Dietary supplements + unlawful medical claims


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

Avini Well being doesn’t present a company handle on its web site or social media profiles however seems to be primarily based 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 trade.”

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

Neil Roth “has over 45 years of expertise within the client merchandise trade and company administration of huge companies.”

Mr. Roth persistently led double-digit development in gross sales and income at the entire 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 marketing consultant in addition to president of a medical diagnostics firm and electrical automobile 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 International.

I used to be solely in a position to confirm this by stumbling throughout third-party advertising movies for Navan International.

Not surprisingly Rik Deitsch, aka Erik Deitsch, was additionally concerned in Navan International. Deitsch appeared in advertising movies as a member of Navan International’s company staff.

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

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

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

repeatedly engaged in manipulative trades of Nutra Pharma inventory by submitting orders to purchase shares at costs greater than the sellers’ ask costs with the intention to “stroll up” the inventory value.

The SEC’s investigation additionally revealed that Nutra Pharma Corp’s “cobra venom” MyNyloxin advertising 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 in opposition to 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 International subsequently collapsed, Avini Well being launched in early 2022.

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

Avini Well being’s Merchandise

Avini Well being markets a spread of dietary dietary supplements.

  • Plus Cardio Care – “supplies the entire vitamins to assist your entire 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 take care of 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 Reduction 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 Reduction – “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 preserve 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 vitality shot that will help you energy by 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 – “support 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 cleansing”, retails at $69 for a bath of 30 servings

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

Be aware that with the intention to depend 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.

Be aware 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 by a restricted unilevel compensation construction.

Sometimes 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 staff.

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

Be aware that direct leg positioning continues to be attainable if a distributor inside the restricted unilevel staff recruits a brand new distributor and all three positions under them haven’t been crammed but.

Be aware 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 by 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 by way of 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 primarily based 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 blended bag throughout its merchandise, advertising of mentioned merchandise and compensation. Let’s begin with Avini Well being’s merchandise and advertising.

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 Reduction 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 in a position to definitively backdate Deitsch’s questionable advertising claims to August 2020.

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

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

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

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

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

This distributor promotes Avini Well being as an alternative choice to drugs:

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

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

Deitsch pitches Avini Well being’s merchandise as with the ability to “repair the physique”, which in flip is then in a position to “repair itself”. The implication being one can simply take Avini Well being dietary supplements and cast off accredited medicines and coverings.

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

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

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

It’s the authentic colloidal clinoptilolite zeolite product and is supported by over a dozen scientific 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 “whitepaper” for Cell Defender however which isn’t a research of Cell Defender and solely focuses on the ingredient clinoptilolite
  • a 2020 “authentic analysis” paper detailing a research on a Navan International complement
  • a 2004 research on clinoptilolite injected into mice
  • a 2009 research pertaining to a Waiora complement
  • a 2018 “important overview on zeolite clinoptilolite security and medical purposes in vivo” that doesn’t reference Avini Well being or its merchandise
  • a 2020 summary of a research on activated clinoptilolite that doesn’t point out Avini Well being or its merchandise
  • a 2022 “product overview” advertising doc pertaining to Zmunity Mushrooms

Avini Well being fails to supply a single peer-reviewed research 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 accredited for therapy of any ailments would undermine any offered precise research.

Avini Well being’s compensation plan is first rate sufficient however the advertising 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 will be put in direction of future product orders.

Quantity from retail prospects nevertheless 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 strategy to buy merchandise, is closely pushed as a manner 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 have to generate retail prospects to qualify for commissions.

AVINI HEALTH AUTOSHIP PROGRAM: Out there solely to Distributors. AVINI HEALTH gives a easy and simple strategy 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 claims
  • dietary supplements being marketed as an alternative choice to drugs, able to treating and/or stopping numerous ailments
  • 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 averted.

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.