This evening, the ever-fabulous Alice Dreger brought an important ongoing Twitter conversation to my attention. Several folks, including Amanda Michelle and others, had sounded the alarm about a company, Use to Believe, that was making misleading, scientifically-unsupported claims about products being sold on their website.
For example, the website claims that their lubricant, ProLube, can protect against HIV and other sexually transmitted infections.
For example, the website claims that their lubricant, ProLube, can protect against HIV and other sexually transmitted infections.
They also claim that, based on "Real Customer Use Experience", a product called ProHP can treat genital and oral herpes.
The site makes numerous other unsupported claims, as detailed by Emmeline Peaches in this blog post, which also includes infuriating quotes from the company on Twitter.
What can a concerned citizen do in a case like this? When it comes to misleading advertising on health-related products being sold in the United States, "The Federal Trade Commission combats...deceptive advertising in coordination with the Food and Drug Administration". For example, Food and Drug Administration (FDA) has a program called "Bad Ad" where individuals can submit complaints about misleading advertising on prescription products.
In the case of non-prescription products, like ProLube, individuals can submit complaints to the Federal Trade Commission (FTC) through its FTC Complaint Assistant.
What can a concerned citizen do in a case like this? When it comes to misleading advertising on health-related products being sold in the United States, "The Federal Trade Commission combats...deceptive advertising in coordination with the Food and Drug Administration". For example, Food and Drug Administration (FDA) has a program called "Bad Ad" where individuals can submit complaints about misleading advertising on prescription products.
In the case of non-prescription products, like ProLube, individuals can submit complaints to the Federal Trade Commission (FTC) through its FTC Complaint Assistant.
While it takes only a few minutes to do this, the forms may be a bit intimidating. Below is an example of how I filled out the FTC complaint I just submitted on this company, in hopes that it will encourage others to do the same when they see a concerning situation like this arise.
1. I went to this website: www.ftccomplaintassistant.gov.
2. On page that says “Select a category below”, I clicked “Other”.
3. When a menu pulled up, I clicked “Health and Fitness”.
4. On page asking “How were you contacted?”, I clicked “Other/Not applicable”.
5. On page asking "Is your complaint related to”, I clicked “Other Medical Products, Supplies, or Treatments”.
6. When asked “Do you have a complaint about”, I clicked “Medical Products or Supplies”.
7. When asked “Did you order an item and have yet to receive it?”, I clicked “No”.
8. When asked “Do you have concerns regarding the privacy of your information with the company?”, I clicked “No”.
9. The next page said “In just a few moments, you will be able to tell your story in your own words. But first we would like to collect some additional information”. I clicked “Continue”.
10. On the “Complaint Detail Information” page, instructions noted “Information on this form may not apply to your complaint. Please fill out only fields that are applicable to your situation.” So, I left all forms blank, because they did not apply.
11. On “Company Information Page”, I filled in the small bit of information that I had about this company, including the Company Name ("Use to Believe"), the company email ([email protected]), and the company website (www.usetobelieve.com). [Note that the form is pretty finicky about it being entered in a www.[text].com format.]
(Addendum 1-3-2016: Ziad Fazel kindly provided additional information about the company via WHOIS, which others may be able to use if/when they submit a complaint to FTC about this company. Thanks, Ziad!)
1. I went to this website: www.ftccomplaintassistant.gov.
2. On page that says “Select a category below”, I clicked “Other”.
3. When a menu pulled up, I clicked “Health and Fitness”.
4. On page asking “How were you contacted?”, I clicked “Other/Not applicable”.
5. On page asking "Is your complaint related to”, I clicked “Other Medical Products, Supplies, or Treatments”.
6. When asked “Do you have a complaint about”, I clicked “Medical Products or Supplies”.
7. When asked “Did you order an item and have yet to receive it?”, I clicked “No”.
8. When asked “Do you have concerns regarding the privacy of your information with the company?”, I clicked “No”.
9. The next page said “In just a few moments, you will be able to tell your story in your own words. But first we would like to collect some additional information”. I clicked “Continue”.
10. On the “Complaint Detail Information” page, instructions noted “Information on this form may not apply to your complaint. Please fill out only fields that are applicable to your situation.” So, I left all forms blank, because they did not apply.
