Medifast (NASDAQ: MED) : Like Lumber Liquidators, But With Undisclosed Toxic Metals, and A Supply Chain Twist PART I

GOTHAM CITY RESEARCH LLC
Medifast (NASDAQ: MED): Like Lumber Liquidators,

But With Undisclosed Toxic Metals,
and A Supply Chain Twist
PART I
▪ Optavia products are priced and perceived to be safe, high quality, and a premium brand.
▪ Optavia powders are so expensive, Herbalife* powders can be purchased for 38%-49% less!
*Herbalife has been accused of ripping off customers and selling overpriced goods.
Competing meal replacement powders cost as much as 85% less per calorie compared to Optavia Select powders
% Discount to % Discount to
Product Name Price/Calorie ($) Optavia Essential Optavia Select
SlimFast Original Meal Replacement Shake Mix - Rich Chocolate Royale 0.005 -83% -85%
SlimFast Advanced Nutrition Meal Replacement - Creamy Chocolate 0.009 -69% -71%
Herbalife Formula 1 Dutch Chocolate 0.015 -44% -49%
Herbalife Non-GM Formula 1 Vanilla 0.017 -38% -43%
Optavia Essential Creamy Vanilla Shake 0.027 0% -9%
Optavia Select Dark Chocolate Covered Cherry Shake 0.030 10% 0%
Question #1: Are Optavia products safe and high quality as their premium pricing signals?
“Facing an increasing number of personal injury lawsuits, coupled with the fraud claims brought
by the FTC, Jason [now known as Medifast/Optavia] filed for bankruptcy in 1994.” –
from Deception about the History of Medifast and Take Shape for Life (now called Optavia)
Question #2 : 24 years later, is history about to rhyme?
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Gotham and Independent Laboratory Methodology:
Background – Gotham City Research submitted Optavia and Medifast product samples to a leading
laboratory in August of 2018. Two rounds of testing were conducted. Given that Medifast’s products have
contained concerning levels of contaminants in the past, we believed that testing for heavy metals was
merited. The analytical test reports from the lab indicate that Optavia products contain concerning levels
of lead and cadmium. We have submitted the original analytical test reports to the FDA and/or other
regulatory bodies. Gotham City Research intends to publicly release these original reports in the future.
In the interim and for the purposes of this report, we provide summaries of the data originating from the
lab reports, and we use pseudonyms when referring to products, flavors, sachets, and/or lot numbers.
Why All Optavia Fuelings Should Be Tested for Contaminants – Gotham City Research believes all
“Optavia Fuelings” marketed by the company should be independently tested for contaminants, as (I) The
average Optavia fueling tested contain concerning levels of contaminants (II) “Optavia Fuelings” are
represented as being “nutritionally equivalent and substitutable” by the company, and (II) these Fuelings
are marketed by the company as part of its flagship Optavia 5 in 1 plan diet, (where its customers are
required to consume 5 of Optavia fuelings every day).
Product Selection – We selected 5 products for testing. These 5 products include flavors that are
prominently marketed. We believe them to be representative of consumer taste and spending patterns.
About The Laboratory – The lab we selected to conduct product testing is described as the “world leader
in food, environment and pharmaceutical products testing.” The specific unit conducting the testing
specializes in “Food, Specialty/Investigative, and Environmental Analyses.”
Testing Methodology – The testing method used by the lab: AOAC 2013.06. The method is applicable to
the determination of As, Cd, Hg, and Pb in a variety of foods by pressure digestion and Inductively Coupled
Plasma/ Mass Spectrometry. The AOAC method is developed by AOAC International, a globally recognized
501(c)(3), independent, third party, not-for-profit association and voluntary consensus standards
developing organization founded in 1884.
Representations and Certifications – All quality control samples and checks were within acceptance limits
unless otherwise indicated. Test results pertain only to those items tested. All samples were in good
condition when received by the laboratory unless otherwise noted. All LOD/LOQs are adjusted to reflect
dilutions.
