Elomir Review: Nutritional strips with an illegal ingredient?
Elomir operates in the nutritional supplement MLM niche.
The company claims it was “founded in 2021 by Toan and Van Nguyen.”
Toan and Van Nguyen are presented as Elomir’s CEO executive team:
Elomir was founded in 2021, but not by the Nguyens.
Elomir was incorporated on September 9th, 2021, as Elomir INC in Texas.
As opposed to the Nguyen’s, Terry Lacore is listed as the sole Director of the company.
Terry LaCore (right) owns LaCore Enterprises, making Elomir part of LaCore’s stable of MLM companies.
As opposed to the usual pretending otherwise, LaCore Enterprises is acknowledged on Elomir’s website as the “LaCore Enterprises eco-system”.
They’re almost there – they just need to be transparent about Terry LaCore owning these companies and getting others to run them.
BehindMLM came across Toan Nguyen earlier this year, as lead consultant of the DeFinity FI Academy Ponzi scheme.
Website traffic to DeFinity FI Academy has since collapsed. The company’s social media accounts were abandoned in March.
Our research into Toan Nguyen for DeFinity FI Academy is applicable here;
Toan and his partner Van appear to have gotten involved in MLM through Legal Shield over a decade ago.
Promotion of BioReigns seems to have stopped around October 2020.
Nguyen’s crypto bro journey appears to have started in mid 2018.
After starting out promoting various shitcoins through “PIG” or “Passive Income Group”, Nguyen began promoting “yield farm” Ponzi schemes about a year ago.
This led to MLM crypto Ponzi schemes, starting with BNBBusiness in October 2021.
Circa January 2022, Nguyen had just started to promote Holton Buggs’ Meta Bounty Hunters NFT Ponzi scheme.
As of April 2022 Toan Nguyen was still promoting crypto Ponzi schemes on his P.I.G. Passive Income Group YouTube channel:
Yield Nodes is a non-MLM crypto Ponzi pitching a 10% average monthly ROI.
A week or so after Nguyen uploaded the video above, the Terra Luna crypto crash hit. After that Nguyen went dark on YouTube, but still promotes Ponzi schemes on FaceBook and Telegram:
Between promoting crypto Ponzi schemes, Toan apparently runs Elomir with partner Van. I’m assuming she’s doing most of the heavy lifting while Toan continues to scam people through crypto.
The Nguyens are based out of California while LaCore Enterprises and Elomir are based out of Texas.
Read on for a full review of Elomir’s MLM opportunity.
Elomir’s only listed product on their website is Axis Klarity.
3 simple and effective ingredients blend, combined with the exclusive proprietary Diffusion Technology.
You may feel the benefits in minutes by simply allowing the strip to dissolve on your tongue!
The three active ingredients in Elomir’s Axis Klarity strips are curcumin conjugate, NAC conjugate and thiamine conjugate.
Curcumin is turmeric. NAC refers to N-acetylcysteine and thiamine is vitamin B1. Conjugate refers to these ingredients being supplied in derivative form.
While you might be familiar with turmeric and thiamine, perhaps you’re less acquainted with NAC.
People commonly use N-acetyl cysteine for cough and other lung conditions. It is also used for flu, dry eye, and many other conditions, but there is no good scientific evidence to support many of these uses.
There is also no good evidence to support using N-acetyl cysteine for COVID-19.
Although many dietary supplement products contain N-acetyl cysteine, the US FDA states that it’s illegal for dietary supplements to contain N-acetyl cysteine since it’s technically an approved drug.
Prescription N-acetyl cysteine products are available under the guidance of a healthcare provider.
Unless I’m missing something, Elomir’s flagship product illegally contains a drug that is only supposed to be available in the US via prescription.
Axis Klarity retails for $89 for a bottle of thirty strips. At time of publication Elomir’s website has Axis Klarity marked as “out of stock”.
Elomir’s Compensation Plan
Elomir’s compensation plan combines retail commissions with Enrollment Pak recruitment commissions.
Residual commissions are paid monthly based on rank, with Rank Achievement Bonuses also available.
Elomir Affiliate Ranks
Elomir’s compensation plan has fifteen affiliate ranks.
