The Privatest: Another Scheme to Sell You Something

Stephen Barrett, M.D.
March 24, 2016

In 2011, The Trump Network, of Rowley, Massachusetts, claimed that its “customized nutritional regimen” provide a rational way to “give you what your body needs so you can be your best—everyday.” [1] The company, operating since 1997 as Ideal Health International, was renamed The Trump Network in 2009 when Trump partnered with Ideal Health’s founders. In 2012, after Trump’s licensing contract ended, the assets of The Trump Network were sold to Antoine Nohra of Montreal, Canada and became part of Bioceutica’s offerings.

The flagship product tied to the PrivaTest is a “customized” dietary supplement said to be based on the results of a urine hormone test called the PrivaTest. The PrivaTest was developed by J. Alexander Bralley, PhD, founder and chief executive officer of MetaMetrix Clinical Laboratory, a lab that caters to chiropractors and other offbeat health professionals. In December 2010, the quoted prices were $139.95 for the test, $69.95 per month for the vitamins, and $99.95 for a retest that is recommended in six months so the formula can be “readjusted.” [2]

This report is based mainly on documents I collected and observations I made about Ideal Health prior to 2009. I don’t know whether The Trump Network or Bioceutica modified their test process, but even if they did, I believe my conclusions are still valid because no single test can provide a rational basis for dietary supplement recommendations. In 2016, the Washington Post reported that Trump claims that his involvement with Ideal Health merely allowed them to use his name for marketing purposes and that he was not involved in the company’s operations. But the paper noted that “statements by him and other company representatives—as well as a plethora of marketing materials circulating online—often gave the impression of a partnership that was certain to lift thousands of people into prosperity.” [3]

Illegal Health Claims

The 1994 Dietary Supplement Health and Education Act (DSHEA) allows supplement products to bear “statements of support” that: (a) claim a benefit related to classical nutrient deficiency disease; (b) describe how ingredients affect the structure or function of the human body; (c) characterize the documented mechanism by which the ingredients act to maintain structure or function; and (d) describe general well-being from consumption of the ingredients. To be legal under DSHEA, a “nutritional support” statement must not be a “drug” claim. In other words, it should not suggest that the product or ingredient is intended for prevention, cure, mitigation, or treatment of disease.

Under DSHEA, manufacturers who make statements of “nutritional support” must have substantiation that such statements are truthful and not misleading. Ideal Health’s 28-page “Opportunity Presentation” makes claims that I believe are illegal. Page 13, pictured here, states or implies that taking Custom Essentials will improve mental alertness, memory, emotional balance, concentration, tension levels, and vitality; improve the appearance of skin, hair, and nails; and “support” the functioning of the liver, kidneys, heart, lungs, eyes, prostate, and joints.


To substantiate these claims, Ideal Health would have had to prove that Custom Essentials users fare better than nonusers with respect to each claim. This would require evidence that people who already consume adequate amounts of the ingredients would be better off by ingesting more. I doubt that the company had any such data.

Another of Ideal Health’s sales aids was a CD-ROM that included an “exciting 7 to 10 minute video of inspiring testimonials from top marketers” who say or suggest that taking Custom Essentials has relieved symptoms of fibromyalgia; improved irritable bowel; stopped them from having colds; improved digestion; stopped hair loss; stopped acne breakouts; caused nails and hair to grow faster; increased their energy, increased sex drive; improved memory; relieved aches and pains; improved their appearance; reduced stress levels; drastically decreased their allergies; lowered their blood cholesterol levels; improved sleep; and healed fractures more quickly [3]. Most of these problems are not caused by nutrient deficiencies. Moreover, claims that Custom Essentials could prevent, mitigate, treat, or cure any of these diseases would be illegal without FDA approval, which, of course, the product did not have.

Toward the end of 2003, Ideal Health announced that it had teamed up with ITV Direct, which marketed products mainly through cable TV infomercials. For several months, the Ideal Health Web site promoted “Supreme Greens with MSM,” an herbal product with about 35 ingredients. The Web site claimed that (a) modern lifestyle tends to make the body too acidic; (b) stress, environmental toxins, refined foods can leave you “vulnerable to the often-serious health consequences of a ‘too-acid’ body”; and (c) the product contained “vital alkalizing nutrients to help support your body’s proper acid/base balance.” [5] These claims were sheer baloney. Meanwhile, ITV Direct infomercials were making similar assertions plus claims that Supreme Greens was effective against cancer and many other diseases. In April 2004, the FDA ordered ITV Direct to stop making the disease-related and “acid-base balance” claims [6]. In June, the Federal Trade Commission (FTC) charged the company with false advertising and obtained a temporary injunction [7]. Although not implicated in these actions, Ideal Health appeared to have stopped marketing Supreme Greens about the time that the FTC obtained its injunction.

Financial Risk

Ideal Health appeared to have more potential for big losses than most multilevel companies. Several people have described to me how they were persuaded to purchase customized television infomercials that they hoped would generate sales for them. They spent thousands of dollars to make the infomercial and additional money to broadcast them on local television channels, but the broadcasts resulted in few or no customers. Some also reported investing in a company-designed mass-mailing program that was also unsuccessful. By August 2004, the FTC had received seven complaints from people who lost from $5,000 to $25,000 using one or both of these systems [8]. I have not examined the marketing strategies of Trump or Bioceutica, but prospective distributors should keep in mind that investing money in any MLM that sells health-related products is risky.

The Bottom Line

Neither the PrivaTest nor Custom Essentials offer good value. Urine tests do not provide a legitimate basis for recommending that people take dietary supplements. Moreover, even if they could, the nutrients in the so-called customized formulas can be obtained far more inexpensively in retail stores.

[Note: The Privatest™ Drug Test System, a drug-screening test offered
by a different company, has no relevance to this article.]


  1. About the Trump Network. Trump home page dropdown menu, accessed March 20, 2011.
  2. Custom Essentials: America’s #1 customized multivitamin. Ideal Health / Trump Web site, accessed March 20, 2011.
  3. Swanson A. The Trump Network sought to make people rich, but left behind disappointment. Washington Post, March 23, 2016.
  4. Product stories. In Major Breakthrough: An Opportunity for You and Your Family. CD-ROM ©2003, Ideal Health.
  5. Supreme Greens with MSM: An alkalyzing dietary supplement. Ideal Health Web site, archived 2003.
  6. Costello, GT. Warning letter to ITV Direct president Donald Barrett Jr., April 19, 2004.
  7. Marketers of “Supreme Greens” and “Coral Calcium Daily” come under fire from the FTC. FTC news release, June 3, 2004]
  8. Federal Trade Commission response to Freedom of Information Act request for complaints about Ideal Health, Aug 4, 2004.

This article was revised on March 24, 2016.