalife, nd Pershing Square expressly disclaims any liability relating tothe Presentation or ‘such communications (or any inaccuracies or omissions therein). Thus, shareholders and others should conduct their own independent investigation and analysis of the Presentation and of Herbalife and other companies mentioned. ‘The Presentation is not investment advice or a recommendation or solicitation to buy or sell any securities. Except where otherwise indicated, the Presentation ‘speaks as of the date hereof, and Pershing Square undertakes no obligation to correct, update or revise the Presentation or to otherwise provide any additional ‘materials. Pershing Square also undertakes no commitment to take or refrain from taking any action with respect to Herbalife or any other company. ‘As used herein, except tothe extent the context otherwise requires, Pershing Square includes its affiliates and its and their respective partners, directors, officers and employees,Introduction > The following comparison of Fortune Hi-Tech Marketing (“FHTM”) and Herbalife (“HLF”) is based upon our review of the following source documents from the FTC’s recent legal action against FHTM: The transcript of the press conference announcing the legal action Complaint, filed Jan. 24, 2013 The memorandum in support of plaintiffs’ ex parte motion for a TRO The FTC’s press release The Declarations of Dr. Peter J. Vander Nat, Roberto C. Menjivar, and Kaitlin A. Dohse The report of temporary receiver's activities > All quotations applicable to FHTM in the following pages come from one of the source documents listed aboveMission Statements F@RTUNE. ECH MARKETING | “The mission of FHTM isto _ enable and transform the lives of __ many by offering outstanding products and services through _ the best opportunity in direct selling” _ “Herbalife’s mission is to chang © HERBALIFE people’s lives by providing the best business opportunity in direct selling and the best nutrition and weight-manageme products in the world”Overview P@R TUNE. Hl=TECH FHTM bills itself as “the business model of the 21* century” and | promises its recruits vast sums of | money, but it really distinguishes itself i in only one important way: _ the overwhelming majority of recruits make nothing at all i In its decade of operation, FHTM has caused hundreds of thousands of consumers to suffer harm of hundreds of millions of dollars © HERBALIFE Herbalife bills itself as ‘the best business ortunity on the face of the earth” and promises its recruits vast sums of money, but it really distinguishes itself in i only one important way: _ 88% of distributors receive $0 in “gross compensation” (before expenses) In its decades of operation, HLF has caused millions of consumers to suffer harm of billions of dollarsOperation of a Pyramid Scheme F@RTUNE. HI-TECH MARKETING “FHTM is an organization in which the participants obtain their monetary rewards primarily from recruiting new participants into the business venture and not rom seling goods and services to the public” “Upon applying the citical consideration ofthe Kascot test, there is only an incidental and de minimis relationship between recruitment rewards, paid to participants and product sales to non-partcipants” “FHTM does nat enforce, nor have in place, procedures that would ensure any meaningful amount of retail sales made to people outside the organization’ “FHTM needs to continually recruit new participants in an effort to survive’ “tts foreseeable from the terms ofthe plan that the vast majority ofthe paricipants are destined to fai at ther ostensible business venture and are thus harmed” © HERBALIFE HLF is an organization in which distributors earn more than 10 times as ‘much from Recruiting Rewards as they do by selng the company's overpriced products to bona fide retail customers (1) “Herbalfe's entre business model appears to incentviz primarily the payment of compensation that s “acially unrelated tothe sale of the product tothe ultimate users because iis paid based on the suggested retail price ofthe amount ordered from (Herbalife), rather than based on actual sales to consumers” (2) The deposition of Jacqueline Miller in Herbalife v. Ford, No. CV 07- 2529 (C.D. Cal. 2009), shows that, between 2006 and 2009, Herbalife disciplined fewer than 25 cstributors for violating the 70 percent rule (Fewer than 1 out of every 100,000 cistributors) “For the latest twelve month re-qualfication period ending January 2005, approximately 60% of our supervisors did nat re-qualfy and more than 90% of our distributors turned over" (3) We estimate that in the 2006 ~ 2012 period ~1.1mm Sales Leaders failed and left the business, a ~90% failure rate (4) Merle ord No 295 (C18. Ca) DLW 374 gui Omi, 794782, Aol Repo compan hr sped pons his dleCompensation Plan Complexity Multiple Levels Iceberg Shape Commissions based Predominantly on Recruitment Special Bonuses F@RTUNE. CH MARKETIN “The plans cificul to comprehend. {believe that for a general participant t would take many hours of scrutiny to identify and understand the relevant terms ofthe plan and how they interelat..”(1) FHTH'sdistbutor structure comprises seven primary levels: independent Representative -> Regional Sales Manager > Executive Sales Manager > National Sales Manager -> Platinum Sales Manager > Presidential Ambassador “The bottom 3 levels [not entitled to CAB] continually comprise more than 96% of participants" (2) *CGU rewards are presented as an array of percentage commissions and cvertides on the purchaselsale of products, where the commissions & overrides are related tothe level of downline sponsorships" (2) “Participants atthe rank of ESM and NSM comprise ~0.5% of all Representatives; ye, for Dish, they. received [29%] ofthe CGU" (4) “Upon attaining the rank of QPSM... there are special bonuses... suchas... sharing company revenue” (5) ‘Declaration f Vande Natepe. 11) © HERBALIFE Herbalfe's Distributor Agreements exremely dificult o comprehend thas 124 pages, 48,000 words and 215 rules HLF's distributor structure comprises eight primary levels: Non-Sales Leaders > Supervisor > World Team -> GET Team > Milionare Tear > Presiden’s Team ~> Chaiman’s Cub -> Founder's Cire’ The bottom 2 levels, Non-Sales Leaders and Inactive Supervisors (who do not receive royalties) continually comprise ~90% of dstbutors (1), ‘Royalty Overrides and Production Bonus rewards are presented as an array of percentage commissions and overrides on the purchase of products | (based on SRP), Production Bonus percentages increase as dstrbutors recruit more participants ito their downline organizations” (2) Participants a the rank of GETIMTIPT comprise ~0.6% of al distributors; yet they received ~84% of Royalty Overrides (3) Upon attaining the rank of Presidents Team there ae special bonuses such as the Mark Hughes Bonus (1% of company *Retal Sales") (2) 2 Sewn teaCompensation Plan (Cont’d) Volume Quotas Product Purchase is Driven by Compensation Plan Lack of Genuine Retail Sales F@RTUNE. CH MARKETIN “Those who hope to makeitto the topikely spend more than $1,500 per j yearto be an FHTM representative” (1) “To qualify fo sales commissions and recruiting bonuses, they had to pay | an entra $1300 $400 per month (2) "The sales data further reveal that new recruits ae ikely not buying procucts and services from FHTM forthe sake of those products and services, bu, rather, new recruits are purchasing the products or services in order to become elighle to receive rewards’ (3) “Further, vitally no participants choose the FHTM compensation option that would maximize their product commissions... More than 95% ofthese transactions indicate a choice for the 29 commission and the customer points*(3) “infact, ew of FHTW's products and services are ever sold to anyone other | than the Reps themselves. Furthermore, Reps receive minimal rancial rewards from FHTM for seling the products and services to ouside consumers” “The real question, as Attorney] General Conway said, is whether the emphasis ison selng products to independent third pares" Menceamfon i TROGE Se Dest ot Wands Rt pe 3 © HERBALIFE Sales Leaders must generate ~$2,600 of Personal Volume per yearto, maintain thet downlines and Sales Leader status (1) ‘To quali for maximum commissions and bonuses, Sales Leaders must, -enerate~$1,600 to ~$3,200 of Personal Volume each month (1) Senior distributors purchase product to “pay-for-theit- paychecks (2) Midlevel distributors purchase product to requalfy: (3) Junio distributors purchase productto advance inthe marketing plan ‘and achieve Supervisor status (4) 25%discount distributors could buy product cheaper and forego Herbaife’s exorbitant shipping & handing charges by purchasing | product online, but they opt to purchase “direct” from the company in order to obiain Volume Points (5) “We don't track this number and do not believe i is relevant tothe business of investors."(6) Who to ea ions pay 72. “vo tate hea Mle (pe 173) “Wh na be Moi”. 