Vitamin Lawyer Update Memo: February 27, 2008
This issue:
“Quackwatch” Exposed
Supplement Trends for 2008
Metabolic Syndrome
C&D Letters
FDA Gets Tough on Health Claims
Natural Solutions Panama ARC Project
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Tim Bolen has exposed the “quackwatch” methodology used to attack CAM practitioners, nutrient and natural remedy purveyors. Please read my blog on this important issue.
vitaminlawyerhealthfreedom .blogspot.com/2008/02/tim-bolen-exposes-quack-anti-health.html
[Please note: all links in this email are incomplete, with the “http://” and/or “www.” removed and an extra space before the .com, to avoid this message being treated as “spam” by AOL or other services.]
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Hartman outlines supplement trends for 2008 - By Lorraine Heller
nutraingredients-usa .com/news/ng.asp?n=83162&m=1NIU211&c=jegwylrviswtnqa
Feb-11-2008 - Healthy aging, balanced energy and inflammation are the three core health concerns that consumers try to address with dietary supplements,
according to a new report. The Hartman Group's Tinderbox on Trends 2008 draws its conclusions through ethnographic research, which includes consumer
interviews and observation in the home and in retail outlets. According to the research group, when a health concern presents itself, most consumers will first examine their diet. When food does not remedy the situation, they look to supplements, preferably from whole foods, to correct and balance their condition.
Supplements most popular with "leading-edge" or "core" consumers were those that addressed aging, energy and inflammation, said Hartman.
Although most supplement users are diligent when it comes to taking multi-vitamins, Hartman said that they tend to vary in their choice of supplements addressing
these three issues, either as they learn of new products, or as they shift focus from the one issue to another.
The group said consumers are "constantly searching for the latest supplement that may ease their condition or outperform a current supplement which is filling
nutritional holes missing from their diet".
Supplement use
Hartman divides supplement usage into three main categories: frequent, occasional and sporadic.
Frequent usage refers to those supplements that are taken on a daily basis in order to complement nutritional needs that are lacking from the diet. Ideally, consumers prefer 'daily' supplements to be sourced from whole foods sources.
These supplements are considered mainstays are taken daily and year-round as a preventative, said the group. Occasionally used supplements are those that are used to boost or alleviate a chronic condition or as a substitute for a prescription drug.
"Typically these supplements are taken from a few days to a week or until the bottle is finished. This demonstrates the core consumer's proactive approach to their
health," said Hartman.
Supplements that are sporadically used are those taken to alleviate an immediate health condition, or those that are tried for the first time. They are typically not taken in the long-term because consumers are unsure about their long-term use or possible side-effects.
Healthy mind and body
According to the report, consumers place a lot of emphasis on the balance between a healthy mind and body. Linked into this is the increasing search for natural methods to reduce low energy, sleep disturbances and anxiety. "Getting enough sleep, having sustained energy throughout the day and managing emotional ups and downs requires being present and truly paying attention to what their body and soul needs from day to day. When one element is out of balance, such as sleep or feeling blue, the whole person eventually needs tuning," said the report. "The core consumer looks to whole foods and the latest vitamin, mineral and herbal supplements in their quest for balancing mood, energy and sleep."
---------------------------------------------------------------
nytimes .com/2008/02/05/health/nutrition/05symp.html?_r=1&oref=slogin
"Researchers have found a correlation between drinking diet soda and metabolic syndrome — the collection of risk factors for cardiovascular disease and diabetes
that include abdominal obesity, high cholesterol and blood glucose levels, and elevated blood pressure... But the one-third who ate the most fried food increased their
risk by 25 percent compared with the one-third who ate the least, and surprisingly, the risk of developing metabolic syndrome was 34 percent higher among those
who drank one can of diet soda a day compared with those who drank none."
-------------------------------------------------------------
nutraingredients-usa .com/news/ng.asp?n=83202&m=1NIU212&c=jegwylrviswtnqa
How to respond to a Cease & Desist Letter
By James F. Ewing, Michelle A. Flores, and Michel Morency
Feb - 12 -2008 - Legal experts form Foley & Lardner suggest a strategy to help nutraceuticals companies respond to an accusation of infringing patent rights.
The nutraceuticals market is dynamic and competitive. As such, your nutraceuticals company may be subject to enforcement of another's patent rights. Receiving a
Cease & Desist letter ('the Letter') accusing you of infringing the patent rights of another is an unwelcome notice that can create a sense of urgency akin to having
been just set ablaze.
Being subject to enforcement of another's patent rights, however, is not an uncommon occurrence for successful businesses in competitive markets such as the
nutraceuticals market. Such letters usually identify the granted Patent(s) by its number(s), assert ownership to the Intellectual Property, and detail your alleged infringing activities as well as conditions and deadlines that are to be met.
To avoid being burned in such circumstances, you may consider implementing a STOP, DROP and ROLL approach. STOP and objectively consider the claims.
Implementing the STOP, DROP and ROLL approach does not mean that you need to immediately stop your business activities upon receiving a Cease & Desist
letter. However, whether the Letter demands that you cease making, using, or selling a particular product or service, or merely suggests that you might be interested in licensing certain patent(s), you should stop to carefully consider the allegation, and refer it to knowledgeable Counsel.
Being placed "on notice" of another's patent rights, is a legally significant event where you have a duty to act. Proactively addressing the concerns or demands of a
patent owner serves to protect your company and mitigate exposure to possible damages and fees for alleged willful conduct.
'DROP a Line' to experienced patent counsel Your response to the Letter should be timely, well-considered, and strategic.
Before responding you need to engage the services of knowledgeable patent counsel. This may involve one or more individuals with expertise in patent prosecution
and enforcement matters who can render an opinion regarding whether your commercial product or activities may infringe the patent claims asserted against you
and/or assess the validity of these claims, and develop an appropriate response strategy.
Enforcement issues can be highly complex and a skilled patent counsel will provide essential guidance to address the issues and assess the risks and potential
commercial impact against your company. Be prepared to 'ROLL with the Punches'...
Simply ignoring a Cease & Desist letter will not make the issue go away and may result in increased costs and liability for the accused patent infringer. The STOP,
DROP and ROLL approach provides a strategy to minimize potential adverse impacts in these situations.
James F. Ewing, Michelle A. Flores, and Michel Morency are attorneys with Foley & Lardner LLP.
[Yes, The Vitamin Lawyer does have C&D formats for your use....]
-------------------------
FDA gets tough on rogue health claims
By Alex McNally
nutraingredients-usa.com/news/ng.asp?n=83501&m=1NIU225&c=jegwylrviswtnqa
25-Feb-2008 -
Two companies have signed an agreement that prohibits them from claiming any of their products can cure, treat, mitigate or prevent diseases after making
unauthorized health claims. The Food and Drug Administration said both Cherry Capital Services and Brownwood Acres Foods have a history of promoting unapproved claims, such as "chemicals found in cherries may help fight diabetes." The terms of the consent decree mean the firms have to remove drug and unauthorized health claims from their labels, brochures and websites....
Margaret Glavin, associate commissioner for regulatory affairs, said: "The FDA will not tolerate unsubstantiated health claims that may mislead consumers. The FDA will pursue necessary legal action to make sure companies and their executives manufacture and distribute safe, truthfully labeled products to consumers."
...The US version of health claims was introduced a few years ago. Initially the legislation was beset by delays. Despite pledging that a response would be given to all claims submitted within 365 days, the FDA has exceeded this timeframe on a number of occasions. In one case the FDA was more than 300 days over an original
deadline for approval.
--------------------------------------
If you've been trying to reach me, you know I just got back from a quick trip to Panama. Awesome! Read on...
Natural Solutions Foundation in Panama was set up to research, educate and demonstrate natural solutions. Our shared vision is of an intentional community that links home sites (on a wonderful hillside with great views) with a natural wellness center/spa and organic+ farm and school, all on a 300 hectare (700+ acre) site that has never been farmed with chemicals. Currently, about ten acres are planted with organic coffee.
Our Panamanian legal entity is very flexible, combining the best aspects of a non-profit and a “private interest” entity that is allowed to form its own commercial enterprises. In keeping with the Songhai Principals, we see three “profit centers” for the project: the Wellness Center, the Organic+ Farm and School and what I call the Infrastructure Company, which provides transportation, communications, off-grid power, etc. to the center and farm school as well as the home sites. The Foundation will hold majority interest in the commercial entities, but there will be private investment opportunities.
The area is in the far north, by the Costa Rica border, against the 17,000 acre Amistad National Forest. Elevations vary from 3,000 to 5,000 feet above sea level. It is in the township of Santa Clara (Sacred Light) and is reached by modern road about an hour from the Vulcan eco-tourist area. The climate is year-round temperate (the woods look much like the woods of the US Northeast: similar evergreen, birch and other deciduous trees, deer and rabbits, but with coffee, banyan trees, plantains and howler monkeys too).
Gen. Stubblebine and Dr. Laibow have explored the area in recent months and I went there last week with a Natural Solutions supporter, guided by Kenneth Taylor, our Panamanian builder with experience in the area.
I am most impressed by Panama as a country where people have great hopes for the future... Panama City and the Canal area, where half of the 3 million population resides, is a very modern, thriving area with a huge building boom, very well developed banking and commercial sectors (the Singapore of the New World).
The Santa Clara area, to the far north, is pristine, flower filled and well connected to civilized amenities (international cuisine, locovore restaurants). It is becoming an eco-tourist center mostly because of the Vulcan Baru. The area is filled with ExPats from the US and Europe (20% of one town is American).
Land values are quite reasonable right now, but will not stay that way for long, as Americans and Europeans looking for more freedom than they can find at home, join the Panamanians in appreciating this land. Two hours away, in Boquete, land is bumping $100,000 per hectare (2.45 acres) – about 8 times our cost. Land taxes are very low and there is a 20 year tax holiday for new construction.
Because the land owners, who farm organically themselves, appreciate our vision, they are giving us a highly favorable financial arrangement and going far out of their way to work with us in a positive and helpful way. One of their sons, who lives on the land, would be ideal as a land manager for us. He is most amenable to that idea.
We are currently making arrangements to have the land surveyed, the soil and water tested and will be setting up preliminary meetings with architects to determine the number of building lots and areas. A generous donor has made that possible with a first gift for Panama.
We are now open for donations which, while fully tax deductible in the US, will allow the Natural Solutions Foundation to proceed with the development of our better than organic, advanced farming technology project complete with farm school for farmers from around the world -- teaching how to farm and feed communities while resisting the pressures of Big Agribiz is a central commitment of the Panama Project.
