Supplements + illegal medical claims


Avini Well being operates within the dietary complement MLM area of interest.

Avini Well being doesn’t present a company deal with on its web site or social media profiles however seems to be based mostly out of the US.

Heading up Avini Well being are “leaders” Doug Dickey (VP of gross sales), Rik Deitsch (CSO) and Neil Roth (CEO).

Doug Dickey’s Avini Well being company bio cites him with “greater than 20 years working as a CEO, CFO within the fertilizer and plant diet business.”

Douglas has additionally been profitable within the community advertising and marketing business with a number of corporations in addition to just lately changing into a Diamond degree distributor in lower than 8 months.

Neil Roth “has over 45 years of expertise within the shopper merchandise business and company administration of enormous companies.”

Mr. Roth persistently led double-digit progress in gross sales and income at all the corporations by which he served as a high govt.

For the previous twenty-five years, Mr. Roth has labored as a extremely sought-after advertising and marketing advisor in addition to president of a medical diagnostics firm and electrical car firm.

Dickey and Roth seem to have gone to some effort to cover specifics of their MLM previous. Previous to Avini Well being each Dickey and Roth had been concerned in Navan World.

I used to be solely capable of confirm this by stumbling throughout third-party advertising and marketing movies for Navan World.

Not surprisingly Rik Deitsch, aka Erik Deitsch, was additionally concerned in Navan World. Deitsch appeared in advertising and marketing movies as a member of Navan World’s company group.

Navan World was a CBD oil MLM alternative run by Trey Knight. Knight was indicted for wire fraud in 2021, successfully bringing Navan World to an in depth.

Previous to Navan World Deitsch was CEO of Nutra Pharma Corp. Via MyNyloxin, Nutra Pharma Corp ran a cobra venom ache reduction MLM alternative.

In 2018 the SEC sued Nutra Pharma Corp and Deitsch. Of their Grievance the SEC alleged, amongst different issues, that Deistch;

repeatedly engaged in manipulative trades of Nutra Pharma inventory by submitting orders to purchase shares at costs larger than the sellers’ ask costs to be able to “stroll up” the inventory worth.

The SEC’s investigation additionally revealed that Nutra Pharma Corp’s “cobra venom” MyNyloxin advertising and marketing claims had been bogus.

Nutra Pharma by no means had a cobra farm, by no means had cobras, and certainly had by no means produced cobra venom.

Deitsch settled the SEC’s fraud costs towards him in April 2024. As a part of his SEC settlement, Deitsch paid $44,046 in disgorgement, $5013 in prejudgment curiosity and a $30,000 civil penalty.

Roughly six months after Trey Knight was indicted and Navan World subsequently collapsed, Avini Well being launched in early 2022.

Learn on for a full evaluate of Avini Well being’s MLM alternative.

Avini Well being’s Merchandise

Avini Well being markets a variety of dietary dietary supplements.

  • Plus Cardio Care – “supplies all the vitamins to assist the complete cardiovascular system”, retails at $69 for a bottle of 90 capsules
  • Plus Thoughts and Imaginative and prescient – “a singular mixture of vitamins and herbs … which work in live performance to keep up and improve mind and nervous system capabilities in addition to promote visible acuity”, retails at $69 for a bottle of 90 capsules
  • Cell Defender for Pets – “helps take away heavy metals and toxins from” pets, retails at $55 for a tube of 90 servings
  • Plus Aid for Pets – “non-narcotic, non-addictive ache reduction”, retails at $55 for a 3.4 oz tube of gel
  • Plus Hydration – “speedy re-hydration”, retails at $55 for a bath of 30 servings or $69 for a field of thirty single-serve sachets
  • Plus Aid – “homeopathic ache reliever formulated to help pores and skin penetration with no scent or dyes”, retails at $69 for a 2 oz roll-on bottle, $69 for a 2 oz bottle of gel, $69 for a 1 oz oral spray bottle or $219 for an 8 oz gel pump bottle
  • Cell Defender – “assist take away heavy metals, toxins, and different substances from the physique; Assist a wholesome immune system; and Assist stability pH ranges within the physique”, retails at $69 for a 1 oz plastic bottle of $79 for a 1 oz glass bottle
  • Plus Fiber – “scientifically formulated to assist keep wholesome ldl cholesterol, blood sugar ranges, and assist digestive intestine well being”, retails at $75 for a 450 g tub
  • Zmunity Mushrooms – ” a pure complement comprised of micronized, activated zeolite (clinoptilolite) and a micronized mix of seven licensed natural, non-GMO medicinal mushrooms”, retails at $89 for a bottle of 60 capsules
  • Plus Power – “an all-natural scientifically formulated adaptogenic power shot that can assist you energy via your day”, retails at $36 for six 2 fl oz bottles
  • Nano Silver – “helps a wholesome immune system”, retails at $89 for a 4 oz spray bottle or $60 for a 3.4 oz gel tube
  • TrimScience – “help in weight administration by burning fats (thermogenesis), blocking carbohydrate absorption (alpha-amylase inhibition), stopping the creation of recent fats (lipid biosynthesis), urge for food suppression (satiety) and systemic detoxing”, retails at $69 for a bath of 30 servings

Avini Well being’s dietary supplements are additionally out there in varied discounted bundle packs.