73)Focus on Recruitment Incentives Favor Recruiting Presentations to Prospects Encourage Recruiting Escalating Bonuses Measure of Success F@RTUNE. CH MARKETIN “The scheme provided much arger rewards for recruiting people than for seling products, and more than 85 percent of the money consumers made was for ecritment” (1) “Under add-on bonuses, iis evident thatthe compensation plan offers covenwtelmingly greater rewards for recruitment than for selingtouying products or services" (2) “Virtually all incentives in the compensation plan encourage more recruitment” (3) “FHTM preaches recruitment, Defendants stress recrultment, not product sales, during their presentations to prospective representatwves" (4) “The business has toe bul every day. You wanted some practical advice Recruit, recut. You goto buld team” (5) “Recruitment bonuses... increase as te representative rises through the ranks ofthe FHTM compensation plan (6) “Paul Orbeson defines success and fale in the business as a function of how wel it recruits new members" (4) © HERBALIFE Herbalife provides much larger rewards for recruiting people than for seling products, and more than 90% ofthe money distributors make is fom Recruiting Rewards (1) Because ofthe Production Bonus, Herbalfe's top eamers are not really retailers... Theyre recruiters” (2) Its impossible to get to Active World Team (median gross compensation ~$6,000) without recruing other Sales Leader (3) | fyou want some money today: Reta. you want Lifestyle money: Recruit’ a) “Its easier to getrich fast in Herbalife thant s to go slow... To Build Fast you need to Power Recruit” (5) Bonus percentages increase as distibuto's rise through the ranks ofthe Herbalife compensation plan (6) Michael Johnson defines success by lead generation, Q:"How da you measure success?” ‘Ac There's wo ways to measure. One is by lad generation... Forte tour of Caiforria... One distributor had over 1000 leads generated at that event alone. That is success measurement in its most" (7)Concentration of Rewards at the Top “And what you expect to see in a pyramid scheme is a heavy concentration of the rewards at the top of the enrollment structure and the data exactly verifies that expectation that, for example, these data show that the top six percent of all of the [BurnLounge] moguls earned something like 85 percent of all the rewards... that’s the kind of concentration, progressive concentration toward the top that you would expect to see in a pyramid scheme.” Bae CUCL 8 "The top six percent of all The top six percent of all Sales moguls earned something like Leaders earned approximately _ 85 percent of all the rewards” 89 percent of all the rewardsStratification of Commissions Paid F@RTUNE. CH MARKET Top 1% Earn "Over half of all product bonuses actually goto avery small set of Majority of representatives atthe top ofthe structure” (1) Rewards Few Participants ‘Arproximately 9% o the Independent Representatives received less Earn Meaningful {2.000 of commision per year (2) Incomes “Less than 0.1%... ceived more than $100,000 in net commissions per year (2) "Only a miniscule number of participants ~ probably less than 1% making even a fve-fgure annual income” (3) Typical Earnings ‘More tanS0% of regional sales managers also received fever than $15° are De Minimis “FHTM's Income Disclosure shows thatthe average Manager eained... an ‘annualized income’ of $440" (5) @® HERBALIFE ‘The top 1% of Herbalife U.S. distributors earned ~88% of Royalty Overrides Ba ‘Approximately 98% of distributors received less than $1,000 of commissions in 2011 (1) ‘Approximately 0.1% received more than $100,000 in commissions in 2011 a Only a miniscule numberof pantcipants - probably ess than 0.7% ~ are making even a fve-igure annual income (1) | More than 50% of Sales Leaders received $0 of commissions in 2011 (1) Herbalfe’s Income Disclosure shows that the typical acve Supervisor earned an annualized income of $475 (1) INB. ths excludes Retail Profi, which we estimate to be $61iyr per average distributor before taxes/expenses} (2) 1 See npend or dea 2. Aiton 0 Bea Milne ne 14Harm F@RTUNE. CH MARKETIN Empirical "Considering two consecutive years of operation ~ I calculate that Failure Rate approximately 90.5% of participants had accrued earnings of ess than $15 a year. These indvduals undertook payments for their business venture that any event, were significantly greater than $15. Thus, as alowside estimate, the data show a business failure rat thats at least 90.5%" (1) Dollar Harm "Based upon the data provided by FHT covering 2006 through June 2017... the related consumer injury over the stated period comes to approximately $169.3 milion” (1) © HERBALIFE We estimate thatin the 2006-2012 period, approximately 90% of new Sales | Leaders exited the business. The vast majority ofthese individuals received {annual commissions of less than $475 (and many received $0). These individuals undertook payments for their business venture that were, most likely, signficanty greater than $475. Thus, we estimate the data show a business failure rate thatis approximately 90% (excluding Non Sales, Leaders) (1) Based on our assumptions and Herbalife’s publicly disclosed data covering {1980 through 2012, ve estimate conservatively, the related consumer injuy ‘over the stated period comes to approximately $3.8 bilion; ‘This estimate does not include the harm done to the ~10mm farmer Non- | Sales Leader distributors. As such, we think the tue financial damage Herbalife has inficted is materially higher than $3.8 bilion (1)Deceptive Income Claims Exaggerated Earnings Claims Anybody Can Do It Change Your Lifestyle Who wants to bea Millionaire? For Your Grandchildren. FP@®RTUNE. HI-TECH MARKETING “The recrting system is if with testimonials oftop earners taking about ineredible sums they've made" (1) "Ata Chicago-area recruiting even, one representative tld an undercover FTC investgatr that she made $10,000in one month anda friend made $60,000in one month (2) “Top FHTM ofcias attempt to motivate representatives wth promises of seat nancial success if they just donot give up" (3) “FHTM lures new recruits in with promises of large paychecks and extravagant lifestyles,” eg. [FHTM has) alowed us lve out our dreams. ‘And you know what? it can for you too if you'l just put your effortin the right vehicle, inthe right place” (3) “A Platinum Manager tod listeners on a team calt ‘lf you'e not aware of what you have your hands on, this is a mul-milion-dolar business, Daria has made milions of dollars. Scott has made milions of dollars, milions and milions of dolas, So, understand, this is a mult-milion dolar organization” (2) “(Top representatives] promise that FHTM will provide consumers with financial securty for themselves and their chidren and grandchildren” (4) @® HERBALIFE We analyzed 393 testimonials and earnings claims from Herbalfe Today | magazines from 1997-2004, Annual earings claims average $178,000! which only roughly 1 in 5,000 new distributors achieves (1) ‘Ata New Yorkarea recrulting event, one representative told an undercover reporter (Herb Greenberg) that he made §20,000in one month and a friend made $65,000 in one month 2) | “Everything is really easy. If can doit, you can doit a welt” ~ Mark Hughes (1) | Doran Andy, Chaliman's Club lures new recruits with a YouTube video featuring his mansion, his Ferrari, and his lavish lifestyle: “You know, ust imagine started witha litte dream to want to have a better ie... And al of | you, i'you just dream, you can have everything we have and much more” (3) “Herbalife are {sic} on the way to become a USD10bilion company and [thanks to that many normal people lke you and I wil become Milionaies;" (4) "Great produc, great brand, incredible business opportunity, unike anything that exists out there, because people can become millionaires at Herbalife” (5) “tf you wantto lock in that secur for life, you need to recruit, And the other thing you need todo, be prepared to rl that cash fw for straight 90 12 | months. Because you know what, in that short space of time, by making that commitment, you are going to create a foundation for if, Absolutely, Not just for yoursel, but a legacy, a legacy for your family, for your children, and their children’s children.” (6) ules sab cai pe urleencompeniat-mnersate han ftp ac abou ease conap conten yoad92012/1/0cine Recufng Tang pl toa lors, CEO, Deoser 16 208 neice dy eas. ie who matte Mileage 7).The Retail Opportunity Inflated Prices Commodity Products Restrictions Placed on Retail Activity F@RTUNE. CH MARKETIN "A price comparison of FHTW's True Essentials and Envy Organics lines shows that equivalent products can typically be purchased for substantally less" (1) “{FHTM representatives] are seling things of dubious value. These include their own ne of organic shampoos and pls” (2) “IRepresentaves] are prohibited from seing products or services on commerce sites such as Amazon, eBay, of Craigslist without obtaining prior written approval from FHTM" (3) [Merman for TRO ip 10s @ HERBALIFE For a 200-calore serving, Formula 1 (~3086 of HLF's volume) costs nearly three times as much as Ensure or Slim-Fast, and nearly ice as much as Lean Shake, Herbals other products are siiely expensive. A rmtivitamin tale rom Herbalife supposedly retail for 26 cents, whereas Centrum (Pfizer) can be purchased for 6 cents per tablet (1) Herbalife’ top-seling products are commodities that should hav ltl tno pricing power These include nuttin ponder, herbal tea, protein ponder, and its own line of organic shampoos and pls. The company says it spends “de minimis’ amounts to edverise ts products, and its GAAP R&D spending is*not material (2) “Distibutors may not (recy or indirectly trough any intermediary or instrumentality ofr or facitate the offering of Herbalife products forsale by solckng or receiving open bids. This prohibition includes, buts not limited to, slicing or receiving bids for Herbalife products onthe Internet, through 2 commercial auction Web site such as eBay, or otherwise” (3) Herbalife Nutrition Clubs are required to abide by an onerous set of restrictions and rules, including: () no exterior signage at residential locations, (i) no mention of Herbalife on the Club exterior, i) windows and doors must be covered, (v) no advertising or promotion, () no atracting walk-in customers, and (vi) Club Operators may charge membership fee only to cover operating costs ~ prohibited from earning retail proft (4) ‘No wan ea iloAnti-Pyramid Rules Buyback Policy 70% Rule | Majority Rule F@®RTUNE HI-TECH MARKETIN “unlike Amway, FHTM charges a 1086 restocking fe onthe products itll even alow a representative to return, [and] requires the representative to return any compensation they earned asa result of buying the products" o) “From all of these considerations itis evident thatthe majorty rule andthe 7096 ule have no effective meaning and certainly do not secure any bona fide customer sales" (2) “Important, any products that an IR could give away as samples while also using these products for oneself such as True Essentials and Envy Organics ~ may be designated as customer orders" (3) @ HERBALIFE Until May 2012, HLF charged a 109 restocking fee onthe products returned by distributors In some courises, HLF hasihad no repurchase policy In ‘thers, ithasihad an escalating restocking fee, HLF does not reimburse ‘Shipping & Handing fees, which canbe as high as ~20% of purchase price; HLF requires distributors and upline cstivutrs to return any compensation they earned (as well as forego promotions) as a resuk of product returns ~ this has the effect of encouraging disributors to ea the cost of product returns (1) “t know that Herbalife has created the Ten Retail Sales Rule and the 70 Percent Rue, but looking atthe record I have serous questions as to