So is providing a free, beautiful, healthful and sustainable community for visionaries like ...YOU! Leasehold and ownership interests will be available.
If you are interested, just send an email to Ralph Fucetola - ralph.fucetola@usa.net - with "Panama" in the subject line or call 973-300-4594 to learn more about your place in the Panama Project! Before I became “The Vitamin Lawyer” I grew up on family construction projects and practiced construction law for fifteen years, being involved in housing, hotel, mall and commercial developments (including historical renovations) in northeast NJ.
I believe this site is ideal to develop and demonstrate natural solutions. It is the right country (friendly to Americans, natural health and organics) and the right natural area. We've looked for years for the best place to demonstrate natural solutions. In my humble opinion, this is the place!
You are invited to join our Panama Yahoo!Group forum where you will find many photos, copies of the organizing documents, skills database and much more:
http://tech.groups.yahoo.com/group/NSF-Panama/join
Natural Solutions Foundation is more than just talk: we are willing to walk our talk… and a beautiful walk up the mountain it will be!
Ralph Fucetola JD
vitaminlawyer .com
vitaminlawyerarchives .blogspot.com/
Wednesday, February 27, 2008
Tuesday, February 5, 2008
02/05/08 - SEO Strategies, Berries and Weight Management
… VLUeM – 02.05.08 - VITAMIN LAWYER UPDATE e-MEMO
PRIVATE MESSAGE: The purpose of the VLUeM e-memo is to update the Vitamin Lawyer and Vitamin Lawyer News web sites for my contacts and client list. Private, privileged & confidential...
This issue: Privacy and Search Engine Optimization
_______________________________________________
1. Vitamin Lawyer Blogs and Factoid
2. Deep red and blue berry elements in weight management
3. Bio-Identical Hormones at Risk!
4. Important Yahoo!Groups Privacy Information
5. Top 10 Search Engine Optimization Strategies For Your Website!
6. VL Update eMemo Archive Blog
______________________________________________
1. Vitamin Lawyer Blogs & Factoids
New Postings - http://vitaminlawyerhealthfreedom.blogspot.com/
Factoid: "01/02/2008 - The deadline for health claims to be submitted by member states to the European Commission passed yesterday, and among those passed on was the UK's 4,000 page dossier. The country's 3,931 page-long booklet, submitted by the Food Standards Agency (FSA), shows the scale of the task before the Commission and the European Food Safety Authority" As usual, relying on bureaucracy to rationalize the market is a near impossible task. Maybe they shoud have left it to market forces? nutraingredients.com/news/ng.asp?n=82966&m=1NIE201&c=jegwylrviswtnqa
This eMemo is being sent through my “back-up” Earthlink email address since AOL is still blocking my usa.net emails; however, please email me at ralph.fucetola@usa.net as I monitor that email all the time. If you have an AOL email address, please add my usa.net address to your permitted list.
______________________________________________
2. Deep red and blue berry elements in weight management
From a study being published in Journal of Agricultural and Food Chemistry
http://www.nutraingredients.com/news/ng.asp?n=82855&m=1NIE129&c=jegwylrviswtnqa
"Purified forms of extracted anthocyanins from berries may decrease obesity, but the whole fruit doesn't produce the same benefits, suggests a new study with mice.
If the results can be translated to humans, anthocyanins extracted from blueberries and strawberries could find a role in the burgeoning weight loss and management market, estimated to already be worth $7bn (€5.2bn) globally.
"The recent findings that anthocyanins could possibly affect the development of obesity, at least in animal models, have generated considerable interest," explained the researchers, from USDA Arkansas Children's Nutrition Center and the University of Arkansas. "
______________________________________________
3. Bio-Identical Hormones at Risk!
From P2C2 - Patients and Professionals for Customized Care
http://iacprx.convio.net/site/PageServer?pagename=P2C2001secBHRTatRisk
"The FDA and Wyeth, a big drug maker, are trying to stop bio-identical hormone replacement therapy! Get involved and fight back!
Last week FDA decided to support a Wyeth campaign against compounded treatments and announced that it will "halt" compounding of hormone treatments that contain estriol. Estriol is a common and critical component of many bioidentical hormone therapies (including Bi-Est and Tri-Est) that meets standards that were established by Congress. If you are not sure if you are taking estriol, ask your doctor or pharmacist. Even if you don't take a medication with estriol, is your hormone or other compounded treatment next?
If FDA and Wyeth have their way, you will lose this access to vital treatment options. This action affects hundreds of thousands of women!"
______________________________________________
4. Important Yahoo!Groups Privacy Information Received from a Friend
If you belong to any Yahoo Groups read this notice - it is important!
Yahoo is now using something called "Web Beacons" to track Yahoo Group users around the net and see what you're doing and where you are going (similar to Cookies.)
Yahoo is recording every website and every group you visit.
Take a look at their updated privacy statement
1. http://info.yahoo.com/privacy/us/yahoo/details.html
2. About half-way down the page, in the section on Cookies, you will see a link that says "Web Beacons".
Click on the phrase "WebBeacons".
3. That will bring you to a paragraph entitled "Outside the Yahoo Network".
In this section you'll see a little "click here to opt out" link which will let you "opt-out" of their new method of snooping.
4. Once you have clicked that link, you are exempted.
Notice the "Success" message on the top of the next page.
Note: Be careful because on that page there is also a "Cancel Opt-out" button which, if clicked, will *undo* the opt-out. It appears after you have hit the opt-out button so is very confusing.
______________________________________________
5. Top 10 Search Engine Optimization Strategies For Your Website!
entireweb.com/newsletter/archive/2008/PRINT409.html
Entireweb Newsletter * January 29, 2008 * ISSUE #409
“Although the concept of search engine optimization can be somewhat complex, there are a number of basic search engine optimization techniques you can use to improve your organic search results…
1. Meta Tags. Meta tags are simple lines of code at the top of your web page programming that tell search engines about your page. Include the title tag, keyword stag, description tag, and robots tag on each page.
2. Create and update your sitemap. Developing a site map is a simple way of giving search engines the information they need to crawl your entire website. There are plenty of free software packages on the web that can help…
3. Ensure that all navigation is in HTML. All too often, navigational items are in the form of java script. Even though navigation technically still works in this format, it's not optimized. Create your navigation in HTML…
4. Check that all images include ALT text. Your image's alt text is spidered by search engines. If you're not including your keywords in alt text, you're missing out on a huge opportunity for improved search engine result placements…
5. Use Flash content sparingly. Content generated through java script or flash is a big no-no…
6. Make sure that your website code is clean. Keep in mind when optimizing a web page crawlers are basically only looking at your source code…
7. Place keywords in your page content. Search engines scan your website and web pages for keywords. Shoot for a keyword density of between two and eight percent…
8. Submit your website to search engine directories. It's always a good idea to let large search engine directories know that you're out there. Submit your website URL to directories like Google, Yahoo, and DMOZ.
9. Build links to your website. Consider building a link exchange program or create one-way links to your site using articles or forum posts…
10. Learn the basics. Learning to optimize your website for search engines takes time and patience…
Author: Michael Fleischner is a Marketing Expert and Search Engine Optimization Specialist - MarketingScoop.com
______________________________________________
6. VL Update eMemo Archive Blog
I’m getting closer to the new version of the Update eMemo. I’ve begun to post earlier memos on a blogspot.com Blog. You can see it at: http://vitaminlawyerarchives.blogspot.com
In the future, you’ll receive a shorter weekly update email with links to Blog articles that will be posted as the information becomes available… more timely information better indexed!
______________________________________________
You got on this e-list by opting in or becoming a client of the Vitamin Lawyer.com Consultancy. If you want to be taken off the list, please “reply” to this email with the word “remove” in the subject line. On the other hand, you are welcomed to forward this to your own eList…
And do remember to check out the VLUeM Online Archives: http://tinyurl.com/rkneb
Online Seminar compilation of briefs and white papers: http://tinyurl.com/ua9lq
For an outline of typical cGMP SOP docs: http://tinyurl.com/2eu6yj
Vitamin Lawyer Oversight Seal: http://tinyurl.com/2cfoyb
For the latest on Adverse Event Reporting: http://www.aer-consultants.com
Vitamin Lawyer Health Freedom Blog: http://vitaminlawyerhealthfreedom.blogspot.com
For Health Freedom Issues: http://www.globalhealthfreedom.org - Please consider donating to Natural Solutions Foundation - your help is needed to protect the natural products market from bureaucratic interference...
Ralph Fucetola, JD - The Vitamin Lawyer.com Consultancy
http://www.vitaminlawyer.com – ralph.fucetola@usa.net
Attorney at Law in NJ, 1971 – 2006 / All Rights Reserved © 2008 . . .
PRIVATE MESSAGE: The purpose of the VLUeM e-memo is to update the Vitamin Lawyer and Vitamin Lawyer News web sites for my contacts and client list. Private, privileged & confidential...
This issue: Privacy and Search Engine Optimization
_______________________________________________
1. Vitamin Lawyer Blogs and Factoid
2. Deep red and blue berry elements in weight management
3. Bio-Identical Hormones at Risk!
4. Important Yahoo!Groups Privacy Information
5. Top 10 Search Engine Optimization Strategies For Your Website!
6. VL Update eMemo Archive Blog
______________________________________________
1. Vitamin Lawyer Blogs & Factoids
New Postings - http://vitaminlawyerhealthfreedom.blogspot.com/
Factoid: "01/02/2008 - The deadline for health claims to be submitted by member states to the European Commission passed yesterday, and among those passed on was the UK's 4,000 page dossier. The country's 3,931 page-long booklet, submitted by the Food Standards Agency (FSA), shows the scale of the task before the Commission and the European Food Safety Authority" As usual, relying on bureaucracy to rationalize the market is a near impossible task. Maybe they shoud have left it to market forces? nutraingredients.com/news/ng.asp?n=82966&m=1NIE201&c=jegwylrviswtnqa
This eMemo is being sent through my “back-up” Earthlink email address since AOL is still blocking my usa.net emails; however, please email me at ralph.fucetola@usa.net as I monitor that email all the time. If you have an AOL email address, please add my usa.net address to your permitted list.
______________________________________________
2. Deep red and blue berry elements in weight management
From a study being published in Journal of Agricultural and Food Chemistry
http://www.nutraingredients.com/news/ng.asp?n=82855&m=1NIE129&c=jegwylrviswtnqa
"Purified forms of extracted anthocyanins from berries may decrease obesity, but the whole fruit doesn't produce the same benefits, suggests a new study with mice.
