ANALYSIS OF PROPOSED CONSENT
                        ORDER TO AID PUBLIC COMMENT

   The Federal Trade Commission has accepted, subject to final approval,
   an agreement to a proposed consent order from Panda Herbal
   International, Inc. ("Panda"), a corporation, and Everett L. Farr III,
   individually and as an officer of the corporation ("proposed
   respondents").

   The proposed consent order has been placed on the public record for
   thirty (30) days for the receipt of comments by interested persons.
   Comments received during this period will become part of the public
   record. After thirty (30) days, the Commission will again review the
   agreement and comments received and will decide whether it should
   withdraw from the agreement and take appropriate action or make final
   the agreement's proposed order.

   This matter involves proposed respondents' making of health-related
   advertising claims on the Internet and elsewhere for their Herbal
   Outlook (a dietary supplement that contains St. John's Wort) and
   HerbVeil 8 (a topical ointment) products. The proposed complaint
   alleges that proposed respondents violated Sections 5 and 12 of the
   Federal Trade Commission Act by making deceptive claims for these
   products.

   The proposed complaint alleges that respondents' claims that ingestion
   of Herbal Outlook is effective in the treatment of HIV/AIDS, herpes
   simplex, tuberculosis, influenza, and hepatitis B infections are
   unsubstantiated. Further, the proposed complaint alleges that
   respondents deceptively fail to disclose significant adverse drug
   interactions in light of respondents' implied drug compatibility claim
   ("ingestion of St. John's Wort, an ingredient in Herbal Outlook, is
   effective in the treatment of HIV/AIDS"). The proposed complaint also
   alleges that respondents' claim that ingestion of St. John's Wort, an
   ingredient in Herbal Outlook, has no known contraindications or drug
   interactions is false because there is substantial information
   available documenting significant adverse drug interactions. In
   addition, the proposed complaint alleges that respondents' HerbVeil 8
   claims that topical application of HerbVeil 8 is effective in the
   treatment of carcinomas, adenocarcinomas, and melanomas are
   unsubstantiated.

   For purposes of the proposed order, a "covered product or service"
   means any service, program, dietary supplement, food, drug, or device.

   The proposed order defines "Herbal Outlook product" as respondents'
   Herbal Outlook or any other covered product or service for which the
   term "Hypericum Perforatum" or "St. John's Wort" appears on the

                        UNITED STATES DISTRICT COURT
                   FOR THE NORTHERN DISTRICT OF ILLINOIS
                              EASTERN DIVISION

                         FEDERAL TRADE COMMISSION,
                                 Plaintiff
                                    vs.
                    NEW MILLENNIUM CONCEPTS, INC. d/b/a
                             RHINOPOINT.COM and
      KARL V. KAY, individually, and as an officer of the corporation,
                                Defendants.

                                  Case No.

            COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF

   Plaintiff, the Federal Trade Commission ("FTC" or "the Commission")
   for its Complaint alleges as follows:

   1. The FTC brings this action under Section 13(b) of the Federal Trade
   Commission Act ("FTC Act"), 15 U.S.C. § 53(b), to secure temporary,
   preliminary, and permanent injunctive relief, restitution, recission
   of contracts, disgorgement and other equitable relief for Defendants'
   deceptive acts or practices in violation of Section 5(a) of the FTC
   Act, 15 U.S.C. § 45(a).

                           JURISDICTION AND VENUE

   2. This Court has jurisdiction over this matter pursuant to 15 U.S.C.
   §§ 45(a) and 53(b), and 28 U.S.C. §§ 1331, 1337(a) and 1345.

   3. Venue in the United States District Court for the Northern District
   of Illinois is proper under 15 U.S.C. § 53(b), and 28 U.S.C.
   §§ 1391(b) and (c).

                                  PARTIES

   4. Plaintiff FTC is an independent agency of the United States
   Government created by statute. 15 U.S.C. §§ 41-58. The FTC is charged,
   inter alia, with enforcement of Section 5(a) of the FTC Act, 15 U.S.C.
   § 45(a), which prohibits unfair or deceptive acts or practices in or
   affecting commerce. The FTC is authorized to initiate federal district
   court proceedings, by its own attorneys, to enjoin violations of the
   FTC Act and to secure such equitable relief as may be appropriate in
   each case, including restitution for injured consumers. 15 U.S.C.
   § 53(b).

   5. Defendant New Millennium Concepts, Inc. ("New Millennium") is an