whether or not those are not exating form over substance and arent just there forthe purpose of creating the impression thatthe second element of the Koscot est has been me” (2) Distributors are able to count sales to frstline Distributors with up to 200 personally purchased Volume Points as sales per the Ten Retail Customer Rule; in addition, products given away as samples at Nuttion Clubs may be counted toward the Ten Retail Customer Rule (3) Distributors can include sales to other distributors toward ther 70% Rule requirement, which does nothing to ensure sales to bona fide retail customers Sales Leaders do noteceive their paychecks unless they cert that hey have abided bythe 70% Rule and Ten Retail Customer Rule ere Fond ae 1 300 Hee Te Dit #00.) ‘in nis fe ion? (136) PeMiscellaneous F@RTUNE. CH MARKETING Management ‘Simon Davies spent te last si years at FHTM as CFO and then Chief Analytics Office (1) Third-Party SEATN does evening can pale the names ofthe tid-pary Credibility usinesses with which thas agreeme Targeting aM niet x eer efforts at oe ‘who are sueae 2 if jc ake ends meet buthave an entrepreneurial bet. Increasingly, FHTM has Specific Ethnic pn targetng nonnative Engish-speakng rectus, parcial Spanish Groups speakers" (3) Responding to “nesponse to DiGrandi’s question about whether FHTM is a pyramid, Pyramid Scheme _[FTHs Genera! Counsel responds, npr, by saying, could oon or Allegations this ~ you know, on this topic fr along ~ fr along time, obviousy. But the botomine i, are people compensated by FHTM Solely for recruiting new people o join he business? And the answer to that questions no, Therefor, i's not a pyramid." emphasis added) (4) aterm ieeentieae 209) bu. ain @ HERBALIFE ‘Simon Davies was the Director of Internal Audit at Herbalfe from 1994 through 2005 (1) Herbalife has cited its UCLA affliation 440 times in SEC flings since its PO in 2004, Including distributor presentation references to UCLA the number would likly be inthe thousands Herbalife has pad its Nobel Laureate spokesman, Dr. Lous Ignarro, and his affliated consuting fm more than $15 millon to help Herbalife promote is business opportunity ots distributors (2) Herbalife targets Latinos, Arican-Americans, ethnic minors, the young, and stay-at-home moms ~ focusing on those in nancial need (3) HLF's investor relations website has atnk to a white paper, commissioned by the Company, and published by Professor Anne T. Coughlan enited, “FAQs on MLM Companies." The paper states “an illegal pyramid scheme awards payments to participants for mere recuiment” (emphasis added) the paper also states, “A tue pyramid scheme causes alate participants to lose money’ (4) guanine ieee 2010040 0834 4 Souwer haa com. Foran ans of Ans Compl’ apr ss: “Anaei OF Are. Coaghs' Hotahte Anes nuseamansnecsnies it) ncacametsumblabetaleatcisHerbalife Statement of Average Gross Compensation of U.S. Supervisors - 2011 (Abridged) @ HERBALIFE. STATEMENT OF AVERAGE GROSS COMPENSATION OF U.S. SUPERVISORS - 2011 Over 25% of Distributors reach the rank of Supervisor and above (‘Leader’), qualifying them for additional compensation which is paid by Herbalife based upon their activities and those they have ‘sponsored directly and indirectly. The annual gross compensation paid by Herbalife to all Leaders during 2011 averaged $2,900 (with a median level of $741). Over 38% of Supervisors are “Active (defined as those who generated at least 2,500 points of volume in 2011 after becoming Supervisor). ‘The annual gross compensation paid by Herbalife to Active Leaders during 2011 averaged $7,354 (with a median level of $837). ‘ACTIVE LEADERS: Average Earnings %ot Total | %oF Active | Compensation | Median Compensation Earning Level Leaders Leaders (usp) (usb) President's Team 02 % 06% |S 514.638 $336,501 Millionaire Team 07 % 1.7% | $ 100,195 $97,303 Get Team 25 % 65% |S 22,766 S$ 19417 World Team 29% 73% |$ 6.224 $ 5.659 ‘Supervisor 33.1% 39% |$ 901 $475 Total 38.4% 100% [$7,354 ‘S637 ‘Source: Heri Stnent of Avsrge Gros Crmenston of U.S Sipe 201, Rens 7/812. Avalae on tabi somStratification of U.S. Herbalife Commissions Backup Pet. of (USD in millions) Total Distribs Total Compensation Amt, Pet. Leaders Average ___Median Total President's Team 207 0.04% 0.2% $514,638 $336,901 $106.5 Millionaire Team. 621 0.1% 0.7% 100,195 97,303, 62.2 GET Team 2,355 0.5% 2.6% 22,766 19,417 53.6 World Team 2,639 0.5% 2.9% 6,224 5,659 16.4 Supervisor 30,255, 5.9% 33.1% 901 475 27.3 Active Leaders 36,076 1.0% 39.4% $7,354 $637 $266.0 Inactive Leaders 55,414 10.7% 60.6% - - : ‘Total Leaders (1) 91,490 17.7% 100.0%. $2,900 30, $266.0 Non-Sales Leaders (2) 424.106 82.3% Total Distributors 515,596 100.0%. $0 ‘Source: Heralife Semen of averse Gross Camperstion of US. Supers 201, Revs " Anse Sls Las wore D423 820110840: L00609- QF 11 150,03 1) Se: Here Rego Key Meticejuestions for Herbalife! February 7, 2013 Des Walsh and Herbalife (the “Company”) executives have repeatedly committed to having a fact-based conversation and total transparency about Herbalife’s business. Specifically, Des Walsh stated during a recent interview: “Our commitment is to total transparency . . . we benefit from people understanding our company, our products, our business model, and so we will answer any and all questions in that area.” Given Mr, Walsh’s comments, Pershing Square would welcome responses to the following questions: Pyramid Scheme Question: > Based on Herbalife’s reading of the 2004 FTC Staff Advisory Opinion, the Company appears to conclude that “the primary motivation for purchasing should be resale and / or consumption.” This conclusion suggests that Herbalife believes that internal consumption is otherwise indistinguishable from independent third-party sales in the FTC’s determination of a pyramid scheme. As recently as November 2012, however, the FTC published the following on its website: “One sign of a pyramid scheme is if distributors sell more product to other distributors than to the public — or if they make more money from recruiting than they do from selling.” © In light of the FTC’s November 2012 statement, why does the Company continue to look to the FTC’s 2004 Opinion for guidance as to whether or not internal consumption is a red flag for a pyramid scheme?” > Rather than respond to Pershing Square’s argument that Herbalife distributors primarily obtain their monetary benefits from recruiting rather than retailing, the Company's presentation on January 10, 2013 seemed to focus on establishing that retail customers do, in fact, exist for Herbalife product, However, in Webster v. Omnitrition, 79 F.3d 776, 782 (9th Cir. 1996), the Ninth Circuit clarified that “Omnitrition cannot save itself simply by pointing to the fact that it makes some retail sales.” © What proof can the Company provide that bona fide reta distributors) at sufficient profits occur such that Herbalife’s distributors obtain their monetary sales (defined as sales to non- This document is based upon a presentation entitled “Who wants to be a Millionaire?,” made by Pershing Square Capital Management, L.P. (“Pershing Square”) on December 20, 2012, to which Herbalife Ltd. ("Herbalife") responded, among ‘other things, with its own presentation at an Investor and Analyst Day on January 10, 2013. Please see full diselaimer atthe ‘end of the document.benefits primarily from sales to independent, thi recruiting rewards? -party retail customers rather than from In Herbalife v. Ford, No. 07-2529 (C.D. Cal.), Judge Feess stated that “Herbalife’s entire business model appears to incentivize primarily the payment of compensation that is “facially unrelated to the sale of the product to the ultimate users because it is paid based on the suggested retail price of the amount ordered from [Herbalife], rather than based on actual sales to consumers.” (Dkt. #374 at 16 (quoting Omnit 79 F.3d at 782).) The Company’s January 10, 2013 investor day presentation argued that “all compensation is directly linked to product sales.” © What does the Company mean by “directly linked to product sales”? By this statement, is the Company referring to the fact that commissions are determined as a percentage of the Suggested Retail Price (“SRP”) of product purchased from the Company? Does the Company believe that a bona fide retail sale is required (that is, a sale to someone who is not part of the marketing scheme) in order for commissions to be related to the sale of products to ultimate consumers? If not, why not? In Herbalife v. Ford., Judge Feess looked to “federal law as articulated in Koscot and adopted in this Circuit in Omnizrition in a case that seems to me to be completely indistinguishable from the present lawsuit.” (une 1, 2009 Hr'g Tr., Dkt. # 300, at 6.) © Yet, Herbalife’s 2011 10-K states that the Company believes there are “ differences between our marketing system and that described in the Onmitrition case. Please elaborate on these “significant differences.” Can you point to any case law that would serve as a basis for the Company to argue that its royalty overrides are determined based on “the sale of product to ultimate users”? According to a white paper paid for by Herbalife and written by Professor Anne T. Coughlan, a non- Tawyer, marketing professor: “an illegal pyramid scheme awards payments to participants for mere recruiting.” (Anne T. Coughlan, FAQs on MLM Companies, July 2012, at 3.) © Can you point to any case law that defines the phrase “mere recruiting”? When a Supervisor recruits a new distributor who qualifies to become a Supervisor by purchasing 4,000 Volume Points of product in one month at a 42% discount (approximate cost: $2,600): © Iso’ tit true that the sponsoring Supervisor receives an 8% Wholesale Commission for this purchase of product (roughly $320)? Page2© Isn’tit true that the upline Sales Leaders receive 5% Royalty Overrides (up to three active levels) and 7% Production Bonuses (roughly $880)? © Are these payments in any way related to the actual retail price at which the product is resold, if itis resold, by the qualifying Supervisor? California’s Permanent Injunction Against Herbalife > Herbalife’s 2011 10K states that: “All of our officers and directors are subject to a permanent injunction issued in October 1986 pursuant to the settlement of an action instituted by the California Attorney General, the State Health Director and the Santa Cruz County