If the results can be translated to humans, anthocyanins extracted from blueberries and strawberries could find a role in the burgeoning weight loss and management market, estimated to already be worth $7bn (€5.2bn) globally.
"The recent findings that anthocyanins could possibly affect the development of obesity, at least in animal models, have generated considerable interest," explained the researchers, from USDA Arkansas Children's Nutrition Center and the University of Arkansas. "
______________________________________________
3. Bio-Identical Hormones at Risk!
From P2C2 - Patients and Professionals for Customized Care
http://iacprx.convio.net/site/PageServer?pagename=P2C2001secBHRTatRisk
"The FDA and Wyeth, a big drug maker, are trying to stop bio-identical hormone replacement therapy! Get involved and fight back!
Last week FDA decided to support a Wyeth campaign against compounded treatments and announced that it will "halt" compounding of hormone treatments that contain estriol. Estriol is a common and critical component of many bioidentical hormone therapies (including Bi-Est and Tri-Est) that meets standards that were established by Congress. If you are not sure if you are taking estriol, ask your doctor or pharmacist. Even if you don't take a medication with estriol, is your hormone or other compounded treatment next?
If FDA and Wyeth have their way, you will lose this access to vital treatment options. This action affects hundreds of thousands of women!"
______________________________________________
4. Important Yahoo!Groups Privacy Information Received from a Friend
If you belong to any Yahoo Groups read this notice - it is important!
Yahoo is now using something called "Web Beacons" to track Yahoo Group users around the net and see what you're doing and where you are going (similar to Cookies.)
Yahoo is recording every website and every group you visit.
Take a look at their updated privacy statement
1. http://info.yahoo.com/privacy/us/yahoo/details.html
2. About half-way down the page, in the section on Cookies, you will see a link that says "Web Beacons".
Click on the phrase "WebBeacons".
3. That will bring you to a paragraph entitled "Outside the Yahoo Network".
In this section you'll see a little "click here to opt out" link which will let you "opt-out" of their new method of snooping.
4. Once you have clicked that link, you are exempted.
Notice the "Success" message on the top of the next page.
Note: Be careful because on that page there is also a "Cancel Opt-out" button which, if clicked, will *undo* the opt-out. It appears after you have hit the opt-out button so is very confusing.
______________________________________________
5. Top 10 Search Engine Optimization Strategies For Your Website!
entireweb.com/newsletter/archive/2008/PRINT409.html
Entireweb Newsletter * January 29, 2008 * ISSUE #409
“Although the concept of search engine optimization can be somewhat complex, there are a number of basic search engine optimization techniques you can use to improve your organic search results…
1. Meta Tags. Meta tags are simple lines of code at the top of your web page programming that tell search engines about your page. Include the title tag, keyword stag, description tag, and robots tag on each page.
2. Create and update your sitemap. Developing a site map is a simple way of giving search engines the information they need to crawl your entire website. There are plenty of free software packages on the web that can help…
3. Ensure that all navigation is in HTML. All too often, navigational items are in the form of java script. Even though navigation technically still works in this format, it's not optimized. Create your navigation in HTML…
4. Check that all images include ALT text. Your image's alt text is spidered by search engines. If you're not including your keywords in alt text, you're missing out on a huge opportunity for improved search engine result placements…
5. Use Flash content sparingly. Content generated through java script or flash is a big no-no…
6. Make sure that your website code is clean. Keep in mind when optimizing a web page crawlers are basically only looking at your source code…
7. Place keywords in your page content. Search engines scan your website and web pages for keywords. Shoot for a keyword density of between two and eight percent…
8. Submit your website to search engine directories. It's always a good idea to let large search engine directories know that you're out there. Submit your website URL to directories like Google, Yahoo, and DMOZ.
9. Build links to your website. Consider building a link exchange program or create one-way links to your site using articles or forum posts…
10. Learn the basics. Learning to optimize your website for search engines takes time and patience…
Author: Michael Fleischner is a Marketing Expert and Search Engine Optimization Specialist - MarketingScoop.com
______________________________________________
6. VL Update eMemo Archive Blog
I’m getting closer to the new version of the Update eMemo. I’ve begun to post earlier memos on a blogspot.com Blog. You can see it at: http://vitaminlawyerarchives.blogspot.com
In the future, you’ll receive a shorter weekly update email with links to Blog articles that will be posted as the information becomes available… more timely information better indexed!
______________________________________________
You got on this e-list by opting in or becoming a client of the Vitamin Lawyer.com Consultancy. If you want to be taken off the list, please “reply” to this email with the word “remove” in the subject line. On the other hand, you are welcomed to forward this to your own eList…
And do remember to check out the VLUeM Online Archives: http://tinyurl.com/rkneb
Online Seminar compilation of briefs and white papers: http://tinyurl.com/ua9lq
For an outline of typical cGMP SOP docs: http://tinyurl.com/2eu6yj
Vitamin Lawyer Oversight Seal: http://tinyurl.com/2cfoyb
For the latest on Adverse Event Reporting: http://www.aer-consultants.com
Vitamin Lawyer Health Freedom Blog: http://vitaminlawyerhealthfreedom.blogspot.com
For Health Freedom Issues: http://www.globalhealthfreedom.org - Please consider donating to Natural Solutions Foundation - your help is needed to protect the natural products market from bureaucratic interference...
Ralph Fucetola, JD - The Vitamin Lawyer.com Consultancy
http://www.vitaminlawyer.com – ralph.fucetola@usa.net
Attorney at Law in NJ, 1971 – 2006 / All Rights Reserved © 2008 . . .
Friday, January 25, 2008
01/25/08 - Web site cross promotion
PRIVATE MESSAGE: The purpose of the VLUeM e-memo is to update the Vitamin Lawyer and Vitamin Lawyer News web sites for my contacts and client list. Private, privileged & confidential...
This issue: saving your company from costly new FDA regulations…
_______________________________________________
1. Health Freedom Blog update
2. Cross-promotion of web sites
3. VL Memo Archives Blog - improved format for this Update eMemo!
______________________________________________
1. Vitamin Lawyer Health Freedom Blog & Factoids
New Postings - http://vitaminlawyerhealthfreedom.blogspot.com/
Factoid: FDA just decided not to define the word “Natural” although petitioned to do so. Functional Nutrition Magazine also tells us that “Natural” was the favorite word last year for launching new food products, appearing on almost 2,500 of them. See: http://www.functionalingredientsmag.com/fimag/articleDisplay.asp?strArticleId=1553&strSite=FFNSite
The OneLook.com meta-dictionary defines “Natural” as: “adjective: existing in or produced by nature; not artificial or imitation… (used especially of commodities) in the natural unprocessed condition…”
eAlerts – STOP FORCED VACCINATION! A powerful new tool to stopped forced vaccination has been established by the Natural Solutions Foundation. You can join this open Yahoo!Group at: http://groups.yahoo.com/group/no-forced-vaccination/join
If you will be in the NYC area on January 26th and would like to meet with Gen. Stubblebine, Dr. Laibow and myself about ending forced drugging and vaccinations (they have a six hour stop over at JFK on their way to a Codex meeting in Africa) let me know; it will be a brunch or lunch meeting near the airport. And you can always join the Health Freedom eAlert list at: www.globalhealthfreedom.org .
This eMemo is being sent through my “back-up” Earthlink email address since AOL is still blocking my usa.net emails; however, please email me at ralph.fucetola@usa.net as I monitor that email all the time. If you have an AOL email address, please add my usa.net address to your permitted list.
______________________________________________
2. Entire Web on Cross-promotion of Web Sites
Entireweb Newsletter * January 22, 2008 * ISSUE #407
Easy Cross-Promotion Tactics
Cross-promotion is an easy, inexpensive method for generating more traffic and more revenue for your business and for the business of your promotional partners.
What could be better than a real win-win situation? With cross-promotion not only can you generate more customers and profit, usually for free, but you can help another entrepreneur do the same!
One simple example of good cross-promotion is swapping business cards with another business in your area. The idea is to find a related, yet non-competing operation, give them a stack of your cards to hand out and take a stack of their cards in exchange.
For example when I ran a local Web design company I swapped stacks of business cards with a nearby computer repair service. It made sense because both of us targeted small businesses, and nearly all small businesses today have computers in their office and a Website to promote their products and services. So often my customers would have an interest in a good computer repair service, and the repair shop's clients might be interested in somebody to build or re-design their Website.
It's easy to see how both parties stand to benefit in this arrangement. And the customers of both businesses also benefit!
Putting together a win-win cross-promotion on the Web is even easier, and here are a few examples of how you might do this:
Exchange Thank You Page Ads
Thank you or confirmation pages that prospects see after they make a purchase or register for a free mailing list are great places to post promotions. The people who see these pages are action takers, making them the ultimate target for a good advertisement.
You could place an ad for your cross-promotion partner on one or more of your thank you pages and have them do the same for you.
Unannounced Member Bonus
If you and your promotional partner run membership programs, you could place unannounced bonuses within one another's secure member areas. For instance, when members login to your site they could find a "free gift" from your partner, and be required to register at your partner's Website to receive access to their free gift; of course you would place a similar promotion in your promotion partner's member area.
Swap Autoresponder Messages
You could include an email in your automated message series promoting your partner's product or service, and they could reciprocate with an email for you. You could even promote as affiliates for one another so you both earn commissions in the process.
Cover Page Promotions
If you and your partner both produce digital information products such as e-books and special reports, you could swap promotions on the first page of your PDF products. This would provide both of you with quality exposure as your ads would be seen by the people who purchase and actually open digital products; so prospects generated by this measure are both buyers and action takers.
These four examples are just the tip of the iceberg. Once you sit down and really brainstorm about innovative ways to cross promote you might be amazed with what you come up with.
Both you and your promotional partner(s) stand to benefit, and neither of you will need to pay any advertising expense to generate new traffic and sales.
About the Author: Tim Whiston is a professional Internet marketer who enjoys his work. He has owned numerous Websites and ezines and has created hundreds of thousands of dollars in profits for his clients. Be sure to check out his free Information Marketing Course and Internet Marketing Tools.
http://www.entireweb.com/newsletter/archive/2008/PRINT407.html
______________________________________________
3. Upgrading the VL Update eMemo!
I’m getting closer to the new version of the Update eMemo. I’ve begun to post earlier memos on a blogspot.com Blog. You can see it at: http://vitaminlawyerarchives.blogspot.com
In the future, you’ll receive a shorter weekly update email with links to Blog articles that will be posted as the information becomes available… more timely information better indexed!
