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Date of Meeting: 03/11/11
Code: 2011-08-007
Product: Circulation Booster
Complainant: Requested anonymity
Respondent: High Tech Health Pty Ltd
Finding: Justified
Sections Found Justified: Act sections 42DL(1)(g); Code sections 4(1)(b), 4(2)(a), 4(2)(c), 4(2)(d), 4(2)(g), 4(6)(b), 4(7), 5
Sections Found Not Justified: Code sections 4(8)
Action: Publication of retraction, Withdraw advertisement; withdraw representations
Panel Determination:
COMPLAINTS RESOLUTION PANEL DETERMINATION

Complaint 2011-08-007 Circulation Booster and Ultralieve

Meeting held 3 November 2011

 




































Complaint summary


Complainant


Requested anonymity


Advertiser


High Tech Health Pty Ltd


Subject matter of complaint


Website advertisements


Type of determination


Final


Sections of the Code, Regulations or Act found to have been breached*


Code sections 4(1)(b), 4(2)(a), 4(2)(c), 4(2)(d), 4(2)(g), 4(6)(b), 4(7), 5

Act sections 42DL(1)(g)


Sections of the Code, Regulations or Act found not to have been breached*


Code sections 4(8)


Sanctions

 


Withdrawal of representations

Withdrawal of advertisement

Publication of a retraction


 

 

 

 

 

 

 

 


* only sections of the Code, Act, or Regulations that were part of the complaint or were raised by the Panel are listed
The advertisement(s)


1.      The complaint concerned a website advertisement published at the website www.circulationbooster.com.au.

2.      The advertisement described the “Circulation Booster v3” device and made claims such as: “Helps to relieve aches, pains and swelling in the lower legs and feet”; “Just 30 minutes a day may help to improve circulation, reduce swollen feet and ankles, ease aching legs [and] aid muscular recovery”; “We ... are constantly undertaking clinical studies with leading Universities”; “helps to remedy blood circulation, bad circulation, back pain, cold feet and cold hands, joint pain, leg pain, mobility & inactivity, muscular injuries/pain, poor circulation, restless leg syndrome, stress and tension [and] swelling/fluid retention”; “increases blood flow throughout the lower limbs”; “increase pain-free walking associated with arthritis or circulation disorders”; “improved circulation within the feet and hands”; “improved muscle tone and strengthening”; “help maintain and increase the range of motion”; “prevent or slow disuse muscle atrophy”; “re-educate muscles which have been affected by poor circulation”; “improve muscle strength”; “reduce wastage”; “increase energy levels”; “reduce stress”; “The Circulation Booster is a T.E.N.S. medical device”. The advertisement made references to Dr David Green, Dr Paul Sumners, Consultant Vascular Surgeon Mr Mark Whitely, Dr Chris Steel and to Josh Penny MD. The advertisement included testimonial materials presented under the headings “Customer reviews” and “Video testimonials”. The advertisement also made references to: “poor circulation”, “Restless Leg Syndrome”, “irregular heart beats”, “muscle wastage”, “muscle atrophy”, “malignancy” and “epilepsy”.

3.      The advertisement also described a portable version of the device, the “Circulation Booster Mobile”.

4.      The advertisement described the “Ultralieve Pro” device and made claims such as: “Helps to promote healing”; “Helps to ease pain and reduce inflammation”; “Joint pain”; “Back/Neck pain”; “Foot and Ankle pain”; “help remedy injury and pain”; “may help a range of conditions such as muscle spasms, aches/pains, back ache, ligament strains, sports injuries and post aid recovery”; “promote healing”; “Aid blood flow to help reduce local swelling and inflammation”; “Enhance absorption of analgesics and anti-inflammatory agents”; “Reduce trigger point pain, the causes of headaches, backache and all other types of muscular soft tissue overuse syndrome”. The advertisement included references to “health professionals” and to a Physiotherapist. The advertisement included testimonial material and made references to: “trigger point pain”, “muscular soft tissue overuse syndrome”, “ligament strains” and “sports injuries”.

