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
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 (firstname.lastname@example.org )
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
"Valery Smirnov" (see below)
"Paul Condering" (see below)
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.
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.