______________________________________________
You got on this e-list by opting in or becoming a client of the Vitamin Lawyer.com Consultancy. If you want to be taken off the list, please “reply” to this email with the word “remove” in the subject line. On the other hand, you are welcomed to forward this to your own eList…
And do remember to check out the VLUeM Online Archives: http://tinyurl.com/rkneb
Online Seminar compilation of briefs and white papers: http://tinyurl.com/ua9lq
For an outline of typical cGMP SOP docs: http://tinyurl.com/2eu6yj
Vitamin Lawyer Oversight Seal: http://tinyurl.com/2cfoyb
For the latest on Adverse Event Reporting: http://www.aer-consultants.com
Vitamin Lawyer Health Freedom Blog: http://vitaminlawyerhealthfreedom.blogspot.com
For Health Freedom Issues: http://www.globalhealthfreedom.org - Please consider donating to Natural Solutions Foundation - your help is needed to protect the natural products market from bureaucratic interference...
Ralph Fucetola, JD - The Vitamin Lawyer.com Consultancy
http://www.vitaminlawyer.com – ralph.fucetola@usa.net
All Rights Reserved © 2008 . . .
Friday, January 18, 2008
01/18/08 - SOPs and FDA Regulations
… VLUeM – 01.18.08 - VITAMIN LAWYER WEEKLY UPDATE e-MEMO
PRIVATE MESSAGE: The purpose of the VLUeM e-memo is to update the Vitamin Lawyer and Vitamin Lawyer News web sites for my contacts and client list. Private, privileged & confidential...
This issue: saving your company from costly new FDA regulations…
_______________________________________________
1. Health Freedom Blog update
2. News Target targets FDA attacks on supplements… are your SOPs ready?
3. Food niche with potential
4. VL Memo Archives Blog - improved format for this Update eMemo!
______________________________________________
1. Vitamin Lawyer Health Freedom Blog & Factoids
New Postings - http://vitaminlawyerhealthfreedom.blogspot.com/
Factoid: FDA just decided not to define the word “Natural” although petitioned to do so. Functional Nutrition Magazine also tells us that “Natural” was the favorite word last year for launching new food products, appearing on almost 2,500 of them. See: http://www.functionalingredientsmag.com/fimag/articleDisplay.asp?strArticleId=1553&strSite=FFNSite
The OneLook.com meta-dictionary defines “Natural” as: “adjective: existing in or produced by nature; not artificial or imitation… (used especially of commodities) in the natural unprocessed condition…”
eAlerts – STOP FORCED VACCINATION! A powerful new tool to stopped forced vaccination has been established by the Natural Solutions Foundation. You can join this open Yahoo!Group at: http://groups.yahoo.com/group/no-forced-vaccination/join
If you will be in the NYC area on January 26th and would like to meet with Gen. Stubblebine, Dr. Laibow and myself about ending forced drugging and vaccinations (they have a six hour stop over at JFK on their way to a Codex meeting in Africa) let me know; it will be a brunch or lunch meeting near the airport. And you can always join the Health Freedom eAlert list at: www.globalhealthfreedom.org .
This eMemo is being sent through my “back-up” Earthlink email address since AOL is still blocking my usa.net emails; however, please email me at ralph.fucetola@usa.net as I monitor that email all the time. If you have an AOL email address, please add my usa.net address to your permitted list.
______________________________________________
2. News Target targets FDA attacks on supplements – see SOP Alert! below.
“FDA Announces Plan to Eliminate Vitamin Companies by Byron Richards
“(January 15 - NewsTarget) The FDA, emboldened by its transformation into a drug company, has embarked upon an anti-American plan of interfering with business and intentionally eliminating various dietary supplement companies from the market. The FDA announcement came on Friday, June 22, 2007 under the guise of a final rule for dietary supplement good manufacturing practices (CGMPs). Within this 800 page rule the FDA states, "We find that this final rule will have a significant economic impact on a substantial number of small entities... Establishments with above average costs, and even establishments with average costs, could be hard pressed to continue to operate. Some of these may decide it is too costly and either change product lines or go out of business... very small …and …small dietary supplement manufacturers … will be at risk of going out of business... costs per establishment are proportionally higher for very small than for large establishments... The regulatory costs of this final rule will also discourage new small businesses from entering the industry." (http://www.cfsan.fda.gov/%7Elrd/fr07625a.html)
”This FDA rule will directly raise the price of dietary supplements for all consumers. The FDA acknowledges this and says "We expect that the majority of these costs will be borne by consumers of dietary supplements, who will likely respond to the increase in prices by reducing consumption." Thus, the FDA is intentionally seeking to shrink the size of the dietary supplement industry and reduce the influence of safe and effective options to improve the dreadful trend in the health of Americans. The goal is to leave toxic drugs as the primary health option.
”Independent analysis of this FDA rule has placed cost of compliance at 10 fold what the FDA estimates with as many as 50% of small companies unable to comply.”
To read more: http://www.newstarget.com/022499.html
SOP ALERT FOR COMPANIES: Now more than ever, “your papers must be in order…” – The Vitamin Lawyer Consultancy has prepared formats for Standard Operating Procedures to allow small companies to comply with the new rules, including the new AER law, by maintaining the necessary records. Our SOP format is relatively short (about 20 pages) but does cover all the areas needed:
A. Refund, Delivery & Returns Policies
B. Standard Disclaimers; Site Use Statement
C. Standard Testimonial Waiver
D. Email Privacy Policy
E. Document Retention Policy
F. Quality Control Procedures - Standards, Complaints and Policy Coordination
G. Order Processing Procedure
H. Bookkeeping and Account Management
I. Order Record Keeping and Retrieval; AER Reporting
J. Emergency Planning and Crisis Management
You can find out more at: http://tinyurl.com/2eu6yj
If you need the format, please email me at ralph.fucetola@usa.net and put “SOP” in the subject line. Typically, it takes an hour or two of my time to fine tune the format for you.
______________________________________________
3. Food niche with potential
Report pinpoints functional food niche with most potential - By Lorraine Heller
January 16, 2008 - Foods and drinks developed to address the specific health needs of consumers are expected to exceed category growth in the US functional food segment, according to a new report. Published by TSG, the study estimates that 'targeted foods', which currently make up 12 percent of the $60bn functional food segment, could grow to take a massive 25-35 percent share in 2012. This could bring up the total value of the sub-segment to between $55bn and $77bn over the next 13 years. Functional foods as a whole are projected to have a market value of $219bn by 2012.
TSG defines targeted foods are those functional foods that are designed to address specific health or disease conditions; specific physical or mental states; or specific age or gender needs. These, says the study, will grow "exponentially" as the functional foods markets continues its ascent into the mainstream.
"They will be the evolution of functional foods," TSG CEO Panna Sharma told NutraIngredients-USA.com.
Foods and beverages in this category include products that address: Digestive health, Celiac disease, Arthritis, Cancer prevention, Heart health
[Note from Vitamin Lawyer: some of these claims would not be allowed as Dietary Supplement claims.]
…[Other of these] products address: * Sports performance, * Beauty, * Skin care, * Libido, * Brain function
…TSG states: "Beverages will continue to drive innovation and early consumer adoption which will drive tighter alignment between functional ingredients and nutraceutical companies and the beverage community."
…"Global food and beverage giants will aggressively enter the market through acquisitions, alliances and select investments," said TSG.
For more –
http://www.nutraingredients-usa.com/news/ng.asp?n=82599&m=1NIU116&c=jegwylrviswtnqa
______________________________________________
4. Upgrading the VL Update eMemo!
I’m getting closer to the new version of the Update eMemo. I’ve begun to post earlier memos on a blogspot.com Blog. You can see it at: http://vitaminlawyerarchives.blogspot.com
In the future, you’ll receive a shorter weekly update email with links to Blog articles that will be posted as the information becomes available… more timely information better indexed!
______________________________________________
You got on this e-list by opting in or becoming a client of the Vitamin Lawyer.com Consultancy. If you want to be taken off the list, please “reply” to this email with the word “remove” in the subject line. On the other hand, you are welcomed to forward this to your own eList…
And do remember to check out the VLUeM Online Archives: http://tinyurl.com/rkneb
Online Seminar compilation of briefs and white papers: http://tinyurl.com/ua9lq
For an outline of typical cGMP SOP docs: http://tinyurl.com/2eu6yj
Vitamin Lawyer Oversight Seal: http://tinyurl.com/2cfoyb
For the latest on Adverse Event Reporting: http://www.aer-consultants.com
Vitamin Lawyer Health Freedom Blog: http://vitaminlawyerhealthfreedom.blogspot.com
For Health Freedom Issues: http://www.globalhealthfreedom.org - Please consider donating to Natural Solutions Foundation - your help is needed to protect the natural products market from bureaucratic interference...
Ralph Fucetola, JD - The Vitamin Lawyer.com Consultancy
http://www.vitaminlawyer.com – ralph.fucetola@usa.net
All Rights Reserved © 2008 . . .
PRIVATE MESSAGE: The purpose of the VLUeM e-memo is to update the Vitamin Lawyer and Vitamin Lawyer News web sites for my contacts and client list. Private, privileged & confidential...
This issue: saving your company from costly new FDA regulations…
_______________________________________________
1. Health Freedom Blog update
2. News Target targets FDA attacks on supplements… are your SOPs ready?
3. Food niche with potential
4. VL Memo Archives Blog - improved format for this Update eMemo!
______________________________________________
1. Vitamin Lawyer Health Freedom Blog & Factoids
New Postings - http://vitaminlawyerhealthfreedom.blogspot.com/
Factoid: FDA just decided not to define the word “Natural” although petitioned to do so. Functional Nutrition Magazine also tells us that “Natural” was the favorite word last year for launching new food products, appearing on almost 2,500 of them. See: http://www.functionalingredientsmag.com/fimag/articleDisplay.asp?strArticleId=1553&strSite=FFNSite
The OneLook.com meta-dictionary defines “Natural” as: “adjective: existing in or produced by nature; not artificial or imitation… (used especially of commodities) in the natural unprocessed condition…”
eAlerts – STOP FORCED VACCINATION! A powerful new tool to stopped forced vaccination has been established by the Natural Solutions Foundation. You can join this open Yahoo!Group at: http://groups.yahoo.com/group/no-forced-vaccination/join
If you will be in the NYC area on January 26th and would like to meet with Gen. Stubblebine, Dr. Laibow and myself about ending forced drugging and vaccinations (they have a six hour stop over at JFK on their way to a Codex meeting in Africa) let me know; it will be a brunch or lunch meeting near the airport. And you can always join the Health Freedom eAlert list at: www.globalhealthfreedom.org .