District Attorney.” > The Injunction states: “The provisions of this final judgment are applicable to: (a) defendants, Herbalife, Mark Hughes, and each of them, and their respective suec corporate or otherwise, and (b) those officers, directors and employees of said defendants and any other entities acting under, by or on behalf of either such defendant or pursuant to their direction, who have notice of this injunction.” sors in interest, whether > Among other things, the Injunction restricts Herbalife from “establishfing], maintain[ing], or operat{ing] marketing plan in which.... (2) Any compensation, however denominated (including but not limited to ‘commissions,’ ‘overrides,’ “achievement bonuses,” or any term of similar import), defendants pay or participants receive is based upon anything other than the retail sale of defendants’ products.” (Id. {| 5(A).) > The Injunction goes on to define the term “retail sale” as follow: this Section 5 means a sale at defendants’ product(s) in any of the following situations: (1) to persons who are not part of defendant's marketing program or distribution system; or, (2) to persons who are not buying to become part of defendants marketing program or distribution system; or, (3) to persons ‘The term “retail sale” as used in who, although desirous of becoming or who are a part of defendants’ marketing plan or distribution system are buying for their own personal or family use.” (Id. 4 5(C).) © How can the Company’s policy of paying Wholesale Commissions be in compliance with Section 5(A)(2) of the Injunction if Wholesale Commissions are paid whenever a Non-Sales Leader distributor orders product directly from Herbalife, and if in many cases, the purchasing Non-Sales Leaders are not strictly “buying for their own personal or family use"? © Isit the Company's policy to only pay Wholesale Commissions when Non-Sales Leaders purchase product directly from the Company expressly for “personal or family use”? If so, how does the Company determine whether product purchased by Non-Sales Leaders will be Page 3v internally consumed as opposed to being purchased for advancement in Herbalife’s marketing plan or for resale outside of the network? © Did Herbalife pay Wholesale Commissions to Non-Sales Leaders in 1986, the year this injunction was put into force? Section 5(B) of the Injunction states that “defendants shall be in compliance with this Section 5, as long as a verification or documentation system they implement allows them, at any given point in time, to verify or document to plaintiff's that any and all participants who receive commis bonuses, overrides and/or advancement from defendants in defendants’ marketing program, after entry of this judgment, are based on retail sales made by or through such participant(s) or others introduced directly or indirectly under participant(s).” ions, However, in an 8-K filed on May 2, 2012 with the SEC, the Company disclosed that “We don’t track [sales to non-distributors} and do not believe it is relevant to the business or investors.” © Given the Company's numerous public admissions that it cannot and does not track “retail sales,” how is it possible for the Company to be in compliance with Section 5(B) of the Injunction? Under Section 3(Q) of the Injunction: “Pursuant to Business and Professions Code Sections 17203 and 17535, defendants are hereby permanently enjoined and restrained from: “Making false or misleading representations with respect to any specific goals for participants in defendants! marketing program relating to the number of new customers or new participants a participant may obtain within a specific time period or an amount of money a participant may earn through bonuses and overrides.” Pershing Square’s December 20! presentation listed a number of reasons why Herbalife’s Statement of Average Gross Compensation of US Supervisors — 2011 (the “2011 Statement of Average Gross Compensation”) was likely to mislead investors and potential distributors, including (i) the fact that 93% of Herbalife distributors (including Non-Sales Leaders) were excluded from the table, (i) the statement referred to “Average Earnings” but was not adjusted for distributor expenses, (ii) the statement seemed to use a definition for the term “Active” that is inconsistent with other public Herbalife disclosures, (iv) the statement overstated the actual percentage of distributors who reached the rank of Supervisor and above, and (v) the statement failed to properly demonstrate the true probability of reaching the upper echelons of Herbalife’s marketing plan, We further note that in response to such «1 Herbalife icisms leveled by Pershing Square and others issued yesterday a new and substantially revised version of its Statement of Average Gro: Compensation for U.S Distributors. We believe that this new disclosure confirms the material Page 4inadequacy of previous Statements of Gross Compensation that were presented to new distributors when inducing them to participate in the Herbalife network, and that the release of this revised statement does not eliminate the serious problems with its predecessor. (Please note that Pershing ‘Square will separately comment on this new Statement of Average Gross Compensation in due course.) © Given the examples above and the recently revised disclosure, does the Company believe its historical distributor earnings disclosures were not misleading and in compliance with Section 3(Q) of the Injunction? In light of this significant disclosure modification, does the Company feel it has an obligation to refund losses of those distributors who were mi result of its previous materially misleading earnings disclosures? © Pershing Square’s presentation also pointed out that Herbalife marketing materials in Brazil suggest new distributors can reach the President’s Team in two years. In addition, Herbalife ‘Today magazines suggested that, when Herbalife entered Ireland, distributors could reasonably expect to reach the President's Team in fewer than three years. We note that nearly ten years after entering the Irish market, there were no President’s Team members in Ireland." = In light of this, what is the Company’s defense against the allegation that it proffered misleading representations to prospective Herbalife distributors as to “specific goals for participants in defendants’ marketing program relating to the number of new participants a participant may obtain within a specific time period or an amount of money a participant may earn through bonuses and overrides”? © OnaDecember 16, 2008 investor day conference call, Michael Johnson made the following statement: We know this isa year about buikling up our recruiting, continuing to build retailing to switch marketplaces from recruiting ‘only to daily consumption, which is a blend of recruiting and retailing, and then retaining those distributors. Great product, great brand, incredible business opportunity, unlike anything that exists out there, because people an become millionaires at Herbalife. Not everyone, so well ake ~ [Brad in case you're listening, well take all the legal disclaimers on that, but there's not many How much of the Company's final sales to actual consumers, by percentage and dollars, is sold to people outside the distributor network, and how much is sold within the distributor network (over the last five years)? > Why have the Company and management answered this simple and straightforward qui ‘many different and inconsistent ways? © Response to David Einhom on May 1, 2012: Des Walsh: “So, we don't have an exact percentage David because we don't have visibility to that level of detail.” David Einhorn: “Do you have an approximation?” Des Walsh: “So well, again going back to our 70% rule, we believe that it’s at 70% or potentially in excess of that.” © Inan8-K filed On May 2, 2012, Herbalife states: “We don’t track [sales to non-distributors] and do not believe it is relevant to the business or investors.” Page 8© Michael Johnson upon Pershing’s announcement (on 12/19/12): = Kate Kelly: "Can you give us a percentage figure though Mr. Johnson as to what percentage of your sales are outside that distribution network." Johnson: "90%." * Kate Kelly: “So the vast majority?” “Absolutely!” = Johnsor © Michael Johnson after Herbalife’s investor day (on 1/10/13): “It was a misstatement. 90% of our distributors, OK, are buying our product, and let me just try to clarify this, buy it for one reason and they buy it for the self- consumption.” = “What we have in our company today is we have a tremendous amount of customers;” “I don’t have a number for you.” © Ifthe Company does not track retail sales, what other empirical basis do you have to exp! the above answers? Why have you provided materially different answers to the same question? > Inthe Company's January 10, 2013 investor day presentation, management references the 2004 FTC Staff Advisory Opinion and deduces from that Opinion that “the primary motivation for purchasing should be resale and / or consumption.” However, in announcing the recent case against Fortune Hi- Tech, the FTC highlighted that the key to a legitimate MLM is an emphasis on selling to “independent third parties” (FTC Midwest Director, Steve Baker, Jan. 28, 2013 Press Conference), Further, on January 28, 2013, the FTC posted on its website a consumer-education piece about pyramids and stated: “If the money you make is based on your sales to the public, it may be a legitimate multilevel marketing plan, If the money you make is mainly based on the number of people you recruit and your sales to them, it’s a pyramid scheme, © Inlight of the above statements by the FTC, does the Company still believe that it ean be indifferent to the amount of product sold or consumed within the network versus the amount of sales to independent third parties in the determination as to whether Herbalife is a pyramid scheme? © Why don’t you actually track sales to independent third parties, particularly when your competitors, like Tupperware, track this information? ‘Tupperware CEO comments during a 1/29/13 interview with Jim Cramer Jim Cramer: Page 9‘Can you define very quickly for our viewers what direct selling is and why you're distancing yourself from some of the other companies that are-- that claim to be in your industry?” Rick Goings: “Over 90% of our sales are through a retail customer. Only 