The lab is ISO/IEC-17025:2005 accredited by the American Associate For Laboratory Accreditation. ISO
stands for: International Organization for Standardization. The specific standard being referenced:
ISO/IEC 17025 enables laboratories to demonstrate that they operate competently and generate valid
results, thereby promoting confidence in their work both nationally and around the world.
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Table of Contents
I. Disclaimer
II. Gotham and Independent Laboratory Methodology
III. Summary
IV. We Believe MED Cuts Corners to Inflate Revenue By 21%-66%
V. Undisclosed Toxic Metals and Why Optavia Is Worse Than Peers
VI. Possible Causes Part I: Suspect Supply Chain
VII. Possible Causes Part II: Underinvestment
VIII. Allergens, Cadmium, And Other Safety Concerns
IX. Valuation: Shares Are Worth No More Than $79 Per Share
X. Appendix A: We Believe the Prop 65 Exemptions Do Not Apply
XI. Appendix B: Optavia is “Healthy”, “Safe”, and “High Quality”?
XII. Appendix C: Made in the USA?
XIII. ppendix D: Lead in Everyday Foods as Tested by the FDA
XIV. Appendix E: Lead in Protein Powders - Clean Label Study Data
XV. Appendix F: Allergies and Medifast/Optavia Products
XVI. Appendix G: Sourcing from China
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GOTHAM CITY RESEARCH LLC
a GOTHAM CITY RESEARCH’S OPINIONS:
General information:
• 21% to 74% of Optavia products contain contaminants. Company: Medifast
• Optavia prices will decline, as prices are 2x-4x more
expensive than peers’ products & programs. Business: Weight loss and
• Nearly all Optavia products are not manufactured by the Multi-level marketing
company, contradicting claims otherwise. Ticker: MED
• MED will be required to add warning labels to its products.
CEO: Daniel Chard (based
• MED’s Optavia products (its “Fuelings”) will require recalls
in Utah)
and/or third-party testing.
• Shares will decline 62%-86% the current prices. HQ: Baltimore, MD
GOTHAM CITY RESEARCH’S OBSERVATIONS Share price information:
Price as of 9/19/18: $208

• 85% of Optavia samples tested by a leading lab exceeded
the maximum allowable dose level for lead, per Prop. 65. Price target: $79
• 23% of the Optavia samples tested exceeded FDA
52-week high: $260.98
maximum daily intake levels for lead.
• The Optavia products we had tested contained higher 52-week low: $55.96
levels of toxic metals than 93% of 133 best-selling protein
Shares outstanding: 12M
powder products tested by the Clean Label Project.
• The average Optavia products tested contain higher lead Market cap: $2.49B
levels than all 283 everyday foods tested by the FDA.
YTD Performance:
• A 2008 Lab test detected similar levels of lead in MED
197.94%
products, implying the problem has remained for 10 years.
• Medifast R&D + capex spend as % of revenue is less than 5-year Performance:
half of its peers, suggesting underinvestment. 697.51%
• A former FDA official informed us that toxic metals in
5-year CAGR: 697.51%
foods is an issue of interest to the FDA, especially when
the agency has specific cause for concern. Financial information:
• MED claims all its powders are made by the company, yet
Optavia labels state “manufactured for Optavia” PE Ratio: 46x
• Optavia products claim “Made in the USA”, yet we have 5-year Revenue CAGR: 8%
evidence that the unqualified claim is false.
• The # of FDA citations for Nellson LLC & Hearthside Food PEG Ratio: 5.78
solution is very concerning. Both are believed to be among Auditor: RSM US LLP
MED’s largest contract manufacturers.
• Optavia diet ranked poorly in the 2018 US NEWS Best Diets Optavia revenue: 89%
Rankings (ranked only 29th of 40).