This eMemo is being sent through my “back-up” Earthlink email address since AOL is still blocking my usa.net emails; however, please email me at ralph.fucetola@usa.net as I monitor that email all the time. If you have an AOL email address, please add my usa.net address to your permitted list.
______________________________________________
2. News Target targets FDA attacks on supplements – see SOP Alert! below.
“FDA Announces Plan to Eliminate Vitamin Companies by Byron Richards
“(January 15 - NewsTarget) The FDA, emboldened by its transformation into a drug company, has embarked upon an anti-American plan of interfering with business and intentionally eliminating various dietary supplement companies from the market. The FDA announcement came on Friday, June 22, 2007 under the guise of a final rule for dietary supplement good manufacturing practices (CGMPs). Within this 800 page rule the FDA states, "We find that this final rule will have a significant economic impact on a substantial number of small entities... Establishments with above average costs, and even establishments with average costs, could be hard pressed to continue to operate. Some of these may decide it is too costly and either change product lines or go out of business... very small …and …small dietary supplement manufacturers … will be at risk of going out of business... costs per establishment are proportionally higher for very small than for large establishments... The regulatory costs of this final rule will also discourage new small businesses from entering the industry." (http://www.cfsan.fda.gov/%7Elrd/fr07625a.html)
”This FDA rule will directly raise the price of dietary supplements for all consumers. The FDA acknowledges this and says "We expect that the majority of these costs will be borne by consumers of dietary supplements, who will likely respond to the increase in prices by reducing consumption." Thus, the FDA is intentionally seeking to shrink the size of the dietary supplement industry and reduce the influence of safe and effective options to improve the dreadful trend in the health of Americans. The goal is to leave toxic drugs as the primary health option.
”Independent analysis of this FDA rule has placed cost of compliance at 10 fold what the FDA estimates with as many as 50% of small companies unable to comply.”
To read more: http://www.newstarget.com/022499.html
SOP ALERT FOR COMPANIES: Now more than ever, “your papers must be in order…” – The Vitamin Lawyer Consultancy has prepared formats for Standard Operating Procedures to allow small companies to comply with the new rules, including the new AER law, by maintaining the necessary records. Our SOP format is relatively short (about 20 pages) but does cover all the areas needed:
A. Refund, Delivery & Returns Policies
B. Standard Disclaimers; Site Use Statement
C. Standard Testimonial Waiver
D. Email Privacy Policy
E. Document Retention Policy
F. Quality Control Procedures - Standards, Complaints and Policy Coordination
G. Order Processing Procedure
H. Bookkeeping and Account Management
I. Order Record Keeping and Retrieval; AER Reporting
J. Emergency Planning and Crisis Management
You can find out more at: http://tinyurl.com/2eu6yj
If you need the format, please email me at ralph.fucetola@usa.net and put “SOP” in the subject line. Typically, it takes an hour or two of my time to fine tune the format for you.
______________________________________________
3. Food niche with potential
Report pinpoints functional food niche with most potential - By Lorraine Heller
January 16, 2008 - Foods and drinks developed to address the specific health needs of consumers are expected to exceed category growth in the US functional food segment, according to a new report. Published by TSG, the study estimates that 'targeted foods', which currently make up 12 percent of the $60bn functional food segment, could grow to take a massive 25-35 percent share in 2012. This could bring up the total value of the sub-segment to between $55bn and $77bn over the next 13 years. Functional foods as a whole are projected to have a market value of $219bn by 2012.
TSG defines targeted foods are those functional foods that are designed to address specific health or disease conditions; specific physical or mental states; or specific age or gender needs. These, says the study, will grow "exponentially" as the functional foods markets continues its ascent into the mainstream.
"They will be the evolution of functional foods," TSG CEO Panna Sharma told NutraIngredients-USA.com.
Foods and beverages in this category include products that address: Digestive health, Celiac disease, Arthritis, Cancer prevention, Heart health
[Note from Vitamin Lawyer: some of these claims would not be allowed as Dietary Supplement claims.]
…[Other of these] products address: * Sports performance, * Beauty, * Skin care, * Libido, * Brain function
…TSG states: "Beverages will continue to drive innovation and early consumer adoption which will drive tighter alignment between functional ingredients and nutraceutical companies and the beverage community."
…"Global food and beverage giants will aggressively enter the market through acquisitions, alliances and select investments," said TSG.
For more –
http://www.nutraingredients-usa.com/news/ng.asp?n=82599&m=1NIU116&c=jegwylrviswtnqa
______________________________________________
4. Upgrading the VL Update eMemo!
I’m getting closer to the new version of the Update eMemo. I’ve begun to post earlier memos on a blogspot.com Blog. You can see it at: http://vitaminlawyerarchives.blogspot.com
In the future, you’ll receive a shorter weekly update email with links to Blog articles that will be posted as the information becomes available… more timely information better indexed!
______________________________________________
You got on this e-list by opting in or becoming a client of the Vitamin Lawyer.com Consultancy. If you want to be taken off the list, please “reply” to this email with the word “remove” in the subject line. On the other hand, you are welcomed to forward this to your own eList…
And do remember to check out the VLUeM Online Archives: http://tinyurl.com/rkneb
Online Seminar compilation of briefs and white papers: http://tinyurl.com/ua9lq
For an outline of typical cGMP SOP docs: http://tinyurl.com/2eu6yj
Vitamin Lawyer Oversight Seal: http://tinyurl.com/2cfoyb
For the latest on Adverse Event Reporting: http://www.aer-consultants.com
Vitamin Lawyer Health Freedom Blog: http://vitaminlawyerhealthfreedom.blogspot.com
For Health Freedom Issues: http://www.globalhealthfreedom.org - Please consider donating to Natural Solutions Foundation - your help is needed to protect the natural products market from bureaucratic interference...
Ralph Fucetola, JD - The Vitamin Lawyer.com Consultancy
http://www.vitaminlawyer.com – ralph.fucetola@usa.net
All Rights Reserved © 2008 . . .
Friday, January 4, 2008
01/04/08 - FDA on AER Labeling
… VLUeM – 01.04.08 - VITAMIN LAWYER WEEKLY UPDATE e-MEMO
PRIVATE MESSAGE: The purpose of the VLUeM e-memo is to update the Vitamin Lawyer and Vitamin Lawyer News web sites for my contacts and client list. Private, privileged & confidential...
This issue: saving your company money…
_______________________________________________
1. Health Freedom Blog update
2. Web site titles and descriptions
3. The Electric Tree – savings and more
4. Guidance from FDA on AER labeling
5. Cost of foods… calorie
6. Coming next year: improved format for the VL Update eMemo!
______________________________________________
1. Vitamin Lawyer Health Freedom Blog & Factoids
New Postings - http://vitaminlawyerhealthfreedom.blogspot.com/
Factoid: Nutrition Business Journal (nutritionbusiness.com) announced recently that the global nutrition industry has reached $226-billion annually. Other sources suggest the US share is about 50% -- so what portion of that $113 billion a year does your company earn?
eAlerts – STOP FORCED VACCINATION! A powerful new tool to stopped forced vaccination has been established by the Natural Solutions Foundation. You can join this open Yahoo!Group at: http://groups.yahoo.com/group/no-forced-vaccination/join
If you will be in the NYC area on January 26th and would like to meet with Gen. Stubblebine, Dr. Laibow and myself about ending forced drugging and vaccinations (they have a six hour stop over at JFK on their way to a Codex meeting in Africa) let me know; it will be a brunch or lunch meeting near the airport. And you can always join the Health Freedom eAlert list at: www.globalhealthfreedom.org .
This eMemo is being sent through my “back-up” Earthlink email address since AOL seems to be blocking my usa.net emails; however, please email me at ralph.fucetola@usa.net as I monitor that email all the time. If you have an AOL email address, please add my usa.net address to your permitted list.
______________________________________________
2. Web site advice from Entireweb Newsletter * January 1, 2008 * ISSUE #401 – entireweb.com
“How to Create Compelling Site Titles and Descriptions - There are many places in your HTML you can include keywords, but the Titles and descriptions are arguably the most important elements of your Web site… These places are …most important in terms of their ability to compel someone to visit your Web site. That is, after all, the ultimate goal of search engine positioning, isn't it? Not a lot of point in attaining a top ranking in a search engine if you are just going to call you site "Shop Here." …the Title tag has special relevance, because so many search engines use the title exactly as it appears on your page. …the title of the site is more important than the site description.
“Longer Titles are More Effective - Longer titles build a more compelling reason to visit a Web site. Because it takes a certain number of words to persuade someone to take action, logic dictates that longer sentences have more opportunity to create that compelling argument… People often scan headlines in brochures and magazines, even when they don't read all the information…
“People Don't Read Text, They Recognize Words - …Educators know that people glance at words and recognize the words by the shapes defined by the tops of the letters. …Since people recognize words because the tops of words vary in height and appearance, then sentences that start with just one capital letter and then lowercase letters are easier to recognize and get read faster… Words in all caps are hard to read…
Every little advantage helps you.” - Pamela Upshur - upshurcreative.com
______________________________________________
3. The Electric Tree = savings and corporate responsibility
Natural Solutions Foundation has been chosen as one of The Electric Tree’s 2008 Corporate Responsibility Designees. What does this mean to your business? If you are located in one of the currently covered states (NY, CT, MA. IL, MD, DE ) and choose to participate, with NO cost to you, The Electric Tree can save between 8 and 14% of your electric power bill… if you spend at least $2,000 per month or more on electricity and are willing to donate half your savings to the Foundation. This can be a “win – win” situation. It is very simple to do. If you have interest, please email me with Electric Tree in the subject line.
______________________________________________
4. FDA Guidance & AER Labeling
You can find a listing of FDA guidance documents for the vitamin industry at: http://www.cfsan.fda.gov/guidance.html
Among the new guidances published is a draft labeling guidance for the AER (adverse event reporting) system, with frequently asked questions. This document was finalized on January 2, 2008, as “Guidance for Industry: Questions and Answers Regarding, the Labeling of Dietary Supplements as Required by the Dietary Supplement and
Nonprescription Drug Consumer Protection Act” - Docket No. 2007D-0491. It can be found at: http://www.cfsan.fda.gov/~dms/dsaergu2.html
Here is the summary of the label requirement: “the act requires the label of a dietary supplement being marketed in the United States to include a domestic address or domestic telephone number through which the responsible person may receive a report of a serious adverse event with such dietary supplement. If the label does not include the required domestic address or telephone number, the dietary supplement is misbranded.” FDA also “recommends that the label bear a clear, prominent statement informing consumers that the domestic address or telephone number is for reporting serious adverse events associated with use of the product.”
http://a257.g.akamaitech.net/7/257/2422/01jan20081800/edocket.access.gpo.gov/2008/07-6266.htm
Please note the distinction between “the act requires…” and FDA “recommends.” If a company voluntarily chooses to add language that the phone number or address on the label is there to report AERs, FDA does say “dual purpose” language such as “"To report a serious adverse event or obtain product information, contact..." would be acceptable.