10% to the sales force, and they buy that because we have so many new products ever) - “Most of the network marketers, the bulk of their products are consumption by their network”, = “You wouldn't believe the level of detail we have" - “We have a report there of what happened the previous week, what the sales were, what the recruits were, who they were to and people that went to the party. We manage our businesses right down to the detail of it.” » Ona May 2010 investor call, John DeSimone referred to “a lot of other distributor statistics that we have visibility to that you investors don’t. So we've got a dashboard that gives us statistics on every one of our distributors and it’s close to three dozen statistics. And it’s a lot of information. So it tells us order patterns for distributors. It gives us the statistical analysis to determine who's doing clubs, which are more predictable versus who’s doing recruiting that they’re bringing a lot of people but they're not sticky. And so it gives us a lot of information into visibility.” © What are the three dozen distributor statistics that Herbalife collects that it does not share with investors? Do any of these statistics track the amount of product that is sold outside the Herbalife network? If not, why not? “Retail Sales” > Herbalife’s compensation to distributors, as well as its charges to distributors for shipping, handling, taxes and other charges, are calculated based on percentages of the Company's SRP for its products, SRPs also drive the Company's statement of “Retail Sales” and of distributors’ “Retail Profits.” © What is the actual retail price at which Herbalife products are sold to independent third- parties and distributors who consume the produet?- What would the Company's “Retail Sales” be if they were based on actual retail prices, not SRP? > Rules 17-A and 18-E of your Sales and Marketing Plan, which binds all distributors, requires distributors to create records of each sale, including product sold, sale price and name and contact information for each customer. Page 10Section 17 Customer Retail Receipts and the Customer Refund Policy Rule 17-A Providing Retail Receipts to Customer A Distributor must provide an official completed Herbalife Retail Order Form to all retail customers when the sale is completed. This must list the products sold, the sales price, and the name, address and telephone number of the Distributor and the customer. Distributors are required to maintain their copy of all Retail Order Forms on file for 1 period of two (2) years. Herbalife maintains the right to request copies of these and to verify the transactions and the terms and conditions of the sale, and the service provided by the Distributor © In light of all the recent questions about the Company's sales outside the distributor network and its importance, why have you not simply requested these receipts from all of your distributors so Herbalife could generate empirical evidence which would demonstrate the amount and pricing of third-party retail sales? Lieberman’s Finding that 92% of Herbalife Ultimate Users are Non-Distributors > According to extrapolations from the 2,000 individuals polled in the Lieberman survey, Herbalife has stated that ~5.7 million U.S. households purchased Herbalife product in the three months prior to the study. Based on the Company's disclosure, there were approximately 500,000 Herbalife distributors in the U.S. as of 12/31/11. Based on Michael Johnson’s January 10, 2013 comments, 90% (i.e., 450,000) of these distributors are “discount customers” who only buy the product for self- consumption. This implies that there are only approximately 50,000 active distributors in the U.S. (i.c., distributors who are selling the product to independent third parties). This would imply that each of these 50,000 distributors have, on average, about 114 third-party independent customers for Herbalife products. Does the company have any evidence that would suggest that this is true? } Based on the figures above, approximately 450,000 of Herbalife’s U.S. customers are distributors or discount customers, and approximately 5 million of Herbalife’s U.S. customers are non-distributors or retail customers. This suggests ~92% of Herbalife’s “customers” are non-distributors or non- discount customers. In a January 2013 investor presentation, Nu Skin disclosed that 10% of its U.S. customers are “retail customers” and 50% are “preferred customers” ~ customers who sign up to purchase Nu Skin product at a discount. (© In light of the similarities between the two companies’ business models, how is it possible that Nu Skin has five times more discount customers than retail customers while Herbalife has 11 times more retail customers than discount customers? Page 11Herbalife’s Argument that Non-Distributors Account for 32% of U.S. “Direct Ship” Volume > Inits January 10" presentation, Herbalife disclosed that in the U.S. in 2012, Herbalife shipped 32% of its volume to non-distributors (31% of orders). According to the Company, these shipments were comprised of 1.4 million orders directly shipped to 460,000 non-distributor unique addresses at an average order size of approximately 260 Volume Points. In 2012 YTD, the ratio of Volume Points to Retail Sales in the U.S. was 1.11 times, Assuming a 7% Surcharge and 4% shipping expense, these 260 Volume Point orders would cost $320 (at full SRP); note that non-distributors supposedly pay 100% of SRP when buying from the Company. © Why would a non-distributor pay $320 for 260 Volume Points of product when he or she could pay $59 to become a 25% discount customer and purchase the same products for ~$300 (including the $59 IBP) and then have a 25% discount on all future purchases? Furthermore, how is it possible that these non-distributors had an average order size of $320 when they are purchasing product for their own use? This seems like a lot of Formula 1 and vitamins for one order for one customer. © Please provide the breakdown of the 32% of sales shipped to non-distributors by orders submitted at 25% discount, 35% discount, 42% discount and 50% discount levels, > The Sales & Marketing Plan notes that “FedEx takes typically three to five working days for delivery, and it is recommended that someone be available at the “Ship To” address to accept the shipment. (You may desire to address your shipment to your neighbor, friend, relative, ete.)” © Could distributors shipping product to alternative addresses account for the volume Herbalife claims is being purchased by non-distributor customers? Herbalife’s Argument that 92% of Volume is from Mature Markets > Inits January 10" presentation, Herbalife stated that 92% of its 2012 YTD September volume came from “Mature Markets” (i.e., markets that Herbalife entered more than 10 years ago). © Why is this analysis based on Volume Points instead of Net Sale: ‘© We note that based on pricing sheets obtained from the internet, the ratio of Retail Sales (SUSD) to Volume Points for Formula | in Malaysia was ~2.1x in 201, but only ~0.6x in Japan. Page 12Why does the ratio of Net Sales to Volume Points vary significantly in certain mature markets versus certain emerging markets? In light of the disparate ratios of Net Sales to Volume Points in different markets, isn’t it misleading to attempt to demonstrate consistent growth using Volume Points rather than net sales? > We note that in the 1990s when Herbalife disclosed Retail Sales by country, the following footnote was in the 10-K: “The Company records sales data based on the country from which distributor orders are shipped by the Company.” (emphasis added) ©. Is Herbalife’s country-specific Volume Point disclosure more a function of Herbalife’s shipping logistics than true end-demand for the products? © Ifa 25% distributor in Vietnam whose sponsoring Supervisor is based in the United States buys $100 of product directly from Herbalife, where is the revenue booked, in the United States (a mature market) or in Vietnam (an emerging market)? © How many President's Team members have distributors from more than one country in their downlines? } To help conduct additional analysis on the extent of “pop and drop” by country, please provide Net Sales by country for each of the last ten years for each country in which Herbalife products are or have been offered > We note that in recent investor presentations, the Company has highlighted its “city by city” approach to growth. © What evidence can the Company provide to prove that the seemingly stable growth of mature markets is not being driven by the “pops” of rolling out Nutrition Clubs in newly entered cities masking the “drops” of previously entered, saturated cities? Herbalife’s Argument that “the Vast Majority of our Sales Take Place at a Full Retail Price” } Inthe Q&A section of Herbalife’s investor presentation, management was asked what percentage of SRP Herbalife product is sold to retail customers. Management responded that “the vast majority of our sales take place at a full retail price,” but provided no evidence for this assertion, © Given (i) that the Company has stated it does not track the actual retail price at which products are resold to third-party retail customers and (ii) the evidence from Pershing Square's presentation that Herbalife products routinely sell on independent ributor Page 13,websites and eBay for discounts of 35%+ from SRP, how can the Company state that its products are resold at “full retail price”? What is the empirical basis for this assertion? > In response to Pershing Square’s evidence that Herbalife products are sold on eBay at a discount of more than 35%, you stated that eBay is not a “proxy for market prices” because “most people . . shop at eBay to find branded product at a discount price.” © How do you respond to the fact that GNC’s Lean Shake sells on eBay for a premium to its retail price of approximately 2%? Do you deny that, in addition to eBay, Herbalife products are sold on distributor websites at discounts of 35% or more? > Management went on to state that “And arguably, in Nutrition Clubs, because it’s a method of going to market where you've got servings, you've actually got, got sales taking place where the ‘cumulation may be actually be even higher than suggested retail, even if by serving basis.” © However, Rule 5-E Walk-In Traffic of Herbalife’s Nutrition Club procedures