Complaint to: UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

Filed by: The FEDERAL TRADE COMMISSION and THE PEOPLE OF THE STATE OF NEW YORK

Against Plaintiffs: QUINCY BIOSCIENCE HOLDING COMPANY, INC., PREVAGEN, INC. and others

Citing:

1.)By the Federal Trade Commission:

REPEATED FRAUDULENT OR ILLEGAL ACTS

FALSE OR UNSUBSTANTIATED EFFICACY CLAIMS

FALSE PROOF CLAIMS

2.)VIOLATIONS OF NEW YORK STATE LAW

DECEPTIVE ACTS OR PRACTICES AND FALSE ADVERTISING

• • • Prevagen improves memory;

    • Prevagen improves memory within 90 days;

    • Prevagen reduces memory problems associated with aging;

    • Prevagen provides other cognitive benefits, including but not limited to healthy brain function, a sharper mind, and clearer thinking.

CONSUMER INJURY

• • • “Consumers have suffered and will continue to suffer substantial injury as a result of Defendants’ violations.

    • In addition, Defendants have been unjustly enriched as a result of their unlawful acts or practices.

    • Absent injunctive relief by this Court, Defendants are likely to continue to injure consumers, reap unjust enrichment, and harm the public interest.”

(https://www.ftc.gov/system/files/documents/cases/quincy_bioscience_complaint-filed_version.pdf)