Avini Well being’s Compensation Plan

Avini Well being doesn’t present compensation plan particulars on its web site.

The next breakdown is put collectively from an official Avini Well being advertising and marketing presentation dated March 2024.

Avini Well being Distributor Ranks

There are twenty-seven distributor ranks inside Avini Well being’s compensation plan.

Together with their respective qualification standards, they’re as follows:

  1. Silver Apprentice – refer one retail buyer, recruit two distributors and generate and keep 100 PV and 500 GV a month
  2. Silver Director – keep one personally referred retail buyer, two personally recruited distributors and 100 PV a month, and generate and keep 1000 GV a month
  3. Silver Govt – keep one personally referred retail buyer, two personally recruited distributors and 100 PV a month, and generate and keep 1500 GV a month
  4. Gold Apprentice – keep 100 PV a month, refer two retail prospects, recruit three distributors and generate and keep 2000 GV a month
  5. Gold Director – keep 100 PV a month, two personally referred retail prospects, three personally recruited distributors and generate and keep 3000 GV a month
  6. Gold Govt – keep 100 PV a month, two personally referred retail prospects, three personally recruited distributors and generate and keep 4000 GV a month
  7. Sapphire Apprentice – keep 100 PV a month and three personally recruited distributors, refer three retail prospects and generate and keep 5000 GV a month
  8. Sapphire Director – keep 100 PV a month, three personally referred retail prospects and three personally recruited distributors and generate and keep 7500 GV a month
  9. Sapphire Govt – keep 100 PV a month, three personally referred retail prospects and three personally recruited distributors, the generate and keep 10,000 GV a month
  10. Ruby Apprentice – keep 100 PV a month, refer 4 retail prospects, recruit 4 distributors and generate and keep 15,000 GV a month
  11. Ruby Director – keep 100 PV a month, 4 personally referred retail prospects and 4 personally recruited distributors, and generate and keep 20,000 GV a month
  12. Ruby Govt – keep 100 PV a month, 4 personally referred retail prospects and 4 personally recruited distributors, and generate and keep 25,000 GV a month
  13. Emerald Apprentice – refer six retail prospects, recruit six distributors, and generate and keep 200 PV and 35,000 GV a month
  14. Emerald Director – keep 200 PV a month, six personally referred retail prospects and 6 personally recruited distributors, and generate and keep 35,000 GV a month
  15. Emerald Govt – keep 200 PV a month, six personally referred retail prospects and 6 personally recruited distributors, and generate and keep 45,000 GV a month
  16. Diamond Apprentice – keep 200 PV a month, refer eight retail prospects, recruit eight distributors and generate and keep 75,000 GV a month
  17. Diamond Director – keep 200 PV a month, eight personally referred retail prospects and eight personally recruited distributors, and generate and keep 100,000 GV a month
  18. Diamond Govt – keep 200 PV a month, eight personally referred retail prospects and eight personally recruited distributors, and generate and keep 125,000 GV a month
  19. White Diamond Apprentice – keep 200 PV a month, eight personally referred retail prospects and eight personally recruited distributors, and generate and keep 175,000 GV a month
  20. White Diamond Director – keep 200 PV a month, eight personally referred retail prospects and eight personally recruited distributors, and generate and keep 250,000 GV a month
  21. White Diamond Govt – keep 200 PV a month, eight personally referred retail prospects and eight personally recruited distributors, and generate and keep 350,000 GV a month
  22. Blue Diamond Apprentice – keep 200 PV a month, eight personally referred retail prospects and eight personally recruited distributors, and generate and keep 500,000 GV a month
  23. Blue Diamond Director – keep 200 PV a month, eight personally referred retail prospects and eight personally recruited distributors, and generate and keep 750,000 GV a month
  24. Blue Diamond Govt – keep 200 PV a month, eight personally referred retail prospects and eight personally recruited distributors, and generate and keep 1,000,000 GV a month
  25. Black Diamond Govt – keep 200 PV a month, eight personally referred retail prospects and eight personally recruited distributors, and generate and keep 1,125,000 GV a month
  26. Black Diamond Presidential – keep 200 PV a month, eight personally referred retail prospects and eight personally recruited distributors, and generate and keep 1,750,000 GV a month
  27. Black Diamond Ambassador – keep 200 PV a month, eight personally referred retail prospects and eight personally recruited distributors, and generate and keep 2,500,000 GV a month

Word that to be able to rely in direction of rank qualification, retail prospects should have positioned a product order within the qualifying month.