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Introduction
Gotham City Research began investigating mult-level marketing & weight loss companies in May 2018. In
the past, there have been low-quality companies engaged in dubious practices in these industries. Shares
of companies in these spaces – including Medifast (“MED”) – have fared very well in recent years:
950% 950%
850% 850%
750% 750%
650%
650%
550%
550%
450%
450%
350%
350%
250%
250%
150%
150%
50%
-50% 50%
-150% -50%
Medifast, Inc. (NYSE:MED) - Share Pricing Medifast, Inc. (NYSE:MED) - Share Pricing Alphabet Inc. (NasdaqGS:GOOG.L) - Share Pricing
Herbalife Nutrition Ltd. (NYSE:HLF) - Share Pricing Amazon.com, Inc. (NasdaqGS:AMZN) - Share Pricing Microsoft Corporation (NasdaqGS:MSFT) - Share Pricing
Weight Watchers International, Inc. (NYSE:WTW) - Share Pricing
Nu Skin Enterprises, Inc. (NYSE:NUS) - Share Pricing salesforce.com, inc. (NYSE:CRM) - Share Pricing Domino's Pizza, Inc. (NYSE:DPZ) - Share Pricing
Nutrisystem, Inc. (NasdaqGS:NTRI) - Share Pricing Apple Inc. (NasdaqGS:AAPL) - Share Pricing
We wondered about MED: is Medifast a quality business, even better than the likes of
Facebook/Google/Amazon/Microsoft etc – which the MED stock price performance would suggest – or is
it something else? Our interest in MED increased recently, after we found a few smoking guns suggesting
that Medifast was something else – perhaps a Tile Shop or Lumber Liquidators, in their heydays.
Medifast’s Optavia line of products, as a segment accounts for +89% of MED revenue. Significantly, we
found that items in the Optavia product line contain undisclosed contaminants, some in excess of FDA &
California Prop 65 levels if consumed as directed by the company, based on a leading laboratory’s testing.
We also found that MED’s products had been tested for toxic metals ten years ago, and that the company
succeeded in having these analytical reports removed from the website where they had been originally
posted. The recent lab results lead us to believe MED has not fixed the problem in the last ten years.
The recent lab test results suggests that Medifast’s Optavia-driven sales growth since 2016 has come at
the cost of product safety and/or product quality. We see some significant similarities between Medifast,
Lumber Liquidators (“LL”) and Tile Shop (“TTS”). For example:
• Lead levels in the Optavia samples that were tested not only exceed FDA and Prop 65 levels if
consumed as directed, they contain more lead than 93% of similar protein products, & 100% of
everyday foods that the FDA has tested.
• MED’s Core R&D + infrastructure spend is low relative to its peers and has been slashed in recent
years. For example, net PP&E has declined by over 50%, and capex + R&D spend (as % of sales) is
only half that of its peers.
• MED claims that all its powder based products (42% of sales) are manufactured by the company,
yet our investigation reveals Optavia powders are manufactured FOR Optavia, not BY Optavia.
Lumber Liquidators and Tile Shop faced similar product safety and/or quality and sourcing concerns as
described above for MED, some of which Gotham City Research exposed. We believe that these
companies’ actions violated the trust of its customers, causing damage to their brands and reputations.
Based on our research and analysis, we see similar concerns for MED. We believe its shares will decline
62%-86% once the company accounts for the problems revealed in this report and elsewhere.
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We Believe MED Cuts Corners to Inflate Revenue by 21%-66%
Medifast/Optavia: a bona fide turnaround story or a repeat offender?
On September 10, 2012, Medifast paid a $3.7 million civil penalty (23% of 2012 net income) to settle
Federal Trade Commission charges that it made unsupported claims about its weight-loss program. The
FTC barred MED from making any additional unsupported claims about users’ success in achieving or
maintaining weight loss/control. Perhaps due to the negative publicity resulting from the company’s FTC
violations, as well as being under closer scrutiny, revenue declined in subsequent years:
USD, in MMs 2012 2013 2014 2015 2016 2017
Revenue $318.6 $324.1 $285.3 $272.8 $274.5 $301.6
Net income $15.9 $24.0 $13.2 $20.1 $17.8 $27.7
% change in Revenue 1.72% (11.96%) (4.39%) 0.65% 9.85%
% change in Net income 51.0% (45.0%) 52.2% (11.1%) 55.4%
An activist investor entered the scene in May 14, 2014. Soon after, the Company modified the composition
of its Board of Directors, replacing its long-time CEO Michael Macdonald with Daniel Chard (formerly a
senior sale executive of Nu Skin). MED rebranded to Optavia, focusing fully on the Multilevel marketing
unit. Full year revenues bottomed in 2015, and MED’s revenues fully recovered to its 2013 highs by early
this year. Perhaps seeing that the heavy lifting had been already completed, the activist investor began
unloading its stake as revenues recovered, and fully exited their MED position by March of this year.
