UNITED STATES OF AMERICA
                                        FEDERAL TRADE COMMISSION

COMMISSIONERS:
           Timothy J. Muris, Chairman
            Sheila F. Anthony
            Mozelle W. Thompson
            Orson Swindle
            Thomas B. Leary


        In the Matter of


     KRIS A. PLETSCHKE                                      DOCKET NO. C-4040
          individually and d/b/a                            DECISION AND ORDER
        Raw Health

            The Federal Trade Commission having initiated an investigation of certain acts and
the respondent named in the caption hereof, and the respondent having been furnished thereafter
copy of a draft complaint which the Bureau of Consumer Protection proposed to present to the
Commission for its consideration and which, if issued by the Commission, would charge respondent
with violations of the Federal Trade Commission Act; and

            The respondent and counsel for the Commission having thereafter executed an agreement
containing a consent order, and admission by the respondent of all the jurisdictional facts set
draft complaint, a statement that the signing of said agreement is for settlement purposes only and
not constitute an admission by respondent that the law has been violated as alleged in such
or that the facts as alleged in such complaint, other than jurisdictional facts, are true, and
other provisions as required by the Commission's Rules; and

            The Commission having thereafter considered the matter and having determined that it had
reason to believe that the respondent violated the said Act, and that a complaint should issue
charges in that respect, and having thereupon accepted the executed consent agreement,  now in
conformity with the procedure prescribed in Section 2.34(c) of its Rules, the Commission hereby
its complaint, makes the following jurisdictional findings, and enters the following order:


1.          Respondent Kris A. Pletschke is an individual doing business and residing at 11355 SW



St., Beaverton, OR 97005 under the trade name "Raw Health."


2.      The Federal Trade Commission has jurisdiction of the subject matter of this proceeding and
the respondents, and the proceeding is in the public interest.

                                                                                022 3070
                                                UNITED STATES OF AMERICA
                                              FEDERAL TRADE COMMISSION

____________________________________
                                                                ))
            In the Matter of                                    )
                                                                )
KRIS A. PLETSCHKE                                               )     DOCKET NO. C-4040
            individually and d/b/a                              )
            Raw Health.                                         )
                                                                 )
                                                                )
____________________________________)


                                                        COMPLAINT


            The Federal Trade Commission, having reason to believe that Kris A. Pletschke
("respondent"), individually, and doing business as Raw Health, has violated the provisions of the
Federal Trade Commission Act, and it appearing to the Commission that this proceeding is in the
public interest, alleges:
1.          Respondent Kris A. Pletschke is a resident of Oregon.  His principal office or place of
business is 11355 SW 14th St., Beaverton, OR 97005.  Individually, or in concert with others, he
formulates, directs, or controls the policies, acts, or practices of the business operating under
trade name "Raw Health," including the acts and practices alleged in this complaint.
2.a.        Respondent has promoted, advertised, labeled, offered for sale, sold and distributed
directly to the public a colloidal silver liquid product called Colloidal Silver, various vitamin,
mineral, and herbal products, and other health products, including by means of an Internet Web
site,  , that provides product and purchase information and advertising and
promotional claims.

2.b.  Respondent's Colloidal Silver is purportedly a liquid containing 260 ppm silver, enhanced
with gold, quartz, and emerald essence in a water solution, that can be used for various therapeutic
purposes through oral ingestion, intravenous administration, nasal spray, anal and vaginal
administration, or topical application.  Colloidal Silver is either a "food" or "drug" within the
meaning of Sections 12 and 15 of the Federal Trade Commission Act.
3.          The acts and practices of respondent alleged in this complaint have been in or affecting
commerce, as "commerce" is defined in Section 4 of the Federal Trade Commission Act.
4.          Respondent has disseminated or has caused to be disseminated advertisements or

                                                         Page 1 of  11



promotional materials for Colloidal Silver, through, among other media, websites on the Internet,
including but not necessarily limited to the attached Exhibits A and B.  These advertisements
the following statements, among others:

                                                                 022 3070

                            Analysis of Consent
                        Order to Aid Public Comment

   In the Matter of Kris A. Pletschke, individually and d/b/a Raw Health
                             File No. 022 3070
            ____________________________________________________

   The Federal Trade Commission has accepted an agreement to a consent
   order from Kris A Pletschke, d/b/a/ Raw Health (" respondent"), and
   has issued a Complaint and the Decision and Order ("Order") contained
   in the Consent Agreement. Respondent marketed "Colloidal Silver," a
   dietary supplement allegedly containing submicroscopic particles of
   silver that was intended to be taken orally and in other manners for
   the cure and treatment of more than 650 diseases.

   The Commission's complaint charges that respondent made false claims
   that his Colloidal Silver product (1) is effective in treating or
   curing 650 diseases; (2) eliminates all pathogens in the human body in
   six minutes or less; and (3) has been medically proven to kill every
   destructive bacterial, viral and fungal organism in the body,
   including anthrax, Ebola, Hunta, and "flesh-eating bacteria." The
   Commission's complaint also charges that respondent failed to have a
   reasonable basis for claims he made that his Colloidal Silver product
   (1) is effective in treating 650 diseases and health-related
   conditions, including AIDS, allergies, anthrax, arthritis, blood
   poisoning, boils, wounds of the cornea, chronic fatigue, cerebral
   spinal meningitis, candida, cholera, colitis, cystitis, dental plaque,
   diabetes, diphtheria, dysentery, enlarged prostate, gonorrhea, herpes,
   hepatitis, infantile diseases, lesions, leukemia, lupus, Lyme disease,
   parasites, rheumatism, ringworm shingles, skin cancer, staph and strep
   infections, stomach flu, thyroid conditions, tonsillitis, toxemia,
   stomach ulcers and whooping cough; (2) kills the HIV virus and can be
   used as an antibiotic for all acquired diseases of active AIDS; (3) is
   superior to antibiotics in killing disease-causing organisms and the
   treatment of burns; (4) protects and strengthens the immune system;
   (5) can safely be used on open wounds, sprayed into the eye, injected,
   used orally, vaginally, anally, atomized or inhaled into the nose or
   lungs and dropped into the eyes; (6) has no side effects, even at
   double or triple the normal dose of 260 ppm, and is safe for children
   and pregnant and nursing women; and (7) aids the growth and health of
   the developing fetus and eases delivery and recovery.