PV stands for “Private Quantity”. PV is gross sales quantity generated by retail buyer orders and a distributor’s personal orders.

Word that Avini Well being penalizes distributors for producing retail gross sales by solely counting 50% of generated retail gross sales quantity per order.

GV stands for “Group Quantity”. GV is complete PV generated by a distributor and their downline.

Avini Well being tracks GV via a restricted unilevel compensation construction.

Usually in a unilevel compensation construction if any degree 1 distributors recruit new distributors, they’re positioned on degree 2 of the unique distributor’s unilevel group.

If any degree 2 distributors recruit new distributors, they’re positioned on degree 3 and so forth and so forth down a theoretical infinite variety of ranges.

Avini Well being caps positions underneath every unilevel group place at three. On this sense, after the primary three positions on degree 1 have been established, Avini Well being’s unilevel group fills like a 3xx matrix. Manually positioning can also be permitted.

Word that direct leg positioning remains to be attainable if a distributor inside the restricted unilevel group recruits a brand new distributor and all three positions beneath them haven’t been stuffed but.

Word Avini Well being restricts required GV as per the next recruitment leg limits:

  • Silver ranks are capped at 80% of required GV from one recruitment leg
  • Gold and Sapphire ranks are capped at 70% of required GV from one recruitment leg and as much as 25% from a second leg
  • Ruby ranks are capped at 60% of required GV from one recruitment leg and as much as 35% from a second leg
  • Emerald via White Diamond ranks are capped at 50% of required GV from one recruitment leg and 35% from a second leg
  • Blue Diamond and Black Diamond ranks are capped at as much as 40% of required GV from two recruitment legs (every)

Retail Commissions

Avini Well being pays a 20% fee on gross sales quantity generated through retail gross sales.

Recruitment Commissions

Avini Well being distributors earn a fee on distributor recruitment:

  • recruit a $299 Enrollment Pack distributor and obtain $75
  • recruit a $499 Enrollment Pack distributor and obtain $125
  • recruit at $799 Enrollment Pack distributor and obtain $270

Residual Commissions

Avini Well being pays month-to-month residual commissions based mostly on rank:

  • Silver Apprentices earn $60 a month
  • Silver Administrators earn $120 a month
  • Silver Executives earn $180 a month
  • Gold Apprentices earn $240 a month
  • Gold Administrators earn $360 a month
  • Gold Executives earn $480 a month
  • Ruby Apprentices earn $550 a month
  • Ruby Administrators earn $800 a month
  • Ruby Executives earn $1100 a month
  • Ruby Apprentices earn $1500 a month
  • Ruby Administrators earn $2000 a month
  • Ruby Executives earn $2500 a month
  • Emerald Apprentices earn $3250 a month
  • Emerald Administrators earn $4000 a month
  • Emerald Executives earn $5000 a month
  • Diamond Apprentices earn $6000 a month
  • Diamond Administrators earn $8000 a month
  • Diamond Executives earn $9000 a month
  • White Diamond Apprentices earn $12,500 a month
  • White Diamond Administrators earn $17,500 a month
  • White Diamond Executives earn $25,000 a month
  • Blue Diamond Apprentices earn $35,000 a month
  • Blue Diamond Administrators earn $52,500 a month
  • Blue Diamond Executives earn $70,000 a month
  • Black Diamond Executives earn $80,000 a month
  • Black Diamond Presidentials earn $110,000 a month
  • Black Diamond Ambassadors earn $160,000 a month

Matching Bonus

Avini Well being pays Sapphire Apprentices and better a Matching Bonus on residual commissions earned down two ranges of recruitment:

  • a 7% match is paid on degree 1 (personally recruited distributors)
  • a 5% match is padi on degree 2

Rank Achievement Bonus

Avini Well being pays distributors for qualifying at “govt” ranks with the next one-time Rank Achievement Bonuses:

  • qualify at Silver Govt and obtain $150
  • qualify at Gold Govt and obtain $500
  • qualify at Sapphire Govt and obtain $1000
  • qualify at Ruby Govt and obtain $2000
  • qualify at Emerald Govt and obtain $4000
  • qualify at Diamond Govt and obtain $7500
  • qualify at White Diamond Govt and obtain $15,000
  • qualify at Blue Diamond Govt and obtain $30,000
  • qualify at Black Diamond Ambassador and obtain $50,000

Becoming a member of Avini Well being

Avini Well being distributor membership requires buy of a $299, $499  or $799 Enrollment Pack.

The first distinction between the Enrollment Packs is bundled Avini Well being merchandise.