New Brand, Same old tricks? Our Preliminary Suspicions
While a bona fide turnaround appeared plausible, we began to question the prevailing narrative that
Medifast was no longer the repeat offender it was widely believed to be, for the following reasons:
• Price increases seemed to better explain the post 2015 revenue recovery vs volume growth:
MED Price Increases vs. Revenue Growth
% change YoY 2015 2016 2017
Revenue -4.4% 0.6% 9.8%
Price of MED Products 10.6% 4.0% 8.4%
• We did not see corresponding increases in product quality or R&D/capex spend. Instead, we saw
signs MED was shifting away from science/R&D and towards marketing/self-promotion.
• Despite price increases and a marketing push emphasizing Optavia as a premium brand, the
Optavia diet ranked poorly in the 2018 US NEWS Best Diets Rankings (ranked only 29th of 40).
• We have not observed honest & consumer friendly practices, despite its rebranding to Optavia
• Consumers have filed more complaints against Optavia just within the last 4 months, than they
did against Medifast in over 24 months, according to the Better Business Bureau (“BBB”).
Suspecting that the turnaround narrative might be off, we dug deeper. We discovered a few interesting
nuggets buried in a 2010 defamation filing, where MED sued several of its critics. In it, MED vigorously
denied the most central allegation – that MED was a pyramid scheme – made by the controversial Barry
Minkow. Notably, however, the Company (I) did NOT dispute the accuracy of lab results indicating
Medifast powders contained undisclosed toxic metals, and (II) did not claim that its products do not
claim toxic metals. Given they did not dismiss the results, we interpret that to mean they were accurate.
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Did MED fix the toxic metals issue? Why we believe the company is cutting corners to inflate revenue
Although Minkow was subsequently convicted for crimes unrelated to Medifast (we think deservedly),
the MED critics from 2010 were not entirely wrong about everything: allegations regarding improper
accounting and false/deceptive marketing have been validated by the SEC and FTC, respectively:
Allegation Outcome
Improper accounting SEC validated these claims.
False/deceptive marketing FTC validated these claims.
Illegal Pyramid Scheme Unknown.
Products contain toxic metals Please read the remainder of this report.
But what of the toxic metals issue? We engaged an independent, well known lab described as the “world
leader in food, environment and pharmaceutical products testing” to test Medifast and Optavia products
for toxic metals. Should MED’s turnaround be genuine, the lab test results would be favorable. A
completely safe product would justify aggressive price increases and price premiums relative to peer
products. The lab results, as well our subsequent due diligence as to possible causes, lead us to believe:
• Optavia products contain undisclosed toxic metals: The Optavia product samples the lab tested
contain lead exceeding regulatory standards. The samples also contain more lead than 93% of
protein products tested by the Clean Label Project, and more lead than all 283 everyday foods
that the FDA had tested for lead.
• Aggressive price increases and significant premiums to peer products are not justified: Optavia
products contain more toxic metals than peers’ products or everyday foods, MED underinvests
relative to peers, yet their products are far more expensive. We expect Optavia prices to drop.
• Supply chain is suspect and could explain the toxic metals: The company claims it
manufactures all its powders and that its products are “Made in USA”, yet we uncovered
evidence to the contrary, which might explain the presence of toxic metals.
Optavia’s $200 million of sales growth since 2016 is suspect, as MED has violated the trust of customers
By cutting corners, as described above, Gotham City Research believes that:
• MED has violated its customers and coaches’ trust.

• The turnaround narrative promoted since 2016, as well as the corresponding Optavia-fueled
revenue growth ($200 million of Optavia-fueled revenue growth), are suspect.