5.      An excerpt of the advertisement can be viewed in the relevant Appendix to this determination.


The product(s)


6.      The advertisement promoted the products Circulation Booster v3, Circulation Booster Mobile and Ultralieve Pro.


The advertiser(s)


7.      The advertiser was High Tech Health Pty Ltd.


The publisher(s)


8.      The publisher of the advertisement was High Tech Health Pty Ltd.



 


The complaint


9.      The complainant was anonymous.

10. The complainant expressed the following concerns about the advertisement for Circulation Booster:

a)      That it “includes endorsement by medical practitioners without ... meeting the requirements of 4(6)(b) of the advertising code”;

b)      That a user manual for the product contained a reference to diabetes in contravention of section 42DL(1)(c) of the Act (the Panel noted that the user manual did not form part of the website advertisement and hence did not consider this aspect of the complaint);

c)      That it made a number of claims “incapable of substantiation” (the Panel considered this aspect of the complaint to be an allegation of breach of section 4(1)(b) of the Code) ;

d)     That it contained an offer of a sample in breach of section 4(8) of the advertising code;

e)      That it contained testimonials that were not typical and that in some cases breached section 4(2)(g). The complainant cited two testimonials in particular which referred to being able to “walk again after 2 years of being unable to get about without support” and that “after just one 30 minute use ... all pain has now vanished”.

11. The complainant expressed the following concerns about the advertisement for Ultralieve Pro:

a)      That it advertised “a product not included in the ARTG, being a transducer gel ... in breach of 41DL(1)(g)” (the Panel took this to be an alleged breach of 42DL(1)(g));

b)      That it referred to “endorsements by medical practitioners” in breach of section 4(6)(b)(iv) of the Code.

12. The complainant also expressed concerns about an advertisement for Detox Box said to appear on the website.


Additional matters raised by the Panel


13. Under sub-regulation 42ZCAH(1), the Panel is empowered to raise matters other than those specified in the complaint, where the Panel is satisfied that the advertisement to which the complaint relates contains matter that is not mentioned in the complaint, which may contravene the Act, Regulations, or the Code in other ways. The Panel was so satisfied and raised the following additional matters in relation to the advertisement for Circulation Booster:

 

a)      Possible breaches of sections 4(1)(b), 4(2)(a), 4(2)(c) and 4(2)(d) of the Code in relation to the claims of product benefits made in the advertisement.

b)       Possible breaches of section 4(6)(b) of the Code because of references to Dr David Green, Dr Paul Sumners, Consultant Vascular Surgeon Mr Mark Whitely, Dr Chris Steel and to Josh Penny MD made in the advertisement.

c)      Possible breaches of section 4(7) of the Code because of the testimonial materials presented under the headings “Customer reviews” and “Video testimonials”.

d)     Possible breaches of section 5 of the Code because of references to; “poor circulation”, “Restless Leg Syndrome”, “irregular heart beats”, “muscle wastage”, “muscle atrophy”, “malignancy” and “epilepsy” in the advertisement.

14. The Panel also raised the following additional matters in relation to the advertisement for Circulation Booster Mobile:

 

a)      Possible breaches of sections 4(1)(b), 4(2)(a), 4(2)(c) and 4(2)(d) of the Code in relation to the claims of product benefits made in the advertisement.

15. The Panel also raised the following additional matters in relation to the advertisement for Ultralieve Pro:

 

a)      Possible breaches of sections 4(1)(b), 4(2)(a), 4(2)(c) and 4(2)(d) of the Code in relation to the claims of product benefits made in the advertisement.

b)      Possible breaches of section 4(6)(b) of the Code because of references to “health professionals” and to Sarah Webb’s Physiotherapist made in the advertisement.

c)      Possible breaches of section 4(7) of the Code because of the testimonial materials of Sarah Webb.

a)      Possible breaches of section 5 of the Code because of references to; “trigger point pain”, “muscular soft tissue overuse syndrome”, “ligament strains” and “sports injuries” in the advertisement.

 


The advertiser’s response to the complaint


Circulation Booster

16. In relation to the alleged breaches of section 4(6)(b) of the Code, the advertiser stated that they would remove the references to Doctors Green, Sumners, Whitely and Steel and their endorsements. In relation to Joshua Penny MD, the advertiser stated that “MD” was an abbreviation for Managing Director and that this abbreviation would be amended.

17. In relation to the reference to the alleged breach of section 42DL(1)(c) of the Act, the advertiser stated that they would remove the link which contained the reference to diabetes.

18. In relation to the alleged breach of section 4(8) of the Code, the advertiser stated that they did not offer samples of the device to consumers; rather they supplied pharmacies with working demonstration units which consumers were able to trial in-store.

