I awoke the other day to see that Dr. Robert “inventor of mRNA vaccines” Malone and Trial Site News were targeting The Wellness Company, the supplement company in which COVID-19 antivaxxer and quack Dr. Peter McCullough has become a major player, with an “investigative report” entitled Monetizing the COVID-19 Backlash—Big Vision, Palpable Demand, But Can They Pull it Off? Given that there are few things I enjoy better than a quack fight, I knew that this would have to be the topic of my first post for this year, especially when I’ve written about The Wellness Company before in the context of Dr. McCullough’s selling nattokinase supplements(with bromelain) which according to him break down SARS-CoV-2 spike protein, as a fake cure for both COVID-19 and COVID-19 vaccine “injury” and also because Dr. Robert Malone, siding with Trial Site News, got permission to repost the entire story on his Substack, characterizing it as Trial Site News‘ “fair and balanced ‘deep dive’ investigation into ‘The Wellness Company.'”

Even as I noted that 2023 was the year that increasingly a fundamentalist version of evidence-based medicine (EBM) rooted in methodolatry was being weaponized against public health, in particular vaccines and masks, as well as other areas, I have to wonder as 2024 has dawned whether this year will see the culmination of another trend that I’ve been following, namely how COVID-19 contrarian doctors who became—or outed themselves as—antivax in response to the pandemic and then moved to become just generally antivax are increasingly becoming just plain run-of-the-mill grifting quacks. Even more amusing is that this story reveals how increasingly the quacks have been taking sides, in this case with Dr. Robert Malone increasingly coming under fire from his fellow COVID-19 antivaxxers like Dr. Peter McCullough and Dr. Paul Alexander for…reasons…and then firing back., something that I had been meaning to write about ever since I noticed this fight when Dr. Alexander attacked Dr. Malone for having “invented” the mRNA vaccine on his Substack in March and April. Again, I do love internecine war between cranks, particularly when it involves someone like Malone being attacked for is own false claim of credit for an invention, but more importantly when it can be used to make a point relevant to SBM.

Clearly this fight has been brewing for a while, and it’s at the point where even an outlet that promotes as much antivax disinformation and quackery, as well as COVID-19 conspiracy theories, as Trial Site News actually nails some important facts about The Wellness Company, although, as one might expect, more mainstream news sources like The Daily Beast got there first a month ago with a story MAGA Influencers Are Sold on This Grifty Wellness Company, amusingly also calling it “Goop for the GOP,” which is a hilariously spot-on characterization.

But first, a quack fight!

Before I discuss The Wellness Company in more depth, I can’t help but briefly touch on the context in which the Trial Site News article ran, namely that there’s been a big quack fight going on for months between Dr. Robert Malone and much of the rest of the COVID-19 crankosphere, in particular Dr. Paul Alexander, Dr. Peter McCullough, Sage Hana, and the pseudonymous conspiracy propagandist The Vigilant Fox, among others. As much as it plays “fair and balanced,” Trial Site News definitely takes a side, too, namely Dr. Malone’s, albeit with enough plausible deniability that it probably didn’t obviously burn any bridges in the case that The Wellness Company emerges victorious. How this crank fight started, I honestly no longer remember. It appears to have come about because of Dr. Malone’s continued insistence that he was The One True Inventor of mRNA Vaccines, leading the antivax crankosphere to take him at his word and start to attack him for his unstated but implicitly claimed role in having supposedly unleashed hell upon the world in the form of mRNA based COVID-19 vaccines, leading him to fire back from time to time, as in just a couple of weeks ago:

I am constantly amazed by the self-styled social media “independent journalists” who obsessively attack me for the sin of being a mass murderer due to the role which they claim I played in creating the modified-mRNA SARS-CoV-2 vaccines.  George Webb, Jane Ruby, Paul Alexander, “Sage Hana”, the list goes on and on. But they never mention those that actually did develop the specific products. Rather strange. 

Which clearly demonstrates that their years of obsessive hate are not actually about those who developed the products, but rather for some reason it is specifically targeted at me. All appear to be getting compensated in some way for actively promoting hate, although in most cases it is not clear who is paying them to do this. In at least one case, the source of compensation for promoting hate is well documented.

In the case of Paul Alexander, in my opinion it is clear that his support for these activities comes from Foster Colson’s [sic] “The Wellness Company” TWC ads are often displayed on Alexander’s attack posts. Alexander never promoted anti-Malone hate until hired by Wellness, and his accusations have followed the hate narratives promoted by Wellness CEO Foster Colson [sic] in his 2022 Christmas letter.