Consequently we believe 21%-66% of revenues are at risk. We derive the impact using two different
methods. Our first method:
• Optavia has been the primary driver of revenue growth since its launch in 2016, even as MED’s
other reported segments have crumbled to oblivion.
• Revenue growth since 2016 works out to $200 million (as revenue for 2016 was 274.5 million and
revenue for 2018 is expected to be $475 million, the difference is $200 million).
• The $200 million of revenue may not have occurred had Optavia customers and coaches known
about the undisclosed toxic metals issue as shown in this report.
• $200 million works out to 42% of 2018E revenue, right in the middle of the 21%-66% range.
Page 8 of 69
21%-66% of revenues are at risk, derived using our second method:
• The company claims that 42% of product sales as of 2017, originate from selling powders:
Powder Based Products 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
% of Medifast Sales 80% 65% 55% 55% 46% 44% 43% 42% 43% 42%
A company source said 40% of sales come from selling bars, so 82% of sales = powders + bar.
• Optavia products are supposed to be all nutritionally equivalent & substitutable. We interpret this
to mean that if one kind of fueling – say in the form of a bar – were to contain concernings levels
of contaminants, then other types of fuelings – e.g. powder-based, soups, shakes, and puddings
– could contain equal amounts of said contaminants.
• 66% exposure - Out of the Optavia products tested for toxic metals, 85% tested as suspect. Given
that Optavia fuelings are supposed to be “nutritionally equivalent and substituble”, let’s assume
that most, but not all, fuelings (7 out 8) contain the same ingredients as the tested ones. Seeing
that Optavia represents 89% of revenue (on TTM basis), 66% of revenue is at risk, in this scenario.
• 21% exposure - MED claims that 42% of unit sales are from powders (we assume unit sales and $
sales are proportional). For this lower end estimate, we conservatively assume that only powders
contain toxic metal levels of significance AND that only some flavors are risky (so we generously
allow only 50% of powders to be of concern). This would imply that the other products are NOT
nutritionally equivalent nor substitutable. So 50% of 42% powder sales, equals 21%.
• Our estimated Optavia revenues at risk factor in no price reductions – Our above estimates
assume constant pricing, i.e. no price reductions. Given that Optavia products have been priced
at meaningful premiums to peers’ products - Herbalife, Slimfast, and just about all protein shake
powders are less expensive – the risk of price reductions is very high.
• Mechanisms that would facilitate a dramatic decline in sales – There are two important features
of Optavia’s business model that would catalyze a precipitous and sudden decline in sales:
o Multilevel marketing –An MLM, like leverage, amplifies financial results. In good times,
this is great; but in bad times, an MLM collapses far faster and deeper than an equivalent
non-MLM company’s sales would. The MLM feature would ampiify declines.
o Pressure from other channels, such as Ebay – Optavia goods are sold in direct non-MLM
online channels. Pricing in these channels, such as Ebay, could downwardly adjust prices
faster than the other channels.
• Operating leverage, margin pressures, and increased uses of cash – The Company spends less on
R&D and capex as % of sales relative to its peers. We would expect their spending on these
expenditures to converge to their peers’ levels, leading to a reduction in cash flow. In order to
ensure lower levels of toxic metals in their products, we expect their contract manufacturers to
raise prices. We cover these considerations in the Valuation section in this report.
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Cutting Corners to Inflate Financial Results: We Have Seen This Movie Before
Tile Shop & Lumber Liquidators had once been the flavor du jour with the stock market, as MED is today.
But once quality/safety + supply chain related concerns were raised, and the quality of growth of these
companies had come into question – Both companies’ share prices declined. Neither have recovered
since. Perhaps what worsened the underlying problems is that both companies denied the claims and/or
attacked the messengers. In our opinion, MED is like Tile Shop and Lumber Liquidators, and its share price
will suffer a similar fate for the reasons found in this report. We summarize the similarities we see:
Tile Shop Lumber Liquidators Medifast
Product Quality/Safety Concerns YES YES YES
Supply Chain Concerns YES YES YES
Inflated Financial Results* YES YES YES
Critics concerns validated YES YES We think over time
*resulting from growth at the possible expense of product quality and safety
While we believe that the facts and analyses presented in this report sufficiently support our opinions, we
have additional evidence (covered in our Part II) that further reinforce our opinions. The content
contained in Part II will present topics not covered in this report.