19. In relation to the alleged breach of section 4(2)(g) of the Code, the advertiser stated that they would remove the two testimonials cited by the complainant. 

20. In relation to the alleged breaches of sections 4(1)(b), 4(2)(a), 4(2)(c) and 4(2)(d) of the Code, the advertiser stated that they had reviewed the claims and concluded that “some marketing claims on [the] website exceeded the product’s intended purpose and associated clinical data”. The advertiser stated that they would remove all such claims. The advertiser provided some evidence material to support the intended purpose of the product and stated that the intended purpose of the product was to:

a)       Support and improve blood circulation, due to prolonged inactivity and/or a sedentary lifestyle, in healthy individuals.

b)      Reduce swelling volume and discomfort in the lower leg, foot and ankle due to prolonged inactivity and/or a sedentary lifestyle, in healthy individuals.

c)      Alleviate temporary aches and pains in the lower legs caused by poor circulation.

d)     Relieve tired aching feet and legs caused by prolonged periods of standing.

21.  In relation to the alleged breach section 4(7) of the Code, the advertiser stated that all testimonial materials were genuine and typical and provided documentation to support the testimonials. However, the advertiser conceded that some of the material “may be regarded as an over dramatisation of a typical user’s experience” or that it “may extend beyond the product’s intended purpose”. The advertiser stated that they would remove such testimonial material.

22. In relation to the alleged breaches of section 5 of the Code, the advertiser stated that “poor circulation” was consistent with the intended purpose and that “malignancy” and “epilepsy” were part of the product cautions/contraindication and that none of these three claims would be removed from the advertisement. The advertiser stated that they would remove all the other claims that the Panel had raised as potential breaches of section 5.

Circulation Booster Mobile

23.   In relation to the alleged breaches of sections 4(1)(b), 4(2)(a), 4(2)(c) and 4(2)(d) of the Code, the advertiser stated that they had ceased the sale and distribution of the product and that all references to the product would be removed from the website.

Ultralieve Pro

24. In relation to the alleged breach of 42DL(1)(g), the advertiser agreed that the Ultralieve Ultrasound Gel was not included on the ARTG and that it ought to have been.

25. In relation to the alleged breaches of sections 4(1)(b), 4(2)(a), 4(2)(c) and 4(2)(d) of the Code, the advertiser stated that certain of the claims raised by the Panel were consistent with the intended purpose, but that claims which were inconsistent with the intended purpose would be removed. The advertiser identified which claims were in which category, but provided no evidence to support the former.

26. In relation to the alleged breach of section 4(6)(b) of the Code, the advertiser stated that the references to healthcare professionals would be removed.

27. In relation to the alleged breach of section 4(7) of the Code, the advertiser stated that the testimonial would be removed.

28. In relation to the alleged breaches of section 5 of the Code, the advertiser stated that the claim relating to “sport injuries” was consistent with the intended purpose and that this claim would not be removed from the advertisement. The advertiser stated that they would remove all the other claims that the Panel had raised as potential breaches of section 5


Findings of the Panel


Circulation Booster

29. Section 4(1)(b) of the Code requires that advertisements for therapeutic goods “contain correct and balanced statements only and claims which the sponsor has already verified.” Section 4(2)(a) of the Code prohibits representations that are “likely to arouse unwarranted and unrealistic expectations of product effectiveness”. Section 4(2)(c) of the Code prohibits representations that “mislead directly or by implication or through emphasis, comparisons, contrasts or omissions”.

30. The Panel considered the intended purpose of the product (reproduced in paragraph 20 above) and noted the advertiser’s admission that some claims exceeded the intended purpose. The Panel did not form a view as to whether the evidence material provided by the advertiser substantiated the intended purpose, because the references to the following (as admitted by the advertiser) were inconsistent with the intended purpose;  “muscular recovery”, “back pain joint pain, muscular injuries/pain”, “restless leg syndrome, stress and tension”, “arthritis”, “circulation disorders”, “improved muscle tone and strengthening”, “help maintain and increase the range of motion”, “prevent or slow disuse muscle atrophy”, “re-educate muscles which have been affected by poor circulation”, “improve muscle strength”, “reduce wastage”, “increase energy levels”, “reduce stress”.