Along with their respective qualification criteria, they are as follows:
- Brand Partner – sign up as an Elomir affiliate and maintain 65 PV a month
- Icon – generate and maintain 65 PV and 300 GV a month, recruit and maintain one Brand Partner and refer and maintain one retail customer
- Icon1 – maintain 65 PV a month, generate and maintain 500 GV a month and maintain one personally recruited Brand Partner and referred retail customer
- Icon2 – maintain 65 PV a month, generate and maintain 700 GV a month and maintain one personally recruited Brand Partner and referred retail customer
- Icon3 – maintain 65 PV a month, generate and maintain 1500 GV a month, recruit and maintain two Brand Partners and maintain one personally referred retail customer
- Icon4 – generate and maintain 100 PV and 4500 GV a month, and maintain two personally recruited Brand Partners and one referred retail customer
- Icon5 – maintain 100 PV a month, generate and maintain 8000 GV a month, recruit and maintain three Brand Partners and refer and maintain three retail customers
- Icon6 – maintain 100 PV a month, generate and maintain 15,000 GV a month, and maintain three personally recruited Brand Partners and three referred retail customers
- Icon7 – maintain 100 PV a month, generate and maintain 30,000 GV a month, and maintain three personally recruited Brand Partners and three referred retail customers
- Icon 8 – maintain 100 PV a month, generate and maintain 60,000 GV a month, and maintain three personally recruited Brand Partners and three referred retail customers
- Icon 9 – generate and maintain 250 PV and 100,000 GV a month, and maintain three personally recruited Brand Partners and three referred retail customers
- Icon10 – maintain 250 PV a month, generate and maintain 200,000 GV a month, and maintain three personally recruited Brand Partners and three referred retail customers
- Icon 11 – maintain 250 PV a month, generate and maintain 300,000 GV a month, and maintain three personally recruited Brand Partners and three referred retail customers
- Icon12 – maintain 250 PV a month, generate and maintain 500,000 GV a month, and maintain three personally recruited Brand Partners and three referred retail customers
- Legend – maintain 250 PV a month, generate and maintain 800,000 GV a month, recruit and maintain four personally recruited Brand Partners and maintain three referred retail customers
PV stands for “Personal Volume”. Personal Volume is sales volume generated by retail orders and an affiliate’s own purchases.
Elomir’s compensation plan states;
Placing an order monthly of Elomir products or having retail customer orders that creates a minimum of 65PV.
GV stands for “Group Volume”. Group Volume is PV generated by an affiliate and their downline.
Note that up to 60% of required monthly GV is counted from any one unilevel team leg.
Also note that to count towards rank qualification criteria, referred customers must be ordering at least one product each month.
Elomir affiliates earn commissions on the sale of Axis Klarity to retail customers.
Elomir pays retail commissions as 35% of sales volume generated by retail customer orders.
If an Elomir affiliate signs up with an Enrollment Pak, recruitment commissions are paid out weekly and monthly.
The weekly recruitment commission is 15% of the sales volume generated by the $250 Enrollment Pak fee paid.
The monthly recruitment commission is paid out via a unilevel compensation structure.
A unilevel compensation structure places an affiliate at the top of a unilevel team, with every personally recruited affiliate placed directly under them (level 1):
If any level 1 affiliates recruit new affiliates, they are placed on level 2 of the original affiliate’s unilevel team.
If any level 2 affiliates recruit new affiliates, they are placed on level 3 and so on and so forth down a theoretical infinite number of levels.
Elomir caps monthly recruitment commissions at four unilevel team levels.
Monthly recruitment commissions are paid as a percentage of Enrollment Pak fees paid across these four levels based on rank:
- Icons do not earn monthly recruitment commissions
- Icon1s and Icon2s earn 5% on level 1 (personally recruited affiliates)
- Icon3s through Icon7s earn 5% on levels 1 and 2
- Icon8s and Icon9s earn 5% on levels 1 to 3
- Icon10s and higher earn 5% on levels 1 to 4
Elomir pays a flat monthly residual commission based on rank:
- Icons earn $18 a month
- Icon1s earn $36 a month
- Icon2s earn $72 a month
- Icon3s earn $180 a month
- Icon4s earn $540 a month
- Icon5s earn $960 a month
- Icon6s earn $1800 a month
- Icon7s earn $3600 a month
- Icon8s earn $7200 a month
- Icon9s earn $13,000 a month
- Icon10s earn $26,000 a month
- Icon11s earn $39,000 a month
- Icon12s earn $65,000 a month
- Legends earn $104,000 a month
Rank Achievement Bonus
Elomir rewards affiliates for qualifying at Icon4 and higher with the following one-time Rank Achievement Bonuses:
- qualify at Icon4 and receive $200
- qualify at Icon5 and receive $800
- qualify at Icon6 and receive $1500
- qualify at Icon7 and receive $3000
- qualify at Icon8 and receive $6000
- qualify at Icon9 and receive $10,000
- qualify at Icon10 and receive $20,000
- qualify at Icon11 and receive $30,000
- qualify at Icon12 and receive $50,000 (paid out over 4 months, must qualify at Icon12 each month)
- qualify at Legend and receive $80,000 (paid out over 4 months, must qualify at Legend each month)
Note that new ranks must be maintained for two consecutive months to trigger Rank Achievement Bonuses.
