The operator of a multilevel marketing supplement business, Amare Global Holdings Inc., along with three of its principals, has been sued over allegations that the company misrepresented to parents and other consumers that its dietary supplements — some specifically marketed to children — could treat or cure mental health conditions including depression, anxiety, and ADHD.DOCUMENTED
The complaint also alleges Amare misled recruits, known within the company as "brand partners," about how much money they could realistically expect to earn selling the products.DOCUMENTED
- Amare sells supplements including Kids Happy Juice, Kids Mood+, and the Happy Juice Product Pack.
- Named defendants include Shawn Talbott, Amare's former chief science officer; Patrick Hintze, its founding brand partner; and David Chung, its current CEO and majority shareholder.
- Brand partners marketed products as able to reduce suicide risk in children, according to the complaint.
- A study cited as supporting evidence for Kids Mood+ reportedly used no placebo group and included only 10 participants.
- Talbott and Hintze are already subject to a prior FTC order barring false or unsubstantiated health claims.
Marketing built around neurotransmitters and cortisol
According to the complaint, Amare and its brand partners advertised the company's products across Instagram, TikTok, YouTube, and Facebook with claims that they could improve mental conditions in both children and adults, including depression, anxiety, and ADHD.DOCUMENTED Marketing materials described the supplements as able to "normalize serotonin and dopamine activity" and "balance stress hormones," framing everyday mood and behavior in the vocabulary of brain chemistry to lend the claims a clinical appearance.DOCUMENTED
Brand partners went further in individual social media posts, according to the complaint, describing the products as "scientifically backed" or "clinically proven" and claiming they could treat or mitigate depression — in at least one instance specifically including a claim about reducing the risk of suicide in children.DOCUMENTED One brand partner posted that giving her children the kids' formula, after already using the adult version herself, "transformed" her household.REVIEWED
The evidence behind the claims
The FTC's complaint states plainly that there is no competent and reliable scientific evidence supporting the health claims made for Amare's products, and that the studies the company and Talbott point to in their own defense are themselves deeply flawed.DOCUMENTED As one specific example, the study cited as support for Kids Mood+ improving children's focus, mood, and overall performance reportedly used no placebo control group at all and included a total of just 10 participants.DOCUMENTED
A study of that size and design cannot reliably distinguish an actual treatment effect from ordinary variation, a placebo response, or simple chance — which is precisely why regulators, and the broader scientific community, generally require randomized, placebo-controlled trials with meaningfully larger sample sizes before treating a health claim as substantiated.REVIEWED
Recruits and the earnings pitch
Beyond the health claims, the complaint alleges Amare made deceptive earnings representations to prospective brand partners, including specific dollar claims — such as the ability to earn $500 a month — and broader promises that recruits could supplement or entirely replace their existing income, even without prior MLM sales experience or an established social media following.DOCUMENTED That combination — a health-focused product line paired with a recruitment-driven compensation structure — places Amare within a business model the FTC has scrutinized repeatedly across the multilevel-marketing industry, in which most participants' actual earnings depend far more on recruiting new sellers than on retail sales to genuine end customers.REVIEWED
The supporting study for one children's product reportedly involved 10 participants and no placebo group — the evidentiary foundation beneath marketing that claimed the product could help treat depression, anxiety, and ADHD in kids.
A defendant who had already been here before
Shawn Talbott's involvement carries particular weight because he was previously a defendant in a separate FTC case, Window Rock Enterprises, over his role advertising two other supplements, CortiSlim and CortiStress — a case that resulted in an order specifically barring him from making false, misleading, or unsubstantiated health claims going forward.DOCUMENTED Days after filing its new complaint, the FTC separately asked a federal court to hold Amare, Talbott, Hintze, and former Amare CEO Hiep Tran in contempt, alleging they acted in concert to systematically violate that earlier order's terms.DOCUMENTED
Why marketing to children raises the stakes
Health claims aimed at adult consumers already require substantiation under advertising law, but claims specifically targeting children's mental health carry additional weight given how directly parents rely on marketed claims — rather than a child's own judgment — when deciding what to give a child to manage mood, focus, or anxiety.REVIEWED A parent choosing a supplement over, or alongside, an evaluation from a pediatrician or mental health professional based on unsubstantiated marketing claims may delay care a child actually needs, a risk regulators have identified as a central reason to scrutinize child-directed health marketing especially closely.REVIEWED
Because the case was only recently filed, the underlying allegations against Amare, Talbott, Hintze, and Chung remain unproven, and the litigation will continue in federal court alongside the separate contempt proceeding tied to Talbott's earlier order.REVIEWED
Why the multilevel structure complicates accountability
In an MLM model, the most extreme individual health claims are often made not by the company itself in its official marketing, but by independent brand partners posting on their own personal social media accounts — a structure that can let a company maintain more measured official messaging while individual sellers, competing for recruitment and sales within the same compensation system, drift toward increasingly aggressive claims to differentiate themselves.REVIEWED The FTC's complaint addresses this directly by treating the company and its named principals as responsible for brand-partner claims made using company-provided marketing materials and training, rather than treating each individual seller's post as an isolated, unaffiliated statement.REVIEWED
For parents evaluating any supplement marketed for a child's mood, focus, or mental health, the case underscores a straightforward standard: a legitimate health claim should be traceable to a properly designed, adequately sized clinical study, not to a single small trial without a placebo comparison, and consulting a pediatrician before starting any supplement intended to address a child's emotional or behavioral symptoms remains a safer first step than relying on a brand partner's personal testimonial.REVIEWED
Sources behind this report
Have documents relevant to this story? Reach us through our tips channel.