31. The Panel therefore found that the advertisement was in breach of sections 4(1)(b), 4(2)(a) and 4(2)(c) of the Code, because of the many claims made that were inconsistent with the intended purpose of the product. This aspect of the complaint was justified.

32. Section 4(2)(d) of the Code prohibits advertisements which “abuse the trust or exploit the lack of knowledge of consumers or contain language which could bring about fear or distress.” For the reasons outlined above in relation to sections 4(1)(b), 4(2)(a) and 4(2)(c), the Panel found the advertisement in breach of section 4(2)(d).

33. Section 4(2)(g) of the Code prohibits representations that therapeutic goods are “infallible, unfailing, magical, miraculous”, or that they are “a certain, guaranteed or sure cure”. The Panel noted the references in the testimonials to being able to “walk again after 2 years of being unable to get about without support” and that “after just one 30 minute use ... all pain has now vanished”. The Panel considered that these testimonials represented the product as being miraculous and that it would invariably be effective. The Panel therefore found the advertisement to breach section 4(2)(g) and that this aspect of the complaint was justified.

34. Section 4(6)(b) of the Code prohibits representations that therapeutic goods are endorsed by healthcare professionals. The Panel found that the advertisement represented the advertised product to be endorsed by healthcare professionals through the references to named doctors who were said to use the product and to whom positive statements about the product had been attributed. This aspect of the complaint was therefore justified.

35. Section 4(7) of the Code requires that testimonials included in advertisements for therapeutic goods “must be documented, genuine, not misleading and illustrate typical cases only.” The Panel noted the extraordinary nature of the claims made in some of the testimonials as well as the advertiser’s admission that some of the materials may be regarded as an “over dramatisation of a typical user’s experience”. On the basis of the material before it, the Panel did not accept that these testimonials could be considered typical. This aspect of the complaint was therefore justified.

36. Section 4(8) of the Code states that advertisements for therapeutic goods, other than therapeutic devices and sunscreens, must not contain an offer of a sample. The Panel accepted the Advertiser’s explanation as to the mechanism by which free trials of the product were conducted in pharmacies. This aspect of the complaint was therefore not justified.

37. Section 5(2) of the Code prohibits advertisements that “refer, expressly or by implication, to serious forms of diseases, conditions, ailments or defects specified in Part 2 of Appendix 6, unless prior approval is given under the Therapeutic Goods Act 1989.” The diseases and conditions specified in Part 2 of Appendix 6 of the Code include “serious forms of” a wide range of health concerns.

38. The Panel noted that the advertisement included references to the following conditions which were considered to be serious forms of diseases, conditions, ailments or defects in breach of section 5(2);  “Restless Leg Syndrome”, “irregular heart beats”, “muscle wastage”, “muscle atrophy”, “malignancy” and “epilepsy”. This aspect of the complaint was therefore justified.

Circulation Booster Mobile

39. Section 4(1)(b) of the Code requires that advertisements for therapeutic goods “contain correct and balanced statements only and claims which the sponsor has already verified.” Section 4(2)(a) of the Code prohibits representations that are “likely to arouse unwarranted and unrealistic expectations of product effectiveness”. Section 4(2)(c) of the Code prohibits representations that “mislead directly or by implication or through emphasis, comparisons, contrasts or omissions”.

40. The advertisement included claims of product benefits in relation to the Circulation Booster Mobile product for which the advertiser provided no evidence in support. In the absence of any such evidence, the Panel found these sections of the Code to have been breached and this aspect of the complaint to be justified.

41. Section 4(2)(d) of the Code prohibits advertisements which “abuse the trust or exploit the lack of knowledge of consumers or contain language which could bring about fear or distress.” For the reasons outlined above in relation to sections 4(1)(b), 4(2)(a) and 4(2)(c), the Panel found the advertisement in breach of section 4(2)(d).

Ultralieve Pro

42. Section 42DL(1)(g) of the Act prohibits the publication of advertisements for therapeutic goods that are not included in the Register. The Panel noted that the product, Ultralieve Ultrasound Gel, was not included in the Register and that by the advertiser’s admission it ought to have been. As the product was not included in the Register, the advertisement therefore constituted a breach of section 42DL(1)(g) of the Act. The Panel therefore found this aspect of the complaint justified.