I read that Christmas letter and was a bit confused, as I didn’t see appear to be any mention of Dr. Malone in it and no actual “hate” other than typical antivax rhetoric like “unnecessary and often dangerous vaccine.” Still, there is no doubt that much of Dr. Alexander’s Substack is now devoted to saying a lot of rather nasty things about Dr. Malone. There have also been lawsuits; for example, Dr. Malone sued quack psychiatrist Dr. Peter Breggin and his wife for libel to the tune of $25 million, along with Dr. Jane Ruby and Stew Peters’ Red Voice Media, for, in essence, having taken him at his word that he had invented mRNA vaccines and then using their belief that COVID-19 vaccines have killed millions in order to call him a “mass murderer” and accusing him of “fraud, disinformation, dishonesty, deception, lying to the American public, lack of integrity, immorality and ethical improprieties.” For example, Stew Peters said on his show, ““Dr. Malone: All of the time that you’re spending on these podcasts and TV shows, hours with Joe Rogan, even here on the Stew Peters show, are you spending any time in the lab inventing the reversal to the carnage that you helped to invent that is now destroying humanity and killing all kinds of unborn babies and such?”

Again, the hilarity of quacks taking Dr. Malone at his word and then acting on that belief, plus their antivax beliefs, is too much for words. So is Dr. Malone lashing out by attacking not just the Breggins and Drs. Ruby and Alexander, but also other antivax cranks like Drs. Michael Yeadon and Peter McCullough, a situation about which The Vigilant News—the significance of that name will become apparent soon—wrote an article entitled Dr. Malone Versus The World: Why Is He At War With Everyone? in which the list of Dr. Malone’s enemies is long indeed:

The list below, derived from Dr. Malone’s past X and Substack posts, details these entities:
  • Dr. Peter Breggin and Ginger Breggin
  • Dr. Mike Yeadon
  • Sasha Latypova
  • Karen Kingston
  • Matthew [sic] Crawford
  • Dr. Ben Marble
  • Dr. Judy Mikovitz
  • George Webb
  • Sage Hana on Substack
  • America Out Loud
  • Dr. Jane Ruby
  • Red Voice Media
  • Stew Peters
  • Catherine Austin Fitts (The Solari Report)
  • J. J. Couey
  • Mary Holland (President of Children’s Health Defense)
  • The Wellness Company and its founder Foster Coulson
  • Dr. Paul Alexander
  • The Washington Post
  • Alex Berenson
  • Dr. Peter McCullough
  • And more. “The list goes on and on,” Dr. Malone has stated.

Many of these names will be quite familiar to SBM readers, and if you actually go and read the Substack post from right before Christmas linked to in the last bullet point you will see that Dr. Malone comes off as quite besieged, paranoid, even. He also apparently held out hope that the FDA would shut down The Wellness Company, even writing, ““These [supplements] are mislabeled as therapeutics. Peter [McCullough] know[s] this but will not act to object. Eventually, they will get called out by the FDA. Surprising, this has not happened yet.” In fairness, Dr. Malone also accused Dr. Alexander of acting as Dr. McCullough’s “surrogate” to “obsessively” attack him “hundreds of times,” which, as much as I hate to admit anything reasonable about Dr. Malone, is not an entirely unreasonable thing to wonder given just how many posts there are on Dr. Alexander’s Substack viciously attacking him.

(Everything old is new again, and to quacks This Is The Way. It has always been The Way.)

To understand the Trial Site News article that I will use to discuss the quackery that is The Wellness Company, you do need to understand the context, namely this huge crank fight. One group of cranks—definitely the much larger and more influential group—is taking the side of The Wellness Company and those allied with it, like Drs. McCullough and Alexander, and Dr. Malone and his much smaller band of allies. That includes Trial Site News, which is a competitor to The Vigilant News Network for conspiracy and antivax readers.

Malone vs. Everybody
Malone vs. Everybody

The Wellness Company: More than just another quack supplement company?

Trial Site News starts its “exposé” by twisting the knife a bit with a quote from Dr. McCullough that destroyed yet another one of my many irony meters, leaving it a molten mass of plastic and wires with fitful bursts of electricity slowly dying:

We refuse to profit from your sickness. Join the fight for medical freedom by supporting TWC — a company focused on your Wellness with incredible doctors, treatments, and products.” A quote from Dr. Peter A. McCullough of The Wellness Company, a startup seeking to build a parallel health system. But along the way, will the company start embracing attributes mastered by the existing healthcare corporate empire?

