Divine Skin Solutions, inc. Divine Skin Solutions, Inc. sells a galvanic electric tweezer
device under the name Vector for "an unbelievably low price
of $199.95."
The Vector by Divine Skin Solutions
should be avoided by all consumers. It makes illegal and unsubstantiated
claims of permanent hair removal.
Contact information: ( = claimed to be incorrect by manufacturer. See Update,
below.)
 Address: 1983 Marcus Avenue Lake Success,
NY 11042
Phone: (800) 443-4522
email: nautilus@eclipse.net
email: divineskin@nyc.rr.com
website: http://www.divineskin.com
website: http://www.smoothdivineskin.com (mirror
site)
sales server: Five Star Advantage (fivestardavantage.com)
(800) 443-4522
aka Tech-Ni-Comm, Inc.25006 Avenue Kearny Valencia, CA 91355
(technicomm@worldnet.att.net
)
Alternate Contact Address: "Valery
Smirnov" 8357 118th St., Apartment #5F, Kew Gardens NY
11415 (see below)
Alternate Phone: (718) 805-3569 (see below)
Names associated with this product
"Leo Smirnov"
"Leo Smironov"
"John Gubin"
"Valery Smirnov" (see below)
"Paul Condering" (see below)
Update one
On 12 April 2001, I received the following
letter from " John Gubin, V.P. Marketing." My comments to
them are in italics.
To Whom it May Concern:
We have noticed that you are making certain
claims about our company. Please consider the following -
- The contact information you have is
incorrect.
Please provide the correct contact
information, and I'll include it.
- Valery Smirnov and Paul Condering do
not exist in this company.
They are listed as contacts for
your company. Please clarify their relationships to Divine
Skin Solutions.
- You may search the FDA website and
find that we are indeed registered with the FDA. We are making
perfectly legal claims.
Your use of the FDA logo and reference
to your FDA registration are illegal. References to FDA, in
advertisements or other promotional materials for medical
devices, are prohibited by the Federal Food, Drug, and Cosmetic
Act and represent misbranding under section 502(a). The reference
for this may be found under 21 CFR 807.97.
- Hair does not conduct electricity,
the use of gel allows hair to conduct electricity.
I agree, but your competitor says hair does conduct electricity.
Please also note, that you have exactly
24 hours to remove any false claims regarding our company from
your website. If this information is not removed by April 13th,
2001 at 5pm we will proceed with a lawsuit for punitive damages.
You have no grounds for a lawsuit.
All of my information is factual. I look forward to receiving
your updated contact information and your explanation regarding
Paul Condering and Valery Smirnov.
Update two
On 13 April 2001, I received the following
letter from " John Gubin, V.P. Marketing." My comments to
them are in italics.
1. The correct contact information is - 1983 Marcus Avenue
Lake Success, NY 11042
What is your office suite number?
There are many business offices listed at that address.
2. Valery Smirnov and Paul Condering are not listed anywhere
as contacts for our company. These two individuals simply do
not exist in this company.
They are listed as contacts in
your own company information. Please describe their relationship
to Divine Skin Solutions. Are they assumed names used by people
in your company?
3. Our website has been inspected by our representative at
the FDA and she is fully aware of our use of the FDA logo. We
are not making claims that our product is "approved"
by the FDA, we are claiming that our product is registered with
the FDA.
Your conspicuous display of your
registration number with FDA logo appears to a reasonable
consumer to be an endorsement by FDA. My information is based
on comments by Steve Budabin at FDA's national enforcement
office. Please tell me the name of your local FDA contact,
and I will call her to confirm your claims. According to other
cases like yours, conspicuous reference to your establishment
registration implies FDA approval and is a violation of 21
CFR 807.39, which I have quoted below:
21 CFR 807.39
Misbranding by reference to establishment
registration or to registration number.
Registration of a device establishment
or assignment of a registration number does not in any way
denote approval of the establishment or its products. Any
representation that creates an impression of official approval
because of registration or possession of a registration number
is misleading and constitutes misbranding.
You can confirm this by contacting
the Food and Drug Administration, Center for Devices and Radiological
Health, Division of Small Manufacturers Assistance (HFZ-220),
1350 Piccard Drive, Rockville, Md. 20850 (telephone: 800-638-2041
toll free or 301-443-7491). All inquiries should provide complete
information concerning the device and include a copy of the
proposed labeling if the manufacturer contemplates shipping
the device within the United States. Proposed labeling may
be submitted in draft form and need not be printed.
4. Hair has electrical resistance and can conduct current.
However, the voltages required for hair to conduct current will
be lethal. Therefore, in practical terms hair cannot conduct
electricity and electro-conductive gel is required to allow
the current to travel down the hair shaft.
5. We have huge groungs for a lawsuit. You are stating that
our product is a scam, and this information is not factual.
Published clinical data indicates
that electric tweezers result in temporary removal of hair.
In 1998 FDA stated there is no statistically significant scientific
data indicating the device can achieve permanent removal of
hair. If you have substantiation that it's permanent, you
need to provide it.
I would like to remind you, that you have just a few more hours
to remove this information from your website. We fully intend
to proceed with a lawsuit.
I don't believe that you are familiar with our product and
neither have you tried using it. Please be reasonable and do
not cause our companies unnecessary trouble - a lawsuit will
be expensive for both of us.
The burden of proof is on you to
prove your claims of permanence, and you have not done so.
Until you have provided substantiation for your comparative
claims, your product is being promoted illegally.
I will update this as soon as I get a response.
Quotations from their sales site:
The site has a reference to FDA on their front page. Although
they are registered, consumers should know they are not approved
by FDA or endorsed by FDA. Implying FDA endorsement constitutes
misbranding and violates federal law.
Proprietary Device Name: VECTOR
Owner/Operator: DIVINE SKIN SOLUTIONS, INC.
Owner/Operator Number: 9043298
Date of Listing: 10/03/00
Listing Status: Active
Establishment Operations: Manufacturer
The main page states says Vector's for you
"if you are also tired of using products that
make deceiving claims about hair removal," then goes on
to make the following deceiving claims:
"We have developed a hair removal machine specifically
configured for the home user to offer PERMANENT results.
"The Vector machine is just as effective as real electrolysis,
yet does not use needles and requires minimal skill to be
operated!
"you will find some straight talk about hair removal
and how our Vector machine is a permanent solution to unwanted
hair at a very affordable price.
The section on how it works claims: "The Vector
machine works by simply grasping the hair with tweezers and
applying a highly conductive gel with silver chloride. Without
the electrically conductive gel this process would not work,
as hair cannot conduct electricity. Applying
silver chloride gel to the hair above the skin allows electrical
current to pass over the non-conductive portion down into the
hair follicle." This statement is repeated here: "Unfortunately, hair
cannot conduct current." The electric tweezer
scams need to get their story straight. Others (like GHR) claim
the hair does conduct current.
Their ironically-titled truth page says: "If you have been
fooled into purchasing those products by false advertising you
may be reluctant to believe our claims as well. Rest assured
that you will have real results and PERMANENT hair removal.
The Vector is your professional electrolysis in a small box."
After the scam site's obligatory anonymous, unverifiable testimonials, the pricing page states:"The entire Vector
electrolysis system comes with all you need to start immidiate
[sic] treatments and is available for an unbelievably
low price of $199.95."
Save your money. There is no published proof that electric
tweezers can perform permanent hair removal.
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