states: “Nutrition clubs are not retail locations and operators may not state or imply that they are. It is not permissible to sell product servings to anyone, Products servings are only available to registered Nutrition Club members as part of their daily, weekly or monthly membership fee.” ° Given that products are not allowed to be sold at retail at Nutrition Clubs per Herbalife’s own rules and policies, why does the Company assert that “sales [take] place where the cumulation may be actually even higher than suggested retail [price]"? Lieberman’s Finding that Only 4% of Herbalife Distributors Join to Earn “ ime Income” > If, according to the Lieberman survey, only 4% of Herbalife distributors join with expectations of earning “full-time ineome,” then: © Why do so many Herbalife Independent Distributor presentations emphasize “lifestyle money”? co Whyis the average Herbalife monthly income reflected in Herbalife Today magazine testimonials equal to $178,000 per year? © Why was Herbalife’s 2011 Statement of Average Gross Compensation for prospective distributors stratified so that three of the five boxes (60% of the table) represented distributor earnings disclosure for “full-time earners” who only represent less than 4% of Herbalife’s Total Leaders? Page 14© Based on a similar survey on its website, why did the Direct Selling Association (“DSA”) find that 35% of respondents (out of 26,267) joined direct selling organizations “to eam full- time income”? What is the primary reason you became a direct seller? To eam supplemental income (60%, 13.225 Votes) To earn full-time income (35%, 9,424 Votes) To buy the products at a discount (8%, 2.226 Votes) Like to be recognized for my accomplishments (4%, 985 Votes) Like to meet other people (38, 730 Votes) Total Voters: 26,267 (source: www directselling41.com) Form Price “Per Serving’ > Herbalife criticized Pershing Square for comparing the price of Formula 1 to comparable products on a “Per 200 Calorie Serving” basis, arguing that “Per Serving” was the more relevant denominator. ® We note that Formula 1’s serving size is substantially smaller than that of competitive products. © Why is a serving of Formula 1 only 0.8802 while the average serving of Slim-Fast, Ensure, Lean Shake, Genisoy and Total Soy is |.420z? > When both are mixed with water, why is a serving of Formula 1 only 90 calories while a serving of GNC’s Lean Shake is 180 calories? Page 15,> We note that, while the term “meal replacement” is not defined in all markets, European Directive 96/8/EC for “meal replacement for weight control” stipulates that “energy provided by a meal replacement shall not be I than 840 kj (200kcal)”""(emphasis added). Additionally, Amy Greene (Herbalife Vice President) has discussed the “steal one meal a day from fast food” concept with a 200-calorie meal replacement shake.” © Given that Herbalife markets Formula I as a “meal replacement” and Herbalife marketing materials recommend Formula 1 be served mixed with water at Nutrition Clubs, why is a single serving of Formula 1 only 90 calories when mixed with water shake be a “meal”? Why is using a “per 200 calorie serving” not the correct way to compare the cost of Formula 1 with comparable products? How could a 90-calorie Herbalife’s $44mm of Spend in “Science and Technical” Activities In response to Pershing Square's observation that Herbalife’s GAAP R&D spending is “not material,” the Company noted in its January 10, 2013 investor day presentation that it has spent S44mum in “science and technical” activities in 2012. > We note that Herbalife’s $44mm includes money spent on “technical operations,” “quality assurance,” “quality control,” “product safety,” “regulatory compliance,” “nutrition affairs, “regulatory,” “product licensing,” and “strategic sourcing.” © What do these items have to do with research and development? Can you please provide a breakdown of costs in these nine categories and explain what these activities include? > Does Herbalife’s $44mm include fees that Herbalife pays Dr. Ignarro and other doctors for speaking at Herbalife distributor events (such as Extravaganzas) and other services? © Why has Herbalife paid Dr. [gnarro, a Nobel laureate, more than $15 million? What services does he perform for the Company on an annual basis that justify these payments? > Does Herbalife’s $44mm include “product licensing” fees Herbalife pays to license patents to manufacture and distribute Niteworks? > What has Herbalife’s GAAP R&D been for the past 5S years? Recruiting Rewards in SG&. Page 16> In response to Pershing Square’s estimate that Herbalife includes substantial recruiting rewards in SG&A, the Company responded in its January 10, 2013 investor day presentation that only $36 million of SG&A expenditures in 2011 were “promotion-related.” © Please define what is included as “promotion-related” per the Company $36mm disclosure. > In Herbalife’s 2010 10-K, the Company disclosed that “Distributor reward and recognition is a significant factor in motivating our distributors, In 2010, 2009, and 2008 we invested approximately $101.6 million, $84.1 million, and $89.6 million, respectively, in regional and worldwide events and promotions to motivate our distributors to achieve and exceed both sales and recruiting goals.” © Why did Herbalife stop disclos ng this metric in its 2011 10-K? © Did this spending really decrease from $101.6mm in 2010 to $36mm in 2011? © Aren’t these costs promotion related? If so, why did you not include them in your answer to our question? > We note that, according to the 10-K, Herbalife paid “compensation to China sales employees and service fees to China independent service providers totaling $96.8 million” in 2011. Additionally, in a 1/3/13 research report, Wedbush stated: “Again, we are in agreement with the Ackman analysis that some adjustments should be made to the commissions tally from SG&A expense. For example, we would likely classify approximately $63 million of SG&A as commissions / royalty overrides because of the China market. Given the unique set of regulations governing direct selling in China, of which Herbalife is one of only a small handful of companies authorized by the Chinese government to conduct direct selling in that country, the company must classify what all other countries consider to be royalty overrides, into SG&A for China.” © Given that much (if not all) of this $96.8 million is effectively the same as royalty overrides, why did the Company exclude it from its $36 million “promotion related” SG&A disclosure? > Herbalife’s 2011 10K states that SG&A expenses are comprised of “labor and benefits, sales events, professional fees, travel and entertainment, distributor marketing, occupaney costs, communication costs, bank fees, depreciation and amortization, foreign exchange gains and losses and other miscellaneous operating expenses.” © Please break down the $1.1 billion of 2011 SG&A expenses into each of these categories. © Ifonly $36 million of Herbalife’s $1.1 billion of 2011 SG&A expense wi related,” what did you spend the other ~$1 billion on? ‘promotion Page 17> Why is there no operating leverage in SG&A? > Are VAT payments included in SG&A? Herb: Buyback Policy > In its response to Pershing Square’s presentation, management stated that “if somebody wishes to return product, we make it very easy for them to do that.” (Des Walsh, January 10, 2013) Recently, the FTC released 188 complaints against Herbali product is a recurring theme throughout many of these complaints. on its website. A distributor’ ability to return © How does the Company reconcile its statement that returning product for a refund is “easy” with these numerous complaints? > Herbalife’s presentation states that “Herbalife buyback policy accepts either product purchased directly from the Company or in the “field.”” However, Herbalife’s Sales & Marketing Plan (p. 23) states that “if a customer requests a refund... Herbalife will exchange the returned product with the identical replacement product for the Distributor as soon as all the required documentation has been ived.” © Does Herbalife’s Buyback policy refund “field” purchases or does it simply allow for a product exchange? > Why did the Company only eliminate the 10% restocking fee in May 2012 and first introduce a buyback policy in Mexico in January 2013? Herbalife’s Numbers Don’t Add Up > According to page 59 of the Herbalife investor presentation, 60% of Herbalife’s volume is comprised of Non-Sales Leader purchases (assuming “purchases that do not qualify the purchaser for a royalty, bonus, or sales leader qualification” are made by Non-Sales Leaders). If 60% of volume is purchased by Non-Sales Leaders who are buying the product for self-consumption, and if 32% of volume is shipped directly to non-distributors who are buying the product for self- consumption, then only 8% of volume could have been purchased by Sales Leaders for daily consumption / Nutrition Clubs. This contradicts the Company's repeated statements that daily consumption / Nutrition Club volume accounts for 35% to 40% of Herbalife’s volume. © How can you reconcile these percentages? Page 18> Do the 60% of “Purchases that Do Not Qualify the Purchaser for a Royalty, Bonus, or Sales Leader Qualification” include purchases by Non-Sales Leaders that make them eligible to purchase product, at a higher discount level (ie. Non-Sales Leaders who are “working their way up to Supervisor”)? > In your May 2012 investor presentation you disclosed that “New Sales-Leader qualification volume percentage of total Volume” was only 16% in 2011. This is similar to the Company’s disclosure in its January 10" investor presentation that only 15.2% of volume is from “Volume Points That Meet New Sales Leader Qualification.” Based on the following observations, this number appears to be improbably low: © Excluding China, Herbalife reported 3,768 million Volume Points in 2011 16% of 3,768 implies 603 million Volume Points were generated from newly qualif Sales Leaders © Based on the increase in Sales Leaders disclosed by the Company in 2011, we estimate that there were ~217,000 New Sales Leaders who qualified in 2011 (excluding China) © Asaresult, in 2011, 217,000 distributors became New Sales Leaders by generating 603mm Volume Points, for an average of ~2,800 Volume Points per New Sales Leader. We note that 18% of New Sales