3X Rank Bonus
If an Elomir affiliate qualifies at Icon4 to Icon7 in their first month, they’ll receive triple their Rank Achievement Bonus.
Note that 3X Rank Bonus is only paid out on the highest rank achieved within the first month. All other Rank Achievement Bonuses are paid out as normal.
Elomir affiliate membership is $49 annually.
This fee is waived for the first year if an Elomir affiliate signs up with a $250 Enrollment Pak.
Elomir’s Enrollment Pak comes with three boxes of Axis Klarity.
Note there currently doesn’t appear to be any way to sign up as an Elomir affiliate without purchasing an Enrollment Pak:
Having one your company CEO’s scamming people through crypto Ponzi schemes isn’t a good look.
It casts doubt on Toan Nguyen’s long-term commitment to Elomir. Elomir kinda comes off as a side-hustle when compared to crypto scamming, which Toan has been at for a few years now.
As far as I can tell Van Nguyen is committed to Elomir, which is probably why most of the marketing and updates seem to come from her.
Toan and Van doing different things is perfectly fine, but why include Toan as an Elomir co-founder if he’d rather be crypto scamming?
Honestly when I saw Toan Nguyen’s name come up in researching Elomir, I figured he’d given up crypto bro larping and moved on. It’s unfortunate to see that’s not the case.
LaCore Enterprises is notorious for his revolving door executives, so it’ll be interesting to see how things play out at Elomir long-term.
I’m going to reiterate that I might be missing something, but otherwise as far as I can tell Elomir is illegally selling N-acetylcysteine in their Axis Klarity supplement.
I went looking for FDA guidance on this, and the latest seems to be this;
Today, the U.S. Food and Drug Administration (FDA) is announcing the availability of a draft guidance on FDA’s policy regarding products labeled as dietary supplements that contain N-acetyl-L-cysteine (NAC).
The draft guidance, when finalized, will explain our intent to exercise enforcement discretion with respect to the sale and distribution of certain NAC-containing products that are labeled as dietary supplements.
That’s as of April 21st, 2022. While NAC might eventually be approved for inclusion in dietary supplements, that’s currently not the case.
It seems LaCore Enterprises and Elomir might have jumped the gun on this. Which is concerning again with respect to the long-term viability of Elomir.
Seeing as Axis Klarity is a strip product, it’s worth noting Youngevity’s recently filed lawsuit against Innov8tive Nutrition.
Innov8tive Nutrition is another LaCore Enterprises MLM opp. Innov8tive Nutrition sells patches, which Youngevity allege don’t contain the vitamins Innov8tive Nutrition claims they do.
Youngevity had Innov8tive Nutrition’s patches independently tested, and filed receipts with their lawsuit.
Both Innov8tive Nutrition’s patches and Elomir’s strips are manufactured by LaCore Enterprises.
Youngevity’s lawsuit was only filed in late May and is still playing out. I’m not stating that just because Innov8tive Nutrition’s patches are baloney that automatically the same is true for Elomir – but it’s worth keeping in mind.
Dermal patches and strips are different delivery systems, but the basic idea is the same.
Perhaps LaCore Enterprises or one of their affiliates can get Axis Klarity independently tested? Although I’m not sure what that might mean regarding confirmation of the illegal inclusion of NAC.
Moving onto Elomir’s compensation plan, one thing LaCore Enterprises have been getting right recently is retail balance.
Elomir has retail customer requirements and they’re, for the most part, matched against recruitment requirements. This ideally creates a 1:1 balance but I’d like to see retail rank requirements slightly higher than recruitment.
One thing I find concerning is, although it’s presented as “optional”, when you sign up as an Elomir affiliate you have to commit to purchase of an Enrollment Pak.
When you factor in four-level deep recruitment commissions, this side of Elomir functions as a straight pyramid scheme.
Things are tight with Icon3 required to earn residual recruitment commissions (beyond level 1). Icon3 requires two recruited Brand Partners but only one referred retail customer.
Seeing as most affiliates aren’t going to make it past Elomir’s first few ranks, this isn’t ideal.
Between Toan Nguyen still Ponzi scamming, Elomir appearing to illegally use NAC in Axis Klarity and a compensation plan that, at least at lower ranks, lends itself to a pyramid scheme, Elomir throws up enough red flags to warrant caution.
Might want to sit this one out till the dust settles.
Update 13th July 2022 – Van Nguyen has attempted to address some of Elomir’s regulatory concerns raised in this review.