Founded in June 2022, the Wellness Company is a new company that offers supplements that purport to reverse damage from mRNA vaccines, along with COVID-19 treatments offered via telemedicine subscriptions. Founded by Foster Coulson, the driving ethos was to build a company to support a patient-centric, parallel healthcare company.  Driving that vision was what Coulson saw as a system during the COVID-19 pandemic demonizing front line physicians and available, safe medicines that could have saved in his view millions of lives.  A lead player is the high-profile Dr. Peter McCullough, quoted above. But of course, this firm focuses on profits if it is to grow, invest and truly offer an alternative system, friendly to patients. While the Wellness Company is a privately held, independent venture,  a review of Coulson’s investments reveals what looks to be a larger-scale entity designed to give mainstream healthcare systems competition.

So the planned grift appears to be much bigger than yet another quack supplement company fronted by Dr. McCullough, like The Wellness Company, selling ineffective COVID-19 “cures” like nattokinase. I note that, oddly enough, I hadn’t recalled ever having heard of Foster Coulson before, but I learned from both The Daily Beast and Trial Site News articles that he’s the scion of a Canadian logging and aviation company, with the Coulson family company, Coulson Aviation positioning itself as a leader in aerial firefighting as part of Coulson Aircane Ltd, which is all part of the privately held Coulson Group. While The Daily Beast‘s story is more about how the “grifty” supplement company is tied into a whole right wing antivaccine anti-public health infrastructure, oddly enough Trial Site News goes into more detail about its structure, founding, and dealings:

The young Mr. Coulson certainly benefited from that valuable experience with the family venture to launch TWC, which is also part of a complex group of companies, all somehow seemingly related to Integro Capital LLC, (IC LLC) which Coulson founded back in October 2021, (during the apex of the pandemic) as a vehicle to invest and profit, and maybe even change the U.S. healthcare system.

In terms of overall corporate structure, IC LLC has been formed as a holding company designed to monetize the dynamics arising out of the COVID-19 pandemic, with one of the investor’s companies  (TWC) being focused on building a parallel health system.

Because of course. And where did Mr. Coulson get his start selling quackery? It appears to go back to one of the earliest quacks of the pandemic, the late Dr. Vladimir Zelenko, who by the end of March 2020 had already made his name as a COVID-19 quack promoting hydroxychloroquine, the antibiotic azithromycin, zinc, and a number of other ineffective repurposed drugs and supplements, as a cure for COVID-19, with attendant appearances on Fox News and other right-wing media. From Trial Site News:

It was Zelenko’s popularizing a three-drug combination of hydroxychloroquine, zinc and azithromycin as an intervention for mild-to-moderate COVID-19 (Zelenko protocol- derived from the prior work of Dr. Dieter Raoult, which was co-marketed with Coulson as “Z-stack” supplements) that inspired Coulson to think of bigger business opportunities. TrialSite has been told through the network that Coulson did quite well with the Z-stack during the pandemic.

Of course, any mainstream interpretation insists on the conspiracy theorist tag for Dr. Zelenko, but TrialSite chronicled many well-meaning, objective and competent front-line physicians whose character was attacked during the pandemic merely for standing up and offering other ways to help deal with the crisis.  And our network assures us Coulson’s moral outrage was high watching the treatment of both doctors and patients during the pandemic.

Passing in 2022 due to cancer, Dr. Zelenko’s mission and their commercial success with the “Z-stack” product inspired Coulson’s bigger vision for a series of corporations that would take on various aspects of offering a parallel health service. It was a “de-prescribing from Big Pharma once and for all,” as conveyed by Kiera Butler in the Mother Jones piece.

(Here’s the Mother Jones piece referred to above, by the way.)

I also like how Trial Site News basically states what we here at SBM have been saying all along, all while linking to Dr. Malone:

And make no mistake, supplements are big business. Not pharma level, but big. According to analysts such as Precedence Research, the U.S. dietary supplement market was valued at $50.91 billion in 2022 and will grow at a healthy rate (CAGR) of 57% from 2023 to 2030, unless big pharmaceutical companies can tap into and own some of that growth with more regulation, a market strategy another influential COVID-19 response critic recently highlighted.