43. Section 4(1)(b) of the Code requires that advertisements for therapeutic goods “contain correct and balanced statements only and claims which the sponsor has already verified.” Section 4(2)(a) of the Code prohibits representations that are “likely to arouse unwarranted and unrealistic expectations of product effectiveness”. Section 4(2)(c) of the Code prohibits representations that “mislead directly or by implication or through emphasis, comparisons, contrasts or omissions”.

44. The Panel noted the advertiser’s admission that only some of the claims in the advertisement were consistent with the intended purpose and also noted that the advertiser failed to provide evidence material to support the claims said to be consistent with the intended purpose.

45. The advertiser indicated that the following claims were consistent with the intended purpose: “Helps to promote healing”; “Helps to ease pain and reduce inflammation”; “Joint pain”; “Back/Neck pain”; “Foot and Ankle pain”; “help remedy injury and pain”; “promote healing”.

46. The advertiser indicated that the following claims would be removed: “may help a range of conditions such as muscle spasms, aches/pains, back ache, ligament strains, sports injuries and post aid recovery”; “Aid blood flow to help reduce local swelling and inflammation”; “Enhance absorption of analgesics and anti-inflammatory agents”; “Reduce trigger point pain, the causes of headaches, backache and all other types of muscular soft tissue overuse syndrome”.

47. The Panel therefore found that the advertisement was in breach of sections 4(1)(b), 4(2)(a) and 4(2)(c) of the Code, because the claims made were either inconsistent with the intended purpose of the product or they were unsupported by evidence. This aspect of the complaint was justified.

48. Section 4(2)(d) of the Code prohibits advertisements which “abuse the trust or exploit the lack of knowledge of consumers or contain language which could bring about fear or distress.” For the reasons outlined above in relation to sections 4(1)(b), 4(2)(a) and 4(2)(c), the Panel found the advertisement in breach of section 4(2)(d).

49. Section 4(6)(b) of the Code prohibits representations that therapeutic goods are endorsed by healthcare professionals. The Panel found that the advertisement represented the advertised product to be endorsed by healthcare professionals in general and that the product was endorsed by a named sportsperson’s physiotherapist. This aspect of the complaint was therefore justified.

50. Section 4(7) of the Code requires that testimonials included in advertisements for therapeutic goods “must be documented, genuine, not misleading and illustrate typical cases only.” The Panel noted that the advertiser provided no documentation to support the testimonial of Sarah Webb. In the absence of any such documentation, the Panel found this aspect of the complaint to be justified.

51. Section 5(2) of the Code prohibits advertisements that “refer, expressly or by implication, to serious forms of diseases, conditions, ailments or defects specified in Part 2 of Appendix 6, unless prior approval is given under the Therapeutic Goods Act 1989.” The diseases and conditions specified in Part 2 of Appendix 6 of the Code include “serious forms of” a wide range of health concerns.

52. The Panel noted that the advertisement included references to the following conditions which were considered to be serious forms of diseases, conditions, ailments or defects in breach of section 5(2): “trigger point pain”, “muscular soft tissue overuse syndrome” and “ligament strains”. This aspect of the complaint was therefore justified.

Detox Box

53. While the complaint made reference to a product called Detox Box, no such product was described in the advertising materials provided to the Panel.

54. Accordingly, the Panel gave no consideration to this aspect of the complaint.


Sanctions


55. The Panel requests High Tech Health Pty Ltd, in accordance with subregulation 42ZCAI(1) of the Therapeutic Goods Regulations 1990:

a)      to withdraw the advertisements from further publication;

b)      to withdraw any representations that;

i)        the Circulation Booster and the Circulation Booster Mobile products have any benefits in relation to; “muscular recovery”, “back pain joint pain, muscular injuries/pain”, “restless leg syndrome, stress and tension”, “arthritis”, “circulation disorders”, “improved muscle tone and strengthening”, or that they can “help maintain and increase the range of motion”, “prevent or slow disuse muscle atrophy”, “re-educate muscles which have been affected by poor circulation”, “improve muscle strength”, “reduce wastage”, “increase energy levels”, “reduce stress” or that they have any other benefits inconsistent with the intended purpose of the products.

ii)      the Circulation Booster and the Circulation Booster Mobile products are infallible, unfailing, magical or miraculous or that they are endorsed by healthcare professionals.