Leaders in 2011 qualified using the “SK” method, which implies that New Sales Leaders who qualified in one month or two months did so with an average of ~2,300 Volume Points per New Sales Leader. This raises the following questions: = How can distributors qualify to become a New Sales Leader with fewer than 4,000 Volume Points? = In 2007, when the “SK” method did not exist, the average Volume Points per New Sales Leader was ~3,500. Is the decline in average Volume Points per New Sales Leader an indication that more and more distributors are using the “buddy system” to achieve Sales Leader status? What is the “buddy system” and how does it work? Is it a violation of the Company’s rules for distributors to use the “buddy system” to ‘qualify for supervisor and above? * Does the decline in average Volume Points per New Sales Leader potentially indicate that Herbalife is running out of new recruits who can afford to buy enough product to ign up as a Supervisor? Page 19Herbalife’s Argument that “Many Newer Entrants Can and Do Receive Higher Compensation than their Sponsors” > Inits response to Pershing Square’s December 20" presentation, the Company disclosed that 80% of Herbalife’s 100 top earners in 2011 earned more than their sponsor. © We note that Herbalife President's Team members are eligible to receive the discretionary Mark Hughes Bonus, = If you excluded this bonus from your analysis, what % of Herbalife’s top 100 earners in 2011 would have earned more than their sponsor? © Does this analysis include sponsors who are no longer distributors with Herbalife (i., even a Sales Leader who earned $1 would earn more than his or her sponsor if his or her sponsor is no longer a distributor)? > We note that Herbalife had ~500,000 Sales Leaders in 201 1. If you did the same analysis for all 500,000 Sales Leaders (instead of only looking at the top 100 eamers, or the top 0.02% of Sales Leaders), how many Sales Leaders earned more than their sponsor in 2011? > Management went on to say that “what you eam is based not on your placement but rather on your activity.” © What is the average gross compensation for Sales Leaders with between 0 and 5 distributors in their downline? What is the average gross compensation for Sales Leaders with between 5 and 15 distributors in their downline? Between 15 and 25? Between 25 and 50? Between 50 and 100? Between 100 and 150? More than 150? Distributor Turnover > Please state, for each of the past five years, how many people enrolled that year by distributor level. Of each annual group of new distributors, how many remained distributors at each succeeding year-end and what was their gross compensation? The data may be arranged as in this illustration: Page 20v v ae eyed {nut nie Conitos, Rat Ovni, Metin Bones, Mak Hates ome. et Of the group of distributors who resigned in each of the past five years, what was the average duration of their Herbalife distributorship? ‘Why did you stop disclosing the turnover rate for Non-Sales Leaders after 2005? Since the Company went public in 2004, how many distributors have reached President’s Team? How many distributors have become Sales Leaders? How many total new distributors have joined Herbalife? When a Sales Leader fails to requalify, is the Sales Leader removed from Herbalife’s distributor base or is the Sales Leader dropped to Non-Sales Leader status? What is the average amount of time it has taken for the Company’s current President’s Team members to reach President’s Team (calculated from the time they signed their Distributor Agreement)? Beginning in 2009, Herbalife reported “Total New Distributors” in its Regional Key Metrics supplement. We note that this metric, however, is not reported in any of Herbalife’s public financials (ie. 10-Ks/ 10-Qs). © Why doesn’t the Company include this metric in its audited financials? Page 21,> The Company's 2011 10K states that “Distributors who purchase our product for personal consumption or for short-term income goals may stay with us for several months to one year.” © This statement implies that 100% of Non-Sales Leaders tumover every year. Is this true? If not, what percentage turn over each year? > What has the Company’s annual processing fee for Non-Sales Leaders been for the last five years? Does the Company ever waive this fee? Wholesale Commissions > Inan Herbalife Q&A disclosure, Herbalife notes that “Wholesale Profit is paid by the company as a commission check.”* © How much did the Company pay distributors in Wholesale Commissions over the last five years (per year)? By region? > Why does Herbalife refer to Wholesale Profit as “single-level earnings” when commi jons can be “split” and paid to multiple levels of distributors (as shown in the Herbalife diagram from your Marketing Plan shown below)? 6: What are Split Commissions? ‘AG: Spitt Commission is the commission earned from 8 downline Distributor below & ‘Qualified Producer who is purchasing at less than 42% discount. A commission of 79% OF 1796 is first paid to the first upine Qualified Producer and the remaining 8% is paid to the first upline Fully Qualifed Superviser. Example 4 Page 22> Given that other multilevel marketers (“MLMs") (¢.g., Reliv International) account for Wholesale Commissions as an operating expense (Reliv International 2011 10K), why does Herbalife treat Wholesale Commissions as a reduction in net sales? > When a customer buys a TV from an electronics retailer for $1,000 and receives a $100 rebate, the retailer records $900 of net sales. This accounting treatment is appropriate because the purchasing customer receives the rebate: © Given that Herbalife pays Wholesale Commissions to upline distributors rather than to the distributor who purchases the product, why docs the Company account for these payments as if they were rebates, which has the effect of reducing the amount of recruiting rewards and ns shown on the Company’s income statement? > We note that Nu Skin “preferred customers” must purchase product at wholesale directly from Nu Skin. © What is the business rationale for the Company’s policy that does not require distributors to purchase product directly from Herbalife? > What percentage of Wholesale Commissions paid in 2011 were paid to Sales Leaders and what percentage were paid to Non-Sales Leaders? Deception and Income Claims > In its December 20, 2012 presentation, Pershing Square raised a number of material concems with Herbalife’s 201 | Statement of Average Gross Compensation, including disputing Herbalife’s representation that more than 25% of Distributors reach the rank of Supervisor, and the fact that 93% of Herbalife distributors who earn zero commissions were excluded from Herbalife’s presentation, > Aller questions from David Einhorn in May 2012, 2011 Herbalife modified its Statement of Average Gross Compensation in July 2012 to note that the dollar figures shown “are gross, not net income.” © What are the actual average and median net earnings for Herbalife distributors in each of the distributor levels? © Why didn’t you provide an estimate of the costs that are incurred by distributors at each tion shown, so that prospective distributors can figure out how much money they might actually make? earning level to achieve the gross compen Page 23,> In the Company's revised 2011 Statement of Average Gross Compensation for U.S. Supervisors, the median gross compensation for “Active” Leaders is $637. The median gross compensation for Total Leaders is $741. © How could the median compensation for Total Leaders be higher than it is for Active Leaders? > Why did the table in Herbalife’s Statement of Average Gross Compensation shown to all prospective distributors only include the average gross compensation for Active Leaders (approximately 7% of total U.S. Distributors as of 12/31/11) and exclude the 93% of distributors who received zero > In the Company's 2008 investor day presentation, Herbalife disclosed the amount of World Team, GET Team, Millionaire Team, and President’s Team members as of Q3’08 (excluding China): 75,234 World Team; 14,057 GET Team; 3,284 Millionaire Team; 1,200 President’s Team (incl. 36. Chairman's Club) © Based on this disclosure, there were 5.4 times more World Team members than GET ‘Team members in 2008. But in the 2008 Statement of Average Gross Compensation for ULS. Supervisors, World Team represented 2.7% of Total Leaders and GET Team represented 2.2% of Total Leaders, which implies there were only 1.2x more World ‘Team members than GET Team members (in the U.S.). What explains the discrepancy between these ratios? To the extent Herbalife only included “Active” World Team members in its 2008 Statement of Gross Compensation, is the definition of an “Active” World Team member the same as the definition of an “Active” Supervisor? © Multiplying the “Average Earnings” in Herbalife’s 2008 Statement of Average Gross ‘Compensation for World Team, GET Team, Millionaire Team, and President’s Team members by the number of members in each category disclosed in the 2008 investor presentation implies Herbalife would have paid over $1.4bn in Royalty Overrides and Production Bonuses (and this does not even include the Supervisor level). However, in Herbalife’s 2008 10-K, the Company only paid $797mm in “Royalty Overrides” in 2008. Please explain the unexpected outcome of this calculation? Did Sales Leaders outside the U.S. earn approximately half as much as Sales Leaders in the U.S. > Please disclose a Statement of Average Gross (and Net) Compensation in 2011 for all Herbalife distributors (as opposed to just U.S. distributors), Page 24» Why don’t you provide a Statement of Average Gross (and Net) Compensation in 2011 for all of the countries in which Herbalife operates on your website so that distributors can have better transparency into the Herbalife business opportunity on a global basis? ® Inthe 2011 Statement of Average Gross Compensation for U.S. Supervisors, Active Leaders were reported as 39.4% of Total Leaders. In the 2011 Regional Key Metrics supplement (and in the 10K), Herbalife reported “Avg Active Sales Leaders” of 56,741, or 52.4% of Total Sales Leaders for the North America region. © Did Herbalife have a separate definition of “Active” for these various disclosures? If so, why? > Why is the Gross Compensation of members of the Founder's Circle and Chairman's Club who reside in the United States excluded from