Gotham City Research believes that Medifast might be worse than TTS and LL for the following reasons:
• While TTS and LL were alleged to sell goods containing toxic materials, their customers did not
consume the products. On the other hand, Optavia’s main offering is a “5 in 1 plan” diet, where
customers are expected to consume 5 of these toxic metal-laden servings per day!
• MED’s customers – overweight and obese people – are particularly vulnerable to adverse health
health consequences from overexposure to contaminants.
• Optavia products are priced to perfection, selling at a 30%-400% premium to competitors’
goods.
• Optavia products are sold through a multi-level marketing program (“MLM”). An MLM, like
financial leverage, amplifies financial results. In good times, this is great; but in bad times, an
MLM collapses far faster and deeper than an equivalent non-MLM company would.
Gotham City Research believes third parties should and will independently test Optavia products
Just as it happened with Tile Shop and Lumber Liquidators – we expect third parties – i.e., parties with no
ties to Gotham City Research or Medifast – to conduct and/or commission their own tests. As they should.
We believe their findings will corroborate – and possibly further – the findings in our report.
Page 10 of 69
Undisclosed Toxic Metals and Why Optavia Is Worse Than Peers
Medifast/Optavia: safe, effective, and helping customers incorporate healthy habits in their lives?
Medifast/Optavia claim that their products are “safe and effective”, “contain all of the good stuff and
none of the bad stuff”, and that the company “incorporates healthy habits in everything we do”:
Gotham City Research believes that products containing undisclosed toxic metals – such as lead and
cadmium – are not “safe and effective” and are what scientists would call “bad stuff” for the human body.
Toxic metals – such as Lead and Cadmium – are dangerous for human consumption
Lead and cadmium are dangerous, believed by scientists to cause serious health problems. Regarding lead:
• "There is no known level of lead exposure that is considered safe. Lead is a cumulative toxicant
that affects multiple body systems " – World Health Organization (“WHO”)
• “Lead is associated with premature death. It is estimated that in 2016 lead exposure accounted
for 540 000 deaths and 13.9 million years of healthy life lost worldwide"
• "In 2016 lead exposure accounted for 540,000 deaths and 13.9 million years of healthy life lost
worldwide due to long-term effects on health." Institute for Health Metrics & Evaluation (IHME)
• "During pregnancy, current or past exposure to lead by the mother could present a risk to the
fetus." – Environmental Protection Agency (“EPA”)
• In children, “Even low levels of lead in blood have been shown to affect IQ” and “these effects of
lead exposure cannot be corrected.” - Center for Disease Control (“CDC”)
Lead presents dangers particularly relevant to the overweight and obese, Optavia’s target customer
Overweight and obese people – Optavia’s target customer – are a high-risk population that tend to suffer
from other physical conditions, such as high blood pressure, heart disease, and other heart-related
conditions. These problems may be caused or worsened by consuming products high in lead:
• “People with prolonged exposure to lead may also be at risk for high blood pressure, heart
disease, kidney disease, and reduced fertility.” – Center for Disease Control
• “The study found that crash diets in the early phase caused fat to accumulate within the heart
muscle.” – Radcliffe Department of Medicine
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85% Optavia-branded product samples tested last month contain undisclosed toxic metals
Last month, we purchased Medifast and Optavia branded products and had them sent to a laboratory for
testing. Gotham City Research believes (I) Medifast/Optavia-branded products are unsafe and low quality
relative to peer products and everyday foods, and (II) Optavia Fuelings require a recall and/or independent
testing for the reasons mentioned below and in the remainder of this report:
• Nearly all the Optavia samples tested contain lead exceeding the Proposition 65 maximum
allowable dosage level by 10x on average. 22% of the samples exceeded the FDA maximum daily
intake level for lead (a level the FDA is considering lowering).
• Just one serving of an Optavia Fueling exceeds the Prop 65 lead limit by over 100%, based on the
samples tested. These Optavia Fuelings are meant to be consumed 5 times per day.