In the United States, this supplement industry growth rate is largely powered by the Dietary Supplement Health and Education Act of 1994  (“DSHEA), which carved out a regulatory exception for dietary supplement such as vitamins and minerals. Consequent to this bill, the health and wellness industry supplement sector products are not subjected to the same regulatory requirements as pharmaceuticals and other medical products, including conducting expensive time-consuming clinical trials or obtaining regulatory approval. However, supplements and nutraceuticals are forbidden from making efficacy claims unless they are supported by substantial clinical data.  Dr. Robert Malone writes, “Needless to say, the pharmaceutical industry has been working to amend the DSHEA act to make it more difficult for such products to make it to the market.”

Of course, we’ve long bemoaned the DSHEA of 1994 as a law that has for nearly 30 years made it easy for quacks to sell unproven supplements. What amused me about this passage is simply how it demonstrates much of what we’ve been saying all along: Even though the supplement industry is not (yet) big pharma level in terms of profits, it is big, very big. It has long been protected by powerful legislators, including an entire caucus. (Yes, there is a Congressional Dietary Supplement Caucus.) Thus far, nearly every attempt to tighten up the requirements for supplement regulation has failed, with efforts to further weaken even the weak DSHEA of 1994 continuing apace. Unsurprisingly, Trial Site News and Dr. Malone are just echoing every quack conspiracy theory about any effort to strengthen the DSHEA as being big pharma wanting to take over the supplement industry. While there is a germ of truth to that claim, it is only a germ. In reality, such efforts are primarily driven by SBM advocates alarmed at how easily the DSHEA enables selling quackery.

Quackery like The Wellness Company:

Enter Coulson’s International Health Brands (IHB), created along with ex-Navy Seal with supposed defense ties, Dave Lopez. IC LLC, IHB, and TWC (at least during the startup phase) appear to all share the same address in Boca Raton, Florida. These related firms are each designed to support or monetize (depending on one’s perspective), particular areas of health.  But we emphasize that according to CEO Peter Gillooly, any of Coulson’s investments are completely separated, firewalled and not influencing each other.

Sure they are, and sure they don’t. (Yes, that’s sarcasm. It’s not as though we at SBM haven’t been down this road many times before.) In this case, though, IHB includes a number of companies and brands, including Elite, Zelenko Labs (yes, that Zelenko), The Wellness Company, Zinc Research International, and Rebellion, all of which sell supplements, just with a different focus.


Coulson’s Integro Capital, or Coulson operating under a different investor umbrella, also has some level of investment in the other ventures. The following is a list of Integro and/or Coulson direct investments.

That list includes IHB, The Vigilant Network, QU Biologics, Nanobiosym, Unjected. It’s a strange combination of companies, particularly Nanobiosym, which includes Moderna co-Founder Dr. Robert Langer as a key advisor. However, other than that, it all hangs together, with Unjected monetizing antivaccine misinformation by running a dating site for the “unvaccinated” (I kid you not), IHB selling COVID-19 quackery, and The Vigilant Network being a competing disinformation network to Trial Site News that I originally encountered in the form of The Vigilant Fox and The Vigilant News., which could partially explain how Trial Site News actually published a story with grains of truth in it, like this:

In evaluating TWC therapeutic claims or marketing messaging, a key question is whether Nattokinase-based supplements measurably improve clinical outcomes in patients that have some lingering injury associated with an mRNA vaccine or long COVID for that matter?

Are there credible clinical data supporting such a claim? TrialSite can only review the scientific literature, relevant and credible reports and tap into its network.

TrialSite journalists have reviewed multiple claims linked to TWC.  From a strictly medical evidence perspective, there are few, if any, data demonstrating clinical efficacy. However, that’s doesn’t mean that the substance cannot help. It just means that it cannot be marketed to do so.  Rather the substance must be marketed for general health purposes.

Physicians such as Dr. McCullough treat hundreds, if not thousands of people, and based on consenting patients, they should be rigorously tracking (at least in observational studies) clinical findings with this product, publishing the results where other peers can review, learn, critique, and potentially accept.

I laughed out loud when I read the last part, namely how The Wellness Company should “rigorously tracking” their “clinical findings with this product,” but I did have to admit that Trial Site News wasn’t wrong about their being no good evidence that nattokinase does anything for COVID-19. I myself went further and pointed out how the literature cited by quacks like Dr. McCullough actually doesn’t support any of the claims made for nattokinase (or bromelain, included in its Spike Support Formula for COVID-19 vaccine “injury” and long COVID).