And the FDA’s overall FAQs for AERs cam be found at: http://www.cfsan.fda.gov/~dms/dsaergui.html
That document also states: “Your submission will not be construed by FDA as an admission that the dietary supplement involved caused or contributed to the adverse event being reported. Any serious adverse event report submitted to FDA, including any new medical information submitted as a follow-up to the initial report, is considered a safety report under section 756 of the FD&C Act (21 U.S.C. 379v) and may be accompanied by a statement, which shall be a part of any report that is released for public disclosure, that denies that the report or the records constitute an admission that the product involved caused or contributed to the serious adverse event.”
If you have any occasion to report an adverse event, you ought to have the report reviewed by The Vitamin Lawyer before submitting it.
______________________________________________
5. Cost of food, per calorie
Reuters reported on 01/02/08, “the average price of the lowest-calorie foods -- including green vegetables, tomatoes and berries -- increased by almost 20 percent over 2 years. In contrast, in the same time period there was a 2-percent dip in the cost of the most calorie-laden fare, such as butter, potato chips, cookies and candy bars… findings, published in the Journal of the American Dietetic Association, highlight a key obstacle to healthy eating. … They found that snack foods, sweets and fatty foods offered the most bang for a shopper's buck. Whereas the price of the lowest-calorie fruits and vegetables was more than $18.16 per 1,000 calories, the most calorie-rich foods cost $1.76 per 1,000 calories.”
______________________________________________
6. Upgrading the VL Update eMemo!
Coming early this year: this email update system will be replaced by a second, private blog, the Vitamin Lawyer Update Blog, to allow me to keep you up-to-date better than ever! You’ll receive a shorter weekly update email with links to blog articles that will be posted as the information becomes available… more timely information better indexed!
______________________________________________
You got on this e-list by opting in or becoming a client of the Vitamin Lawyer.com Consultancy. If you want to be taken off the list, please “reply” to this email with the word “remove” in the subject line. On the other hand, you are welcomed to forward this to your own eList…
And do remember to check out the VLUeM Online Archives: http://tinyurl.com/rkneb
Online Seminar compilation of briefs and white papers: http://tinyurl.com/ua9lq
For an outline of typical cGMP SOP docs: http://tinyurl.com/2eu6yj
Vitamin Lawyer Oversight Seal: http://tinyurl.com/2cfoyb
For the latest on Adverse Event Reporting: http://www.aer-consultants.com
Vitamin Lawyer Health Freedom Blog: http://vitaminlawyerhealthfreedom.blogspot.com
For Health Freedom Issues: http://www.globalhealthfreedom.org - Please consider making an end-of-the-year donation to Natural Solutions Foundation - your help is needed to protect the natural products market from bureaucratic interference...
Wishing you and yours a joyous, prosperous, peaceful and free new year!
Ralph Fucetola, JD - The Vitamin Lawyer.com Consultancy
http://www.vitaminlawyer.com – ralph.fucetola@usa.net
All Rights Reserved © 2008 . . .
PRIVATE MESSAGE: The purpose of the VLUeM e-memo is to update the Vitamin Lawyer and Vitamin Lawyer News web sites for my contacts and client list. Private, privileged & confidential...
This issue: saving your company money…
_______________________________________________
1. Health Freedom Blog update
2. Web site titles and descriptions
3. The Electric Tree – savings and more
4. Guidance from FDA on AER labeling
5. Cost of foods… calorie
6. Coming next year: improved format for the VL Update eMemo!
______________________________________________
1. Vitamin Lawyer Health Freedom Blog & Factoids
New Postings - http://vitaminlawyerhealthfreedom.blogspot.com/
Factoid: Nutrition Business Journal (nutritionbusiness.com) announced recently that the global nutrition industry has reached $226-billion annually. Other sources suggest the US share is about 50% -- so what portion of that $113 billion a year does your company earn?
eAlerts – STOP FORCED VACCINATION! A powerful new tool to stopped forced vaccination has been established by the Natural Solutions Foundation. You can join this open Yahoo!Group at: http://groups.yahoo.com/group/no-forced-vaccination/join
If you will be in the NYC area on January 26th and would like to meet with Gen. Stubblebine, Dr. Laibow and myself about ending forced drugging and vaccinations (they have a six hour stop over at JFK on their way to a Codex meeting in Africa) let me know; it will be a brunch or lunch meeting near the airport. And you can always join the Health Freedom eAlert list at: www.globalhealthfreedom.org .
This eMemo is being sent through my “back-up” Earthlink email address since AOL seems to be blocking my usa.net emails; however, please email me at ralph.fucetola@usa.net as I monitor that email all the time. If you have an AOL email address, please add my usa.net address to your permitted list.
______________________________________________
2. Web site advice from Entireweb Newsletter * January 1, 2008 * ISSUE #401 – entireweb.com
“How to Create Compelling Site Titles and Descriptions - There are many places in your HTML you can include keywords, but the Titles and descriptions are arguably the most important elements of your Web site… These places are …most important in terms of their ability to compel someone to visit your Web site. That is, after all, the ultimate goal of search engine positioning, isn't it? Not a lot of point in attaining a top ranking in a search engine if you are just going to call you site "Shop Here." …the Title tag has special relevance, because so many search engines use the title exactly as it appears on your page. …the title of the site is more important than the site description.
“Longer Titles are More Effective - Longer titles build a more compelling reason to visit a Web site. Because it takes a certain number of words to persuade someone to take action, logic dictates that longer sentences have more opportunity to create that compelling argument… People often scan headlines in brochures and magazines, even when they don't read all the information…
“People Don't Read Text, They Recognize Words - …Educators know that people glance at words and recognize the words by the shapes defined by the tops of the letters. …Since people recognize words because the tops of words vary in height and appearance, then sentences that start with just one capital letter and then lowercase letters are easier to recognize and get read faster… Words in all caps are hard to read…
Every little advantage helps you.” - Pamela Upshur - upshurcreative.com
______________________________________________
3. The Electric Tree = savings and corporate responsibility
Natural Solutions Foundation has been chosen as one of The Electric Tree’s 2008 Corporate Responsibility Designees. What does this mean to your business? If you are located in one of the currently covered states (NY, CT, MA. IL, MD, DE ) and choose to participate, with NO cost to you, The Electric Tree can save between 8 and 14% of your electric power bill… if you spend at least $2,000 per month or more on electricity and are willing to donate half your savings to the Foundation. This can be a “win – win” situation. It is very simple to do. If you have interest, please email me with Electric Tree in the subject line.
______________________________________________
4. FDA Guidance & AER Labeling
You can find a listing of FDA guidance documents for the vitamin industry at: http://www.cfsan.fda.gov/guidance.html
Among the new guidances published is a draft labeling guidance for the AER (adverse event reporting) system, with frequently asked questions. This document was finalized on January 2, 2008, as “Guidance for Industry: Questions and Answers Regarding, the Labeling of Dietary Supplements as Required by the Dietary Supplement and
Nonprescription Drug Consumer Protection Act” - Docket No. 2007D-0491. It can be found at: http://www.cfsan.fda.gov/~dms/dsaergu2.html
Here is the summary of the label requirement: “the act requires the label of a dietary supplement being marketed in the United States to include a domestic address or domestic telephone number through which the responsible person may receive a report of a serious adverse event with such dietary supplement. If the label does not include the required domestic address or telephone number, the dietary supplement is misbranded.” FDA also “recommends that the label bear a clear, prominent statement informing consumers that the domestic address or telephone number is for reporting serious adverse events associated with use of the product.”
http://a257.g.akamaitech.net/7/257/2422/01jan20081800/edocket.access.gpo.gov/2008/07-6266.htm
Please note the distinction between “the act requires…” and FDA “recommends.” If a company voluntarily chooses to add language that the phone number or address on the label is there to report AERs, FDA does say “dual purpose” language such as “"To report a serious adverse event or obtain product information, contact..." would be acceptable.
And the FDA’s overall FAQs for AERs cam be found at: http://www.cfsan.fda.gov/~dms/dsaergui.html
That document also states: “Your submission will not be construed by FDA as an admission that the dietary supplement involved caused or contributed to the adverse event being reported. Any serious adverse event report submitted to FDA, including any new medical information submitted as a follow-up to the initial report, is considered a safety report under section 756 of the FD&C Act (21 U.S.C. 379v) and may be accompanied by a statement, which shall be a part of any report that is released for public disclosure, that denies that the report or the records constitute an admission that the product involved caused or contributed to the serious adverse event.”
If you have any occasion to report an adverse event, you ought to have the report reviewed by The Vitamin Lawyer before submitting it.
______________________________________________
5. Cost of food, per calorie
Reuters reported on 01/02/08, “the average price of the lowest-calorie foods -- including green vegetables, tomatoes and berries -- increased by almost 20 percent over 2 years. In contrast, in the same time period there was a 2-percent dip in the cost of the most calorie-laden fare, such as butter, potato chips, cookies and candy bars… findings, published in the Journal of the American Dietetic Association, highlight a key obstacle to healthy eating. … They found that snack foods, sweets and fatty foods offered the most bang for a shopper's buck. Whereas the price of the lowest-calorie fruits and vegetables was more than $18.16 per 1,000 calories, the most calorie-rich foods cost $1.76 per 1,000 calories.”
______________________________________________
6. Upgrading the VL Update eMemo!
Coming early this year: this email update system will be replaced by a second, private blog, the Vitamin Lawyer Update Blog, to allow me to keep you up-to-date better than ever! You’ll receive a shorter weekly update email with links to blog articles that will be posted as the information becomes available… more timely information better indexed!
______________________________________________
You got on this e-list by opting in or becoming a client of the Vitamin Lawyer.com Consultancy. If you want to be taken off the list, please “reply” to this email with the word “remove” in the subject line. On the other hand, you are welcomed to forward this to your own eList…
And do remember to check out the VLUeM Online Archives: http://tinyurl.com/rkneb
Online Seminar compilation of briefs and white papers: http://tinyurl.com/ua9lq
For an outline of typical cGMP SOP docs: http://tinyurl.com/2eu6yj
Vitamin Lawyer Oversight Seal: http://tinyurl.com/2cfoyb
For the latest on Adverse Event Reporting: http://www.aer-consultants.com
Vitamin Lawyer Health Freedom Blog: http://vitaminlawyerhealthfreedom.blogspot.com
For Health Freedom Issues: http://www.globalhealthfreedom.org - Please consider making an end-of-the-year donation to Natural Solutions Foundation - your help is needed to protect the natural products market from bureaucratic interference...