iii)    the Ultralieve Pro product “Helps to promote healing”, “Helps to ease pain and reduce inflammation” has any benefits in relation to “Joint pain”, “Back/Neck pain”, “Foot and Ankle pain”, or that it can “help remedy injury and pain” or “promote healing” or that it has any other benefits inconsistent with the intended purpose of the product.

iv)    the Ultralieve Pro product is endorsed by healthcare professionals;

c)      not to use the representations in (b) above in any other advertisement*;

d)     where the representations have been provided to other parties such as retailers or website publishers, and where there is a reasonable likelihood that the representations have been published or are intended to be published by such parties, to advise those parties that the representation(s) should be withdrawn;

e)      to arrange for publication on the website www.circulationbooster.com.au of a retraction in the form of, and in accordance with, the conditions set out in the attachment to this determination; and,

f)       within 14 days of being notified of this request, to provide evidence to the Panel of its compliance, including a response in writing that they will comply with the Panel’s sanctions, and where appropriate, supporting material such as copies of instructions to advertising agents or publishers, or correspondence with retailers and other third party advertisers.

56. The advertiser’s attention is drawn to the provisions of sub-regulations 42ZCAI(3) and (4) which permit the Panel to make recommendations to the Secretary in the event of non-compliance with this request, including a recommendation that the inclusion of the goods on the Register be cancelled.

 

 

Dated 10 January 2011

For the Panel

 

 

Steven Scarff

Acting Chairman




Appendix A:    Definitions and footnotes


In this determination, unless otherwise specified:

a)      “the Act” means the Therapeutic Goods Act 1989;

b)      “the Regulations” means the Therapeutic Goods Regulations 1990;

c)      “the Code” means the Therapeutic Goods Advertising Code;

d)     “the Register” means the Australian Register of Therapeutic Goods;

e)      “any other advertisement” appearing in sub-regulation 42ZCA1(1)(d) is not confined to advertisements in specified or broadcast media (in relation to which complaints may be made to the Panel under Regulation 42ZCAB). It should be noted that HTML metatags and other information which can be retrieved by internet search engines, whether or not it is ordinarily viewed directly by consumers, constitutes advertisement material.

 

 

 

 

*Under regulation 42ZCAI of the Regulations, the Panel may request that a representation not be used in any other advertisement unless the advertiser satisfies the Panel that the use of the representation would not result in a contravention of the Therapeutic Goods Act 1989, the Therapeutic Goods Regulations 1990 or the Therapeutic Goods Advertising Code. Under the Panel’s procedures, the Panel will not ordinarily give additional consideration to such a matter unless significant new material that was not available at the time of the Panel’s determination has become available, or until at least 12 months have passed since the Panel’s request was made.




Appendix B:     Retraction


 

An advertisement is to appear on the home page of the website www.circulationbooster.com.au  at the earliest booking opportunity.

 

A copy of the retraction advertisement, and the page on which it will be published, is to be provided to the Complaints Resolution Panel for approval before publication.

 








 

RETRACTION

 

Advertisements for the Circulation Booster, Circulation Booster Mobile and Ultralieve products, which we published on this website, should not have been published.

 

In the advertisements we unlawfully made claims that the products had benefits that were inconsistent with their intended purpose and that the products were endorsed by healthcare professionals. We also unlawfully made claims in relation therapeutic goods not included on the ARTG and unlawfully made reference to serious forms of diseases, conditions, ailments and defects without approval to do so.

 

A complaint about the advertisement was recently upheld by the Complaints Resolution Panel. We provided no evidence to support these claims, and the Panel found that the claims were unlawful, misleading, and unverified and breached the Therapeutic Goods Advertising Code.

 

The Panel therefore requested that High Tech Health Pty Ltd publish this retraction.

 

The full text of the Panel’s determination can be found at: www.tgacrp.com.au/complaints

 


 

No other copy should be included in the advertisement.

 


























Location:


website front page, so that it can be viewed without scrolling the page


Size:


No less than 500 pixels wide and 200 pixels high


Heading:

 


Arial or Helvetica

Red on a white background

The letters should be no less than 20 pixels in height, and should be no smaller than any other body text on the page

Bold


Text:


Arial or Helvetica

Red on a white background

The letters should be no less than 14 pixels in height, and should be no smaller than any other body text on the page

Bold


Text Box:


Red on a white background


Duration:

Advertisement Copy: Download

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