Avini Well being Conclusion

Avini Well being is a combined bag throughout its merchandise, advertising and marketing of mentioned merchandise and compensation. Let’s begin with Avini Well being’s merchandise and advertising and marketing.

In mild of Rik Deitsch’s latest Nutra Pharma Corp SEC settlement, Avini Well being promoting a “cobra venom” product is the plain elephant within the room.

Does Avini Well being’s Plus Aid comprise cobra venom? Or would one other SEC investigation result in repeat allegations of fraud?

I can’t reply that however given Deitsch’s Nutra Pharma Corp settlement I’m extremely suspect.

I used to be capable of definitively backdate Deitsch’s questionable advertising and marketing claims to August 2020.

Amid the early onset of the COVID-19 pandemic, Deitsch was shilling substances in Navan World dietary supplements as a “broad spectrum anti-viral agent”.

Whereas it does slap FDA disclaimers on its product pages, Avini Well being’s advertising and marketing is riddled with unlawful medical claims.

Avini Well being’s unlawful medical claims begins with the corporate’s brand:

Avini Well being markets Plus Fiber as a preventative for “heart problems”:

Zmunity Mushrooms purportedly “cut back the danger of coronary heart illness”:

This distributor promotes Avini Well being as a substitute for medication:

The identical distributor additionally weaves in most cancers into her Avini Well being advertising and marketing:

This seems to stem from the top-down, with Rik Deitsch himself:

Deitsch pitches Avini Well being’s merchandise as having the ability to “repair the physique”, which in flip is then capable of “repair itself”. The implication being one can simply take Avini Well being dietary supplements and eliminate authorized medicines and coverings.

This isn’t solely unlawful as per the Federal Meals and Drug and FTC Acts, it’s additionally probably harmful if individuals with life-threatening medical circumstances are focused.

In an try and assist their medical claims, Avini Well being cites “medical research … revealed in peer-reviewed journals”.

Cell Defender is the one micronized and activated zeolite colloidal suspension on the earth.

It’s the authentic colloidal clinoptilolite zeolite product and is supported by over a dozen medical research – together with trials revealed in peer-reviewed journals.

To that finish Avini Well being has a “scientific analysis” part on its web site.

Right here we discover:

  • a 2021 advertising and marketing “whitepaper” for Cell Defender however which isn’t a examine of Cell Defender and solely focuses on the ingredient clinoptilolite
  • a 2020 “authentic analysis” paper detailing a examine on a Navan World complement
  • a 2004 examine on clinoptilolite injected into mice
  • a 2009 examine pertaining to a Waiora complement
  • a 2018 “vital evaluate on zeolite clinoptilolite security and medical functions in vivo” that doesn’t reference Avini Well being or its merchandise
  • a 2020 summary of a examine on activated clinoptilolite that doesn’t point out Avini Well being or its merchandise
  • a 2022 “product overview” advertising and marketing doc pertaining to Zmunity Mushrooms

Avini Well being fails to offer a single peer-reviewed examine backing and of the medical claims it and its distributors make with respect to its dietary supplements.

Even when they existed, Avini Well being’s dietary supplements not being authorized for therapy of any illnesses would undermine any offered precise research.

Avini Well being’s compensation plan is first rate sufficient however the advertising and marketing of it’s contradictory.

To their credit score Avini Well being does have retail buyer necessities. Retail Avini Well being prospects obtain rewards factors, which might be put in direction of future product orders.

Quantity from retail prospects nonetheless is penalized by 50% although. In the meantime quantity from recruited Avini Well being distributors is at all times counted at a “1 to 1 ratio of {dollars} spent”.

Autoship, which ought to solely ever be used as a handy approach to buy merchandise, is closely pushed as a approach for Avini Well being distributors to qualify for commissions.

The contradiction right here is autoship recruitment can nonetheless occur in Avini Well being however you continue to must generate retail prospects to qualify for commissions.

AVINI HEALTH AUTOSHIP PROGRAM: Obtainable solely to Distributors. AVINI HEALTH affords a easy and straightforward approach to obtain your merchandise month-to-month and qualify personally for downline payouts.

Placing all of this collectively we’ve got

  • dietary supplements tied to a person with not less than one documented run-in with a regulator over false advertising and marketing claims
  • dietary supplements being marketed as a substitute for medication, able to treating and/or stopping varied illnesses
  • no peer-reviewed research backing any of the medical claims getting used to market Avini Well being’s merchandise
  • a compensation plan that requires retail prospects however focuses primarily on autoship recruitment

Any MLM firm making unsubstantiated medical claims about its merchandise must be prevented.

And in the event you’re pitched on Avini Well being with unsubstantiated medical claims, a report back to the FDA and/or FTC might be a good suggestion.