Wishing you and yours a joyous, prosperous, peaceful and free new year!
Ralph Fucetola, JD - The Vitamin Lawyer.com Consultancy
http://www.vitaminlawyer.com – ralph.fucetola@usa.net
All Rights Reserved © 2008 . . .
Friday, December 14, 2007
12/14/07 - Saving Your Company Money
… VLUeM – 12.14.07 - VITAMIN LAWYER WEEKLY UPDATE e-MEMO
This issue: saving your company money…
_______________________________________________
1. Health Freedom Blog update
2. Key food product trends
3. How do your email “click-throughs” rate?
1. Vitamin Lawyer Health Freedom Blog & Factoids
New Posting - http://vitaminlawyerhealthfreedom.blogspot.com/
NJ Tops Maryland in Compulsory Vaccination Stupidity
eAlerts – STOP COMPULSORY DRUGGING & VACCINATION! please go to: http://www.globalhealthfreedom.org and sign up for the eAlert list today! Better, please tell everyone on your elist to do the same! This list of several hundred thousand purveyors and consumers of natural products and remedies is having a powerful impact…
Practice Note #1: FDA has brought together its various guidances on Food Defense and Terrorism. You can find this information at: http://www.cfsan.fda.gov/~dms/defguids.html
“FDA has simplified these documents by repackaging the information found in each guidance document into the new Food Defense Self Assessment Tool.”
Practice Note #2: It took a couple weeks of persistent emails to Google Adsense, but we just got Adsense to reject a paid ad by a competitor of a VitaminLawyer.com client where the competitor had purchased the client’s name to pass-off their inferior product as the real deal… I suspect deciding factors were that the client had her own name as one of her URLs and that it was a well-known name, not just a business phrase, thereby rising to the status of what the law calls a “famous mark.”
______________________________________________
2. Key food product trends
From an email: The 10 Key Trends for 2008 are:
“Key Trend 1: Digestive Health – a wellness issue and the biggest opportunity
Key Trend 2: Fruit and superfruit – the future of food and health
Key Trend 3: The marketing power of “naturally healthy”
Key Trend 4: Beauty foods – the newest niche
Key Trend 5: Weight management more about maintaining than losing
Key Trend 6: Mood food feels its way
Key Trend 7: A tipping point for the premiumisation of health
Key Trend 8: Healthy snacking for the “me” generation
Key Trend 9: Kid’s nutrition – connecting to multiple trends is crucial
Key Trend 10: Antioxidants - the new probiotics…
“Premiumization” has become a standard for healthy foods …which brands are able to command price premiums of 100%-800% over regular foods – and how they do it
Green tea, antioxidants, probiotics and fibres are the ingredients with the brightest futures
Omega-3 and plant sterols will continue to be niche ingredients
How packaging innovation is the biggest product differentiator…”
______________________________________________
3. How do your email blast “click throughs” rate?
What is the average click-through rate for email newsletters? I reproduce an excellent answer from Emaillabs.com:
Answer: The click-through rate is important because without it, you don't get conversions. However, there's no single benchmark click-through rate, because CTRs depend on many factors: whether you send to a business or consumer audience, the kind of mailing you send, how relevant it is to your audience, how often you send, your opt-in process, your use of personalization and segmentation and dozens of other factors. And most significantly, how many links you have in your email and if you are providing content such as articles, whether you include the entire article within the body of the email or you have a teaser or snippet that requires subscribers to click through to a Web site to read.
Beyond that, many companies calculate and report CTRs differently - using total rather unique clicks. Many subscribers will click on multiple links, which means that CTRs based on "total" clicks are typically about two times higher than those based on "unique" clicks..
That being said, below are some ranges for average CTRs for permission-based house lists. CTRs that we cite are based on unique clicks (only one click per person is counted) and are calculated as: unique clicks/emails delivered:
* B2B newsletters typically range from 5% to 15%. If yours are consistently below that level then among other things, you are probably providing content of little value to your subscribers. Or you may have most of the content within your email, not giving subscribers a reason or means to click-through to your site.
* B2C promotional emails often range from about 2% to 12%. Emails with less than a 2% CTR may be a result of over mailing and questionable opt-in processes.
* Highly segmented and personalized lists (B2B and B2C) are often in the 10% to 20% CTR range. Also, email messages with very strong content but sent to unsegmented lists, like many news or trend-type newsletters, are often in the 10%-15% range.
* Trigger or behavior-based emails (emails that are sent to a recipient based on some behavior they showed, such as clicking on a product link, visiting a specific Web page, etc.) are often in the 15% to 50% range.
If your emails are typically showing under say 2-3% CTRs, some of the causes likely include:
* Poor permission or opt-in processes. This includes pre-checked boxes, not making it clear what type of email they will be receiving, automatically adding someone to receive your email when they've actually signed up for something else such as a whitepaper, etc.
* Poorly written subject lines that do not direct and motivate recipients to take an action.
* Poor delivery rates. If a lot of your emails are getting blocked or filtered and you don't know it, your CTR will obviously be affected.
* Poor open rates. If few people open your email, fewer recipients have a chance to click.
* Poor design and layout. If they can't easily find where to click through or aren't motivated to by your layout - you've got trouble in River City.
* Lack of links. Quite simply, the more links the better. Make it so that readers are continuously stumbling over text and graphic links like they do signage in a retail store.
* No reason to click. If your newsletter has a single or multiple articles in their entirety, then don't expect them to click. You haven't given them any reason. If you are sending a promotional email and you don't include a deadline for the offer, or convey a discount, special offer, limited supply, etc., few people are probably going to take action.
emaillabs.com/FAQ/email_marketing_faq_1.html
This issue: saving your company money…
_______________________________________________
1. Health Freedom Blog update
2. Key food product trends
3. How do your email “click-throughs” rate?
1. Vitamin Lawyer Health Freedom Blog & Factoids
New Posting - http://vitaminlawyerhealthfreedom.blogspot.com/
NJ Tops Maryland in Compulsory Vaccination Stupidity
eAlerts – STOP COMPULSORY DRUGGING & VACCINATION! please go to: http://www.globalhealthfreedom.org and sign up for the eAlert list today! Better, please tell everyone on your elist to do the same! This list of several hundred thousand purveyors and consumers of natural products and remedies is having a powerful impact…
Practice Note #1: FDA has brought together its various guidances on Food Defense and Terrorism. You can find this information at: http://www.cfsan.fda.gov/~dms/defguids.html
“FDA has simplified these documents by repackaging the information found in each guidance document into the new Food Defense Self Assessment Tool.”
Practice Note #2: It took a couple weeks of persistent emails to Google Adsense, but we just got Adsense to reject a paid ad by a competitor of a VitaminLawyer.com client where the competitor had purchased the client’s name to pass-off their inferior product as the real deal… I suspect deciding factors were that the client had her own name as one of her URLs and that it was a well-known name, not just a business phrase, thereby rising to the status of what the law calls a “famous mark.”
______________________________________________
2. Key food product trends
From an email: The 10 Key Trends for 2008 are:
“Key Trend 1: Digestive Health – a wellness issue and the biggest opportunity
Key Trend 2: Fruit and superfruit – the future of food and health
Key Trend 3: The marketing power of “naturally healthy”
Key Trend 4: Beauty foods – the newest niche
Key Trend 5: Weight management more about maintaining than losing
Key Trend 6: Mood food feels its way
Key Trend 7: A tipping point for the premiumisation of health
Key Trend 8: Healthy snacking for the “me” generation
Key Trend 9: Kid’s nutrition – connecting to multiple trends is crucial
Key Trend 10: Antioxidants - the new probiotics…
“Premiumization” has become a standard for healthy foods …which brands are able to command price premiums of 100%-800% over regular foods – and how they do it
Green tea, antioxidants, probiotics and fibres are the ingredients with the brightest futures
Omega-3 and plant sterols will continue to be niche ingredients
How packaging innovation is the biggest product differentiator…”
______________________________________________
3. How do your email blast “click throughs” rate?
What is the average click-through rate for email newsletters? I reproduce an excellent answer from Emaillabs.com:
Answer: The click-through rate is important because without it, you don't get conversions. However, there's no single benchmark click-through rate, because CTRs depend on many factors: whether you send to a business or consumer audience, the kind of mailing you send, how relevant it is to your audience, how often you send, your opt-in process, your use of personalization and segmentation and dozens of other factors. And most significantly, how many links you have in your email and if you are providing content such as articles, whether you include the entire article within the body of the email or you have a teaser or snippet that requires subscribers to click through to a Web site to read.
Beyond that, many companies calculate and report CTRs differently - using total rather unique clicks. Many subscribers will click on multiple links, which means that CTRs based on "total" clicks are typically about two times higher than those based on "unique" clicks..
That being said, below are some ranges for average CTRs for permission-based house lists. CTRs that we cite are based on unique clicks (only one click per person is counted) and are calculated as: unique clicks/emails delivered:
* B2B newsletters typically range from 5% to 15%. If yours are consistently below that level then among other things, you are probably providing content of little value to your subscribers. Or you may have most of the content within your email, not giving subscribers a reason or means to click-through to your site.
* B2C promotional emails often range from about 2% to 12%. Emails with less than a 2% CTR may be a result of over mailing and questionable opt-in processes.
* Highly segmented and personalized lists (B2B and B2C) are often in the 10% to 20% CTR range. Also, email messages with very strong content but sent to unsegmented lists, like many news or trend-type newsletters, are often in the 10%-15% range.
* Trigger or behavior-based emails (emails that are sent to a recipient based on some behavior they showed, such as clicking on a product link, visiting a specific Web page, etc.) are often in the 15% to 50% range.
If your emails are typically showing under say 2-3% CTRs, some of the causes likely include:
* Poor permission or opt-in processes. This includes pre-checked boxes, not making it clear what type of email they will be receiving, automatically adding someone to receive your email when they've actually signed up for something else such as a whitepaper, etc.
* Poorly written subject lines that do not direct and motivate recipients to take an action.
* Poor delivery rates. If a lot of your emails are getting blocked or filtered and you don't know it, your CTR will obviously be affected.