the 201] Statement of Average Gross Compensation for U.S. Supervisors? Why are you concerned about disclosing to rank-and-file distributors the enormous sums earned by these distributors at the top of the distribution structure? > Why do Herbalife Independent Distributor presentations claim “everything is really easy” given that only one out of every ~5,000 new Herbalife distributors" achieves an income level commensurate with Herbalife testimonial-based income claims? Herbalife Independent Distributor > What roles do Chairman's Club and Founder's Circle members play in the company’s operations, decisions, plans ete.? What is the average, highest, and lowest compensation paid to Chairman’s Club and Founder’s Circle members by the Company? > Your Sales & Marketing Plan states that Herbalife distributors “are prohibited from selling leads” and may not “earn any compensation (directly or indirectly) for referrals” of distributors to third party lead providers. (Rule 26-E(1),) © Are you aware that a substantial number of your senior-most distributors have affiliates (e.g. Income at Home, IOffice, Online Business Systems, Financial Success Systems, ete.), which sell leads and other business tools to Herbalife distributors for substanti money? J amounts of © What steps, if any, has Herbalife taken to enforce this rule? How many, if any, distributors have been disci ied for violating this rule? Page 25,v > © Ina November 28, 2007 investor presentation, Herbalife’s then-CFO stated the following: ThenorLatine business the US.isbeing driven primary bythe ead ~ internet ead capture system ad we ao couple that with sampling. That's been very, vr efetiv in unning mea ving people tothe website giving them ether a business or aproduct opportunity following up with sampling, Does Herbalife actively participate in or in any way fund the generation of “online leads” that are ultimately sold to Herbalife distributors? Js Herbalife aware that senior Herbalife distributors push new distributors to buy leads at substantial prices for as much as $130 per lead?” If Herbalife is truly a product company, then why are senior- distributor affiliates pushing new distributors to purchase leads? Do you believe that Herbalife has a duty to ensure that the income claims made in Independent Distributor presentations are consistent with reality? What steps, if any, has the Company taken to ensure that false or misleading claims are not made in Herbalife Independent Distributor presentations? Anthony Powell recently left Herbalife and claims to have taken 16,000 distributors with him to another MLM. Des Walsh stated that Powell “had a slightly different philosophy.” Herbalife spokesperson Barb Henderson said: “Anthony Powell’s stated focus is on creating ‘explosive growth’ fucled by lead purchases.” © Given Mr. Powell's 22 years with the Company, when did the Company discover that Mr. Powell and the Company had ‘a difference in philosophy’? © Why did the company pay Mark Hughes’ Bonuses to Mr. Powell over the last five years if the company did not support his business approach? © Do any other senior distributors (President’s Club, Chairman’s Club, and Founders Circle) “have different philosophies” and / or emphasize “lead purchases”? What are you doing to stop these distributors from engaging in inappropriate and / or illegal behavior? © Why does the Company selectively enforce its policy regarding distributors soliciting downlines to move to another MLM? Under what circumstances are policies not enforced? Was there a spi situation that enabled Powell to leave on good terms and Ford et al to wind up in court? Was there an agreement negotiated and / or executed between Herbalife and Anthony Powell or any of his businesses or subsidiaries around the time of his leaving? Was there any consideration paid by either party as the parties ‘agree(d) to part ways" ‘How much has the Company paid to settle legal disputes with distributors or former distributors each year for the past five years? How many distributors have been paid settlements by the Company during the last five years? Page 26the Lieberman Survey ® Please release the Lieberman surveys’ detailed findings, methodology, research design, question wording and ordering, participant demographies, and other details sufficient to enable the survey approach to be analyzed by an expert in survey methodology and design. > Why have you chosen to use Lieberman market research and public opinion data based on the survey of 2,000 participants to make claims about your customers instead of relying on internal Herbalife data and customer analysis based on your millions of supposed customers? > Does the Company have any other survey data on these same subjects, whether collected by Lieberman, the Company or other parties? Actual Retail Price > One of the most critical issues in determining whether or not Herbalife is a pyramid scheme is the retail price at which Herbalife products are resold to bona fide retail customers. Knowing the actual retail price would assist in calculating the actual Retail Profit eared by Herbalife distributors and in determining whether Herbalife “participants obtain their monetary benefits primarily from recruitment rather than the sale of goods and services to consumers.” See Peter J. Vander Nat & William W. Keep, Marketing Fraud: An Approach for Differentiating Multilevel Marketing from Pyramid Schemes, 21 J, Pub. Pol'y & Mktg. 139, 144 (Spring 2002). Given the importance of this issue: © Why didn’t the Company respond to Pershing Square’s analysis, based on pricing data obtained from independent Herbalife distributor websites and eBay that Herbalife products retail for approximately 35% less than adjusted SRP? co Why is the SRP of Herbalife multivitamin tablets more than three times the price of comparable multivitamins such as Centrum? © Why are Herbalife’s products offered at SRPs substantially higher than comparable products sold in retail stores around the world? © Why do Herbalife investor presentations refer to 100% of distributor allowances as “retail profit” (a statement which assumes products sell for 100% of adjusted SRP)? Page 27> Based on our assumptions for actual retail price, Wholesale Commissions, and internal consumption in the Pershing Square presentation, we estimated that the average Herbalife distributor earns approximately $5 per month in Retail Profit (before taxes / expenses). © Given that the Company did not respond to this claim, do you agree with our calculation? If not, what does the average Herbalife distributor earn per month in Retail Profit before expenses and taxes and what is the basis for your estimate? inancial Statements > Given what appears to be consistent annual cash flows in the business, why are there such dramatic and increasing fluctuations in the intra-quarter revolver amounts (¢.g., $581M in borrowings from Jong term debt and $633M in principal payments on long term debt in Q3 2012 alone)? > What percentage of Herbalife’s sales volume comes in the last five business days of each month? ‘What percentage of Herbalife’s Net Sales has occurred in January in each of the last five years? What percentage of Herbalife’s Net Sales has occurred in the last five business days of January in each of the last five years? > Why is it that 22% of the cash on Herbalife’s balance sheet as of 9/30/12 is domiciled in Venezuela, a country that represented only 3% of Herbalife’s net sales for the first nine months of 2012? » Why is it that only 1% of the cash on Herbalife’s balance sheet as of 9/30/12 is invested in U.S. dollars ($4.7mm) given that the U.S. represents approximately 20% of Herbalife’s total sales’ > What percentage of the Company's cash is dom led offshore? > Why are distributor allowances for Literature, Promotional and Other positive (whereas they are negative for all other product categories)? > Why are allowances for product returns accounted for as @ reduction to net sales as opposed (0 as an expense (i.e. a bad debt expense)? Discontinued Disclosure Items > Please explain the rationale for Herbalife discontinuing the following disclosure items: © In 2004, after reemerging as a public company, Herbalife stopped disclosing “Retail Sale: by country; Page 28© In 2005, Herbalife stopped disclosing distributor turnover; © In 2006, Herbalife stopped disclosing the tumover rate of Non-Sales Leaders; © In 2009, Herbalife stopped disclosing the number of President’s Team members; © In 2011, Herbalife stopped disclosing New Sales Leaders; © In 2011, Herbalife stopped disclosing worldwide events and promotions expenditures; and © In 2011, Herbalife stopped disclosing the composition of Non-Sales Leaders by discount bracket (until David Einhorn asked about it) Enforcement of Herbalife Rules > The United States Court of Appeals for the 9th Circuit held in Onmitrition that evidence of “the actual effectiveness of ... anti-pyramiding distribution rules” is “crucial” in determining whether MLM programs constitute a pyramid scheme. See Webster v. Onmitrition, 79 F.3d 776, 783-84 (9th Cir. 1996) (emphasis in original); see also id. (“there must be evidence that the program’s safeguards are enforced and actually serve to deter inventory loading and encourage retail sales” (emphasis added)), © What proof does Herbalife have of the “actual effectiveness” of its 70% rule and 10- customer rule? In each of the past five years: How many Herbalife distributors in the U.S. were (i) audited and (ii) disciplined for failure to sell product to at least 10 separate retail customers in a given month (over the last five years)? When a distributor purchases Herbalife product for personal use, can that purchase be used to satisfy the 10-customer rule? * How many Herbalife distributors in the U.S. were (i) audited and (ii) disciplined for failing to sell to retail customers and/or sell at wholesale to downline distributors at least 70% of the total value of Herbalife products they retained for resale (over the last five years)? = What group or department within Herbalife conducts audits for compliance with respect to these rules? Why don’t you publicize the results of whatever compliance audits you do perform? © Inthe Ford case, Judge Fees noted in 2009 that he had “serious question[s] as to whether or not” the Herbalife 10-customer rule and 70% rule “are not exalting form over substance and Page 29