At a recent BioLimitless marketing event, owner Jeremy Roma pitched consumers on a passive investment opportunity.

Roma represented consumers could invest in “BioLimitless Centers of Excellence”, the operation of which would perpetually fund increasing returns over time.

Roma pitched BioLimitless’ securities offering at a September 7th marketing event, held at the Sonesta Irvine John Wayne Airport hotel in California.

Instead of being honest about the passive returns investment opportunity, BioLimitless marketing frames it as a “crowdfunding model”.

That said, Roma opened his investment pitch by claiming BioLimitless’ investment opportunity was “fully registered in the United States”.

We have an opportunity [for] you through a crowdfunding model, fully registered in the United States, globally.

We’ll get into whether BioLimitless is “fully registered in the United States” later in the article.

A person will have the ability, literally to come in and invest five hundred dollars if they want. And actually have real equity ownership in these clinics, in the BioLimitless Centers.

Roma (below) goes on to state BioLimitless’ goal is to open two hundred clinics over the next three years, expanding to two thousand clinics “over the next several years”.

Each BioLimitless Center will require $5 million in investment, apparently solicited in cryptocurrency.

Members of [the] crowdfund will have fifty percent equity … ownership and lifetime profit sharing.

So the way it works is we’ll raise five million dollars per clinic and every person who’s a part of that group belongs to a smart contract that’s connected to that clinic.

And fifty percent of all the profits of that clinic go back to the individual investors.

The perpetual nature of passive returns offered through BioLimitless pertain to clinics funding future development.

Each own clinic will self fund a second center. Well what does that mean?

So we raise five million dollars for a center in Orange County, for example.

We build that center. That center does ten million dollars in profits. Five million of that goes back to the investors.

Now the investors have made a complete ROI. All their money is made back, right? Done.

The other five million goes to opening up a second clinic. And that second clinic is also owned by the investors who crowdfunded the first clinic.

Now that person has not only made their ROI, but they now have lifetime profit sharing in their share of fifty percent of all of the profits of clinic number one and clinic number two.

I’m aware of the math problem in that the assumption is BioLimitless’ proposed clinics will generate any profit at all. BehindMLM reviewed BioLimitless last month and noted the MLM company marketed grossly overpriced supplements.

To be honest I’m not even sure what these “BioLimitless Centers of Excellence” are even for. But all of that is a discussion for another time.

BehindMLM’s concern at this point is Roma is clearly pitching consumers on a passive returns investment opportunity.

If we apply the Howey Test to BioLimitless’ $500 a pop clinic investment scheme, we have:

  1. consumers investing $500 or more in cryptocurrency into BioLimitless (a common enterprise);
  2. investment made on the “reasonable expectation of profits” (BioLimitless marketing projects a ROI in “18 to 24 months”); and
  3. profits purportedly funding BioLimitless investor returns are “derived from the efforts of others” (clinic operation, which investors have nothing to do with).

Roma claims BioLimitless is “fully registered in the United States”. As of September 14th (i.e. after Roma made the “registered” claim), a search of the SEC’s EDGAR database reveals neither BioLimitless or Jeremy Roma are registered.

And so we have BioLimitless pitching US resident consumers on an unregistered securities offering, in apparent violation of US securities law.

This of course isn’t a surprise. Roma has been violating US securities law with his Daisy AI Ponzi schemes for years. The last iteration of Daisy AI collapsed in October 2023, prompting a Blockchain Sports reboot.

With investors wondering where funds they pumped into Daisy AI went, Blockchain Sports has been a flop. Roma and his Daisy AI co-conspirators continue to gaslight Daisy AI investors with respect to their losses.

Now we have BioLimitless, encompassing overpriced supplements and an unregistered clinic investment opportunity.

Pending any further updates, BioLimitless has announced a March 2025 launch event in Dubai.