* Poor open rates. If few people open your email, fewer recipients have a chance to click.
* Poor design and layout. If they can't easily find where to click through or aren't motivated to by your layout - you've got trouble in River City.
* Lack of links. Quite simply, the more links the better. Make it so that readers are continuously stumbling over text and graphic links like they do signage in a retail store.
* No reason to click. If your newsletter has a single or multiple articles in their entirety, then don't expect them to click. You haven't given them any reason. If you are sending a promotional email and you don't include a deadline for the offer, or convey a discount, special offer, limited supply, etc., few people are probably going to take action.
emaillabs.com/FAQ/email_marketing_faq_1.html
Friday, December 7, 2007
12/07/07 - Insurance for Your Products
… VLUeM – 12.07.07 - VITAMIN LAWYER WEEKLY UPDATE e-MEMO
This issue: saving your company money…
_______________________________________________
1. Health Freedom Blog update
2. Insurance for your products
3. Bayer told to tone down vitamin claims
4. HOLIDAY DISCOUNT: VITAMIN LAWYER’S TIME FOR SALE!
5. Coming next year: improved format for the VL Update eMemo!
______________________________________________
1. Vitamin Lawyer Health Freedom Blog & Factoids
New Posting - http://vitaminlawyerhealthfreedom.blogspot.com/
eAlerts – STOP FORCED VACCINATION! If you are on the Natural Solutions Foundation eAlert list you received an alert about the emergency health freedom advocates’ meeting in Tiburon CA I attended. If you want to stay current on health freedom issues, you really need to sign up to the eAlert list - please go to: http://www.globalhealthfreedom.org and sign up today! Better, please tell everyone on your elist to do the same! This list of several hundred thousand purveyors and consumers of natural products and remedies is having a powerful impact in Washington and internationally.
And they’re getting the idea behind The Codex 2 Step:
"Although Codex is not a regulatory body, its decisions are used as a benchmark of discussion should trade disputes arise in the future, and while Codex does not have the same force of law as an EU directive or national legislation, it is used as a reference point for countries that are looking at revising or creating legislation."
nutraingredients.com/news/ng.asp?n=81841&m=1NIED05&c=jegwylrviswtnqa
For an 8 minute video of me explaining the Codex 2 Step, see: http://youtube.com/watch?v=rlmyvDnn2i0
______________________________________________
2. Insurance for your products
Obtaining product insurance has become increasingly difficult as FDA/FTC regulatory oversight has ratcheted up. I’ve worked with one particular agent here in NJ for nearly a decade and many of the Vitamin Lawyer clients have found his services reassuring. Here is the type of information that is needed for the application.
1) Description of all named insured person or entities
2) Financials – latest annual income statement and balance sheet.
3) 5 years of sales/receipts history
4) Product labels & brochures, reflecting ingredients in the products
5) 5 year currently valued company loss runs or “No Known Loss Letter.
6) Expiring program including carrier, limits, deductible, premiums, and term.
7) Does the insured have or plan on having any products containing Organ/Glandular Extracts, Ephedra, Colloidal Silver, Green Tea, Synephrine/Bitter Orange, Kava, Lobelia, Magnolia or Yohimbe products? If so what are the product names, what percentage of their sales is applicable to these products and how many milligrams go in the products? We will need these product names and labels
I have the 8 page application form available; please email me with “Insurance App” in the subject line.
The agent tells me that he spoke with the underwriters. “They are not willing to speculate on the impact [of the new Adverse Event Reporting law that goes into effect on December 22, 2007]. They aren't doing anything [with rates] at the moment, but will be following it over time to determine its impact. … "
______________________________________________
3. Bayer told to tone down vitamin claims
December 5, 2007 - The National Advertising Division (NAD) of the Council of Better Business Bureaus is recommending Bayer Healthcare modify or discontinue certain claims surrounding its Vital and Sharp Mind supplement. NAD, the Federal Trade Commission and industry trade associations have been targeting the marketing claims of supplement makers. Because this move involves a large player in the health industry getting its knuckles rapped by a monitoring body, it could send out warning signals to smaller companies about being more careful in marketing their products… NAD found no fault with following its review are that Vital & Sharp Mind "supports memory, mental sharpness, and healthy brain function", as well as that it promotes "memory, concentration, and mental sharpness," and can "keep your mind vital and active." [But] … there was insufficient evidence to support the claim made in a television commercial that Vital & Sharp Mind could assist healthy adults in recalling a list of items that was recited moments earlier… this claim suggests the product can actually assist healthy adults in recalling a list of names that was recited moments earlier. The agency says this level of effectiveness goes beyond the general claim made by Bayer that the product "supports" memory and as such requires further scientific evidence…”
nutraingredients-usa.com/news/ng.asp?n=81855&m=1NIUD05&c=jegwylrviswtnqa
______________________________________________
4. Holiday Sale! Vitamin Lawyer Time for Sale…
It’s that time of year when your successful natural product business needs to expense out profits… So, why don’t you prepay The Vitamin Lawyer for consulting time good anytime in 2008? Here’s my special holiday deal: buy two hours at regular rate, $295/hr and get a third hour FREE… that’s a 33% savings! You can reserve as many hours as you’d like. We all know the dollar is tanking… that means all professional fees will be going up this coming year. Lock in 2007 discounted rates now! You can go to my PayPal page, http://tinyurl.com/yvdapx or email me with VL DISCOUNT in the subject line. And have happy holidays; prosperous new year!
______________________________________________
5 Upgrading the VL Update eMemo!
Coming next year: this email update system will be replaced by a second, private blog, the Vitamin Lawyer Update Blog, to allow me to keep you up-to-date better than ever! You’ll receive a shorter weekly update email with links to blog articles that will be posted as the information becomes available… more timely information better indexed!
This issue: saving your company money…
_______________________________________________
1. Health Freedom Blog update
2. Insurance for your products
3. Bayer told to tone down vitamin claims
4. HOLIDAY DISCOUNT: VITAMIN LAWYER’S TIME FOR SALE!
5. Coming next year: improved format for the VL Update eMemo!
______________________________________________
1. Vitamin Lawyer Health Freedom Blog & Factoids
New Posting - http://vitaminlawyerhealthfreedom.blogspot.com/
eAlerts – STOP FORCED VACCINATION! If you are on the Natural Solutions Foundation eAlert list you received an alert about the emergency health freedom advocates’ meeting in Tiburon CA I attended. If you want to stay current on health freedom issues, you really need to sign up to the eAlert list - please go to: http://www.globalhealthfreedom.org and sign up today! Better, please tell everyone on your elist to do the same! This list of several hundred thousand purveyors and consumers of natural products and remedies is having a powerful impact in Washington and internationally.
And they’re getting the idea behind The Codex 2 Step:
"Although Codex is not a regulatory body, its decisions are used as a benchmark of discussion should trade disputes arise in the future, and while Codex does not have the same force of law as an EU directive or national legislation, it is used as a reference point for countries that are looking at revising or creating legislation."
nutraingredients.com/news/ng.asp?n=81841&m=1NIED05&c=jegwylrviswtnqa
For an 8 minute video of me explaining the Codex 2 Step, see: http://youtube.com/watch?v=rlmyvDnn2i0
______________________________________________
2. Insurance for your products
Obtaining product insurance has become increasingly difficult as FDA/FTC regulatory oversight has ratcheted up. I’ve worked with one particular agent here in NJ for nearly a decade and many of the Vitamin Lawyer clients have found his services reassuring. Here is the type of information that is needed for the application.
1) Description of all named insured person or entities
2) Financials – latest annual income statement and balance sheet.
3) 5 years of sales/receipts history
4) Product labels & brochures, reflecting ingredients in the products
5) 5 year currently valued company loss runs or “No Known Loss Letter.
6) Expiring program including carrier, limits, deductible, premiums, and term.
7) Does the insured have or plan on having any products containing Organ/Glandular Extracts, Ephedra, Colloidal Silver, Green Tea, Synephrine/Bitter Orange, Kava, Lobelia, Magnolia or Yohimbe products? If so what are the product names, what percentage of their sales is applicable to these products and how many milligrams go in the products? We will need these product names and labels
I have the 8 page application form available; please email me with “Insurance App” in the subject line.
The agent tells me that he spoke with the underwriters. “They are not willing to speculate on the impact [of the new Adverse Event Reporting law that goes into effect on December 22, 2007]. They aren't doing anything [with rates] at the moment, but will be following it over time to determine its impact. … "
______________________________________________
3. Bayer told to tone down vitamin claims
December 5, 2007 - The National Advertising Division (NAD) of the Council of Better Business Bureaus is recommending Bayer Healthcare modify or discontinue certain claims surrounding its Vital and Sharp Mind supplement. NAD, the Federal Trade Commission and industry trade associations have been targeting the marketing claims of supplement makers. Because this move involves a large player in the health industry getting its knuckles rapped by a monitoring body, it could send out warning signals to smaller companies about being more careful in marketing their products… NAD found no fault with following its review are that Vital & Sharp Mind "supports memory, mental sharpness, and healthy brain function", as well as that it promotes "memory, concentration, and mental sharpness," and can "keep your mind vital and active." [But] … there was insufficient evidence to support the claim made in a television commercial that Vital & Sharp Mind could assist healthy adults in recalling a list of items that was recited moments earlier… this claim suggests the product can actually assist healthy adults in recalling a list of names that was recited moments earlier. The agency says this level of effectiveness goes beyond the general claim made by Bayer that the product "supports" memory and as such requires further scientific evidence…”
nutraingredients-usa.com/news/ng.asp?n=81855&m=1NIUD05&c=jegwylrviswtnqa
______________________________________________
4. Holiday Sale! Vitamin Lawyer Time for Sale…
It’s that time of year when your successful natural product business needs to expense out profits… So, why don’t you prepay The Vitamin Lawyer for consulting time good anytime in 2008? Here’s my special holiday deal: buy two hours at regular rate, $295/hr and get a third hour FREE… that’s a 33% savings! You can reserve as many hours as you’d like. We all know the dollar is tanking… that means all professional fees will be going up this coming year. Lock in 2007 discounted rates now! You can go to my PayPal page, http://tinyurl.com/yvdapx or email me with VL DISCOUNT in the subject line. And have happy holidays; prosperous new year!
______________________________________________
5 Upgrading the VL Update eMemo!
Coming next year: this email update system will be replaced by a second, private blog, the Vitamin Lawyer Update Blog, to allow me to keep you up-to-date better than ever! You’ll receive a shorter weekly update email with links to blog articles that will be posted as the information becomes available… more timely information better indexed!
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