   Part I of the consent order prohibits respondent from misrepresenting
   any claims that Colloidal Silver or any food, dietary supplement,
   drug, device, or health-related service or program has been medically
   proven to kill disease-causing organisms or any number of infections

                                  UNITED STATES OF AMERICA
                                  FEDERAL TRADE COMMISSION

____________________________________
                                                     )
        In the Matter of                  )          FILE NO. 022-3070
                                                      )
KRIS A. PLETSCHKE                                    )     AGREEMENT CONTAINING
        individually and d/b/a                       )     CONSENT ORDER
        Raw Health.               .                  ))
____________________________________)


        The Federal Trade Commission has conducted an investigation of certain acts and practices
of proposed respondent, Kris A. Pletschke, individually and doing business as Raw Health.  Kris
A. Pletschke is willing to enter into an agreement containing a consent order resolving the
allegations contained in the attached draft complaint.  Therefore:

IT IS HEREBY AGREED by and between Kris A. Pletschke ("proposed respondent"),
individually and d/b/a Raw Health, and counsel for the Federal Trade Commission that:

1.      Proposed respondent Kris A. Pletschke is a  resident of Oregon.  His principal office or
place of business is 11355 SW 14th street, Beaverton, OR 97005.  Individually, or in concert with
others, he formulates, directs, or controls the policies, acts, or practices of the business
under the trade name "Raw Health."

2.      Proposed respondent admits all the jurisdictional facts set forth in the draft complaint.

3.      Proposed respondent waives:

        a.      Any further procedural steps;

        b.      The requirement that the Commission's decision contain a statement of findings of
                fact and conclusions of law; and

        c.      All rights to seek judicial review or otherwise to challenge or contest the
                the order entered pursuant to this agreement.


                                               Page 1 of  11



4.      This agreement shall not become part of the public record of the proceeding unless and until
it is accepted by the Commission.  If this agreement is accepted by the Commission, it, together
with the draft complaint, will be placed on the public record for a period of thirty (30) days and
information about it publicly released.  The Commission thereafter may either withdraw its
acceptance of this agreement and so notify proposed respondent, in which event it will take such
action as it may consider appropriate, or issue and serve its complaint (in such form as the

                                            ATTACHMENT A


                          LETTER SENT TO DISTRIBUTORS WITH WHOM
              RESPONDENT HAS DONE BUSINESS BETWEEN JANUARY 1, 1999
                          AND THE DATE OF SERVICE OF THIS ORDER


[To Be Printed on Kris Pletschke's or Raw Health's letterhead]

[NAME AND ADDRESS OF RECIPIENT]

[DATE]

Dear [DISTRIBUTOR'S NAME]:

        This letter is to inform you that Raw Health recently settled a civil dispute with the
Trade Commission regarding its advertising for Colloidal Silver.  Among other things, the settlement
requires us to notify distributors of the settlement.  Importantly, the settlement requires us to
monitor our distributors and terminate all distributors making prohibited claims for Colloidal
Silver or any other dietary supplement, food or drug purchased from us for resale.

         According to the FTC complaint, our advertising materials falsely claimed that Colloidal
(1) is effective in treating or curing 650 diseases; (2) eliminates all pathogens in the human body
minutes or less; (3) has been medically proven to kill every destructive bacterial, viral and fungal
organism in the body, including anthrax, Ebola, Hunta, and "flesh-eating bacteria."  In addition,
complaint alleged that we did not have a reasonable basis to claim that Colloidal Silver (1) is
in treating AIDS, allergies, anthrax, arthritis, blood poisoning, boils, wounds of the cornea,
fatigue, cerebral spinal meningitis, candida, cholera, colitis, cystitis, diabetes, diphtheria,
enlarged prostate, gonorrhea, herpes, hepatitis, infantile diseases, lesions, leukemia, lupus, Lyme
disease, parasites, dental plaque,  rheumatism, ringworm shingles, skin cancer, staph and strep
infections, stomach flu, thyroid conditions, tonsillitis, toxemia, stomach ulcers and whooping
kills the HIV virus and can be used as an antibiotic for all acquired diseases of active AIDS; (3)
superior to antibiotics in killing disease-causing organisms and the treatment of burns; (4)
strengthens the immune system; (5) can safely be used on open wounds, sprayed into the eye,
used orally, vaginally, anally, atomized or inhaled into the nose or lungs and dropped into the
has no side effects, even at double or triple the normal dose of 250 ppm, and is safe for children
pregnant and nursing women; and (7) aids the growth and health of the developing fetus and eases
delivery and recovery.

        Please sign, date, and return this letter to Kris Pletschke at 11355 SW 14th Street,
OR 97005.  A copy of this letter has been provided for your files.  If you have any questions or you
want a copy of the FTC order, please contact [Insert name and telephone number of respondent's



contact].  Thank you for your anticipated cooperation and assistance.