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Writer's pictureAsa Waldstein

Implying symptomatic use of CBD for COVID as relates to "material connection" will get a letter

Updated: Dec 14, 2020




Although this ingredient may be useful, discussing this in a format that implies sellable product usefulness crosses the compliance line.


From Warning Letter:

“‘What we are seeing here is, what we feel, a direct effect from what's happening with the coronavirus. Our customers are suggesting that using CBD is helping to ease the symptoms of COVID-19. We are seeing people literally flocking to purchase high quality CBD for the potential relief it gives,’ states Justin Elenburg, Patriot Supreme's CEO and Founder.” [Your post is followed by a picture of your CBD product, from a July 23, 2020, post on your Facebook page]

Notice this Facebook post is near three months old? My suggestion is to check old social media posts for claims, then retroactively clean them up. This is one of the many reasons to learn how to read FDA/FTC trends.













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