• The Optavia samples tested contain more lead on average than 93% of other high protein
powders suggesting that Optavia products are of worse quality than peer products.
• The Optavia samples tested contained more lead on average than all everyday foods tested by
the FDA for lead (a basket of 283 everyday foods were tested for lead).
• The Optavia samples contain similar levels of lead on average as Medifast samples that were
tested in 2008, suggesting that the company has known about lead as a risk factor, and that it
has failed to reduce lead to the lowest levels currently feasible.
A single serving of an Optavia fueling would exceeds the maximum allowable daily limit levels by 2x
California’s Prop 65 requires companies to provide a warning label regarding the reproductive risks of
consuming lead, when daily intake exceeds 0.5 µg/day. In 6 out of 7 cases, as shown below, just one
serving (for example, just one pouch of powder) of the tested Optavia products exceeds the Prop 65 levels
yet there are no warning labels on the boxes or the pouches:
Lead Lead per Lead per
Concentration Serving Day
Report Date Sample # (µg/kg) (in µg) (in µg)
8/17/2018 Sample: 1 22 0.70 3.52
8/17/2018 Sample: 2 43 1.38 6.88
8/22/2018 Sample: 3 22 0.70 3.52
8/22/2018 Sample: 4 17 0.54 2.72
8/22/2018 Sample: 5 19 0.61 3.04
8/22/2018 Sample: 6 77 2.31 11.55
AVERAGE: 33 1.04 5.21
These Optavia products are meant to be consumed 5x per day, according to their flagship diet plan
The flagship Optavia 5 in 1 diet plan (Optavia’s only diet plan we’re aware of that makes specific claims
about possible average weight loss), requires its customers to consume 5 Optavia “fuelings” per day (a
fueling is a serving of “nutritionally equivalent and substitutable” products, including powders and bar). If
its customers were to adhere to the plan, they would consume enough lead to exceed the Prop 65
Maximum Allowable Dose Level by over 10x! Seeing that the company represents all its Optavia Fuelings
as “nutritionally equivalent and substitutable”, we believe that the lead levels per the tests we had
conducted are a fair proxy for the risk that the untested Optavia products may present. We do not know
how often Medifast tests its own products, but our results suggest that it does not do so sufficiently, or,
if it does, that it has chosen not to disclose those results.
Page 12 of 69
23% of samples exceed FDA maximum daily intake level 6 µg per day
Samples 2 & 6 contain enough lead such that consuming them as required by the 5 in 1 plan would exceed
the FDA’s maximum daily intake level for lead, of 6 µg/day. Notably the FDA’s maximum level may be
revised lower, just as other organizations, such as WHO, have already done. The table below shows how
the FDA remains the only entity among those listed who has yet to lower maximum lead levels:
Organization Lead Limit Guidance Year Lead Units
World Health Organization Provisional Tolerable Weekly Intake 1972 0.050 mg/kg bw
1999 0.025 mg/kg bw
2011 0.000 mg/kg bw
European Food Safety Authority Provisional Tolerable Weekly Intake 1992 0.025 mg/kg bw
2010 0.000 mg/kg bw
US Food and Drug Administration Provisional Tolerable Total Dietary Intake 1993 0.006 mg/day
Under Review*
According to a former FDA official, toxic metals in foods is an issue of interest to the FDA. He said that the
FDA acts when the agency has specific cause for concern, and the levels of lead in the tested Optavia
samples would raise questions for the FDA.
Background: The FDA may lower the maximum daily intake level of 6 µg/day
In 1993, the FDA established a maximum daily intake level (6 µg/day), known as the Provisional Tolerable
Total Dietary Intake level (PTTDI) based on the Centers for Disease Control and Prevention (CDC)’s Level
of Concern of 10 micrograms of lead per deciliter of blood (µg/dL). The PTTDI helps the FDA in assessing
the risk of lead in food in various aspects of its regulatory mission such as in supporting enforcement
actions, rulemaking and guidance development. At the time the FDA set the 6 µg/day level, the agency
stated that its Provisional Level “may be reduced if additional research