The Wellness Company Spike Support Formula

Think of this article by Trial Site News as being similar to what Mike Adams did when he bought a secondhand mass spectrometer and started posting about how the supplements sold by companies competing with his were loaded with lead and other heavy metals. It’s an article that supports the general narrative that brave maverick doctors like Dr. McCullough (and Dr. Malone) are facing a “captured” healthcare system that won’t recognize their genius and how they have supposedly discovered highly effective treatments for COVID-19, while targeting competitors like The Wellness Company (fronted by Dr. McCullough) and The Vigilant News, all while giving the appearance of some “balance” by saying some nominally good things about the targets. Even while stating that there is no evidence that The Wellness Company’s Spike Support Protocol does anything for COVID-19, long COVID, or COVID-19 vaccine “injury,” Trial Site News nonetheless concedes:

Up until recently, the Nattokinase-based supplement which is claimed by TWC to target spike protein has been heavily promoted online in various conservative and libertarian leaning channels, again, mostly centered around its chief scientific proponent Dr. Peter McCullough, a contributor to TrialSite, and an internationally renowned figure at this point, especially for those that had real problems with the top-down, overbearing statist and globalist approach to COVID-19 response.

McCullough, a highly published cardiologist-epidemiologist, resisted the approved narratives which emerged during COVID-19, establishing protocols of repurposed drugs to help patients on the front lines during the onset of the pandemic. McCullough was an early adopter in promulgating alternative treatment regimens in response to mild-to moderate COVID-19—the McCullough Protocol.

While becoming an activist for patients and physician autonomy, the former academic cardiologist paid a heavy price economically, with terminations and lawsuits—one big one in which he was victorious.

Other groups staking a claim to early adoption and promotion of front-line protocols would include the COVID-19 Front Line Critical Care Alliance (FLCCC), Zelenko himself, Dr. Sabine Hazan (who registered one of the first ivermectin-based studies with the U.S. government) and others.

And, later:

TrialSite believes Coulson’s entry into alternative health supplements was authentically driven by a certain level of disgust in how the health system and government responded to the pandemic. Coulson, then joined by colleague Lopez, sought to establish a business model that would help individuals also fed up “de-prescribe from Big Pharma once and for all.”

And also:

Like most others active in this sector, TrialSite had no idea TWC appeared to be part of a startup-to-conglomerate aspiration, one seeking to power and monetize a parallel health economy. For example, while TWC and Elite might be different companies, they both sell supplements, and both have Coulson as likely majority shareholder.

Coulson’s certainly thinking big, and in healthcare and pharmaceuticals this comes with high risk and the need for large amounts of capital. But we have a level of appreciation for Coulson’s big vision.

See what I mean? According to the story, Coulson was sincere (the implication being that the operative word here is “was”); Trial Site News appreciates “his big vision” (although it implies that it’s too big Pharma-like now); and Dr. McCullough was a hero early on in the pandemic, at least before he turned to shilling for a supplement company selling products with no evidence that they work. Of course, from a medical and scientific standpoint, they were all always wrong right from the get-go, and TWC’s medical board is a who’s who of COVID-19 antivax quacks, including in addition to Dr. McCullough, Drs. Drew Pinsky, James Thorp, and Harvey Risch (who pushed hydroxychloroquine in 2020), along with William Makis (of “turbo cancer” fame) on its Canadian board.

Then, after discussing the various “preparedness kits,” such as the Medical Emergency Kit (complete with ivermectin!), that The Wellness Company sells by fear mongering about the next pandemic and claiming that everyone should have these supplements and drugs on hand and contracting with physicians to prescribe prescription pharmaceuticals to customers, just in case, Trial Site News notes:

Now selling supplements direct to consumers falls under the exceptions to FDA regulation, but employing or contracting with prescribing physicians, marketing pharmaceuticals such as ivermectin likely subjects the company to direct FDA oversight if any claims are violative.

According to TrialSite’s O’Connor, when a company’s business model becomes ever more dependent on business involving prescribing FDA regulated medicines for future indications, TWC physicians will be prescribing medicines for an indication that doesn’t yet exist.

