Department of Health and Human Services' logo Department of Health and Human Services

Public Health Service
Food and Drug Administration
New England District


One Montvale Ave
Stoneham, MA 02180
Fax: 781-596-7896

January 30, 2006

Nina E. Anderson
The Long Life Catalog Co
561 Shunpike Rd
Sheffield, MA 01257-9758

Ref. No. NWE-06-06W

Dear Ms Anderson:

The Food and Drug Administration (FDA) has reviewed your website at the Internet address and has concluded that claims in your labeling cause your product ISD-10 Immune System Defense to be a drug as defined in section 201(g)(1)(B) of the Federal Food, Drug, and Cosmetic Act (the Act) [21 USC 321(g)(1)(B)]. You can find the Act and FDA's regulations through links on FDAs Internet homepage:

Under the Act, articles intended for use in the diagnosis, cure, mitigation, treatment or prevention of disease in man are drugs [Section 201(g)(1)(B) of the Act, 21 USC 321(g)(1)(B)]. Your website claims that your product is useful in the prevention and treatment of avian flu and other forms of influenza.

The Internet labeling of your product bears the following claims:

These claims cause your product to be a drug, as defined in section 201(g)(1)(B) of the Act [21 USC 321(g)(1)(B)]. Because your product is not generally recognized as safe and effective when used as labeled, it is also a new drug as defined in section 201(p) of the Act [21 USC 321(p)]. Under section 505 of the Act [21 USC 355 (a)], a new drug may not be legally marketed in the United States without an approved New Drug Application (NDA).

This letter is not an all-inclusive review of your website and the products your firm markets. It is your responsibility to ensure that all products marketed by your firm comply with the Act and its implementing regulations.

You must immediately correct these violations. If you do not immediately correct them, you may be subject to enforcement action without notice. The Act provides for seizure of illegal products and for injunctions against the manufacturers and distributors of illegal products [21 USC 332 and 334]. Individuals and businesses that violate the Act may also be subject to criminal prosecution.

Please advise this office, in writing and within fifteen (15) working days of the receipt of this letter, as to the specific steps you haven taken to correct the violations noted above and to ensure that similar violations do not occur. If corrective actions cannot be completed within fifteen working days, state the reason for the delay and the time within which the corrections will be completed. Your written response should be sent to Seth A. Mailhot, Compliance Officer, US Food and Drug Administration, New England District Office, 1 Montvale Ave, 4th Fl, Stoneham, MA 02180-3500.

If you have any questions about this letter, please contact Mr Mailhot by telephone at 781-596-7769 or by fax at 781-596-7896.

Gail T. Costello
District Director

Company's response to FDA

This page was revised on August 5, 2010.

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