11. On “Company Information Page”, I filled in the small bit of information that I had about this company, including the Company Name ("Use to Believe"), the company email ([email protected]), and the company website (www.usetobelieve.com). [Note that the form is pretty finicky about it being entered in a www.[text].com format.]
(Addendum 1-3-2016: Ziad Fazel kindly provided additional information about the company via WHOIS, which others may be able to use if/when they submit a complaint to FTC about this company. Thanks, Ziad!)
12. On the “Consumer information” page, I filled out my personal information.
13. On the “Additional information” page, you can describe your concern. I wrote: “I am a reproductive health professional and concerned citizen. Several individuals on Twitter have raised attention to unsupported claims made by the company "Use to Believe". An overview is provided in this post: http://emmelinepeachesreviews.com/2016/01/02/some-thoughts-on-prolube-and-scam-products/. In brief, the company makes numerous claims, including that their lubricant, ProLube, protects against HIV. For example, the following page (http://usetobelieve.com/sex-workers/) states: "Once ProLube is applied, it will give 12 hours of protection from Sexually Transmitted Diseases including HIV." Another page advertises a product called ProHP with claims that customer use experience indicates that this gel treats genital and oral herpes. I have screenshots available in case of use. There is very little information about the location or management of this company on their website, but they have a Twitter account (@usetobelieve) and request donations via PayPal. I hope FTC will be able to follow up and ensure that consumers do not fall prey to these unsupported and dangerous claims.”
It's that's easy! Soon after I submitted the complaint on the website, I got an email from FTC with a reference number for my complaint.
Many thanks to all who raised attention to this issue! I'll sleep better tonight knowing that the FTC is aware, and can hopefully take action to prevent unsuspecting consumers from purchasing unproven, and potentially dangerous, sexual health products.
Addendum 1-4-16: It is somewhat unclear whether this company is based in the United States or not. The website server appears to be in San Jose, California, but the physical address of the domain owner appears to be San Jose, Costa Rica. If I receive any information from FTC on what they are and are not able to do, I will provide updates here.
Addendum 1-12-16: The great folks at Sense About Science asked me to write a short blog on this whole situation as part of their excellent #AskForEvidence campaign. Some interesting updates regarding how the company responded are described in the piece. Thanks to Sense about Science for helping to amplify!
13. On the “Additional information” page, you can describe your concern. I wrote: “I am a reproductive health professional and concerned citizen. Several individuals on Twitter have raised attention to unsupported claims made by the company "Use to Believe". An overview is provided in this post: http://emmelinepeachesreviews.com/2016/01/02/some-thoughts-on-prolube-and-scam-products/. In brief, the company makes numerous claims, including that their lubricant, ProLube, protects against HIV. For example, the following page (http://usetobelieve.com/sex-workers/) states: "Once ProLube is applied, it will give 12 hours of protection from Sexually Transmitted Diseases including HIV." Another page advertises a product called ProHP with claims that customer use experience indicates that this gel treats genital and oral herpes. I have screenshots available in case of use. There is very little information about the location or management of this company on their website, but they have a Twitter account (@usetobelieve) and request donations via PayPal. I hope FTC will be able to follow up and ensure that consumers do not fall prey to these unsupported and dangerous claims.”
It's that's easy! Soon after I submitted the complaint on the website, I got an email from FTC with a reference number for my complaint.
Many thanks to all who raised attention to this issue! I'll sleep better tonight knowing that the FTC is aware, and can hopefully take action to prevent unsuspecting consumers from purchasing unproven, and potentially dangerous, sexual health products.
Addendum 1-4-16: It is somewhat unclear whether this company is based in the United States or not. The website server appears to be in San Jose, California, but the physical address of the domain owner appears to be San Jose, Costa Rica. If I receive any information from FTC on what they are and are not able to do, I will provide updates here.
Addendum 1-12-16: The great folks at Sense About Science asked me to write a short blog on this whole situation as part of their excellent #AskForEvidence campaign. Some interesting updates regarding how the company responded are described in the piece. Thanks to Sense about Science for helping to amplify!
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