With growth comes increased costs and pressure to sell, and this model [anticipatory prescriptions] could evolve into one involving perverse incentives—to promulgate fear of emerging infectious diseases, which would then increase the probability of  consumers opting to pay for a prescription.” TrialSite’ O’Connor asked TWC CEO about company culture, and how they would avoid this sort of capitalist creep, the type that so many in the medical freedom movement are critical of big pharma for doing.

Gillooly became passionate at this point, explaining that they are building the company to empower patients, to offer a new model, one that honors their right to health care, to key medicines lie amoxicillin. That if guided correctly by a licensed prescribing physician following a Hippocratic oath that this culture will prevail as the company grows.

You mean like the way the quack physicians group America’s Frontline Doctor got busted for running a prescription mill selling ivermectin? Seriously, what is being described here is nothing more than a massively larger and better funded version of that sort of prescription mill, no matter how much Mr. Gillooly tries to deny it. That whole schtick about “empowering” patients is nothing more than the same schtick that quacks from time immemorial have used when selling their quackery, whatever it is, be it supplements, naturopathy, or repurposed pharmaceuticals that don’t work for the indication for which the quack prescribes them.

There’s a lot more in the article, including a rather interesting bit about how controlling a right wing propaganda and conspiracy site like The Vigilant News—it’s not that it’s called that in the story, but that’s what it is—poses the problem of a conflict of interest, which is breezily dismissed:

Coulson investing in controlling a political right media site has its benefits and drawbacks.  TrialSite founder Daniel O’Connor told this writer, “Coulson is smart, has the pedigree for business based on his upbringing and likely believes at the core in what he says publicly, but the pressures of costs, investors and the realities of capitalism will undoubtedly enforce the same discipline on this groups of ventures as any others.”

When confronted with this logic, TWC CEO Gillooly explained to O’Connor that they have established strict firewalls, and that while they will buy advertising in the news network it would be violative to unduly influence the content.

 The entrepreneur also says he founded Vigilant News Network “as a free and open network to bring people the latest unmanipulated stories….”  But regardless,  given the need for continual growth, rising costs associated with what in essence will be a regulated company,  the pressures to exploit the firewalls will be significant.  Only company culture of integrity and ethics can minimize such concerns. And of course, that starts at the top and Gillooly did assure TrialSite “we are building a serious big company and we will not compromise on our ethics, integrity or our mission.”

Sure they will, the same way that Mike Adams does with Natural News and Alex Jones does with his various websites and publications.

The Wellness Company: “Goop for the right” is a good description

At the end of its 6,000+ word article, Trial Site News warns:

Trust in the U.S. government, healthcare systems and the medical products industry sunk to what are likely all-time lows during the pandemic. Enter TWC and Foster Coulson’s mission to capitalize on those trends to build what he and Peter Gillooly emphasize will be a new kind of patient-centric company, dedicated to medical freedom.

But the uptick in TWC’s advertisements on conservative-leaning podcasts, Substack authors, and the like is palpable. Products that claim to “clean” the spike protein are not proven, and despite an esteemed Chief Medical Board seemingly validating the integrity and scientific veracity backing the products, they are dietary supplements that cannot be marketed for treating any form of disease, including SARS-CoV-2, the virus behind COVID-19, long COVID or long Vax, also known as COVID-19 vaccine injury.  Of course, a physician at their discretion and patient consent can try different approaches to solve a medical problem. TrialSite stood up for that right of both patient and doctor during the pandemic. But that model doesn’t scale well enterprise wide.

No, it doesn’t. Actually, it doesn’t really hold true at any scale, but a large corporation is likely to make the grift so much more effective and therefore worse. Then, after pivoting to go on about how medicine and pharma are so far behind the times because they don’t recognize the spike protein from COVID-19 vaccines as the health evil that Dr. McCullough and his merry band of quacks consider it to be (you know, in the name of balance and saying that The Wellness Company comes from an honest place rather than a desire to grift), Trial Site News concludes:

And it’s the later dynamics that Coulson and Lopez have seized upon. Yes, a growing number of people demand an alternative health system. But in a market economy Coulson will need to be ready to plow all of his profits, and then some, back into actually demonstrating defensible efficacy before making claims, the true standard of any health-related brand, plus seriously invest in adherence to the compliance and regulatory regimes that currently govern healthcare delivery. Because that’s the world that he must now abide by.

We all know that Mr. Coulson will do no such thing. His goal is profit, and, for all his claims of wanting to “empower” people and free them of the supposed tyrannical shackles of big pharma, all he is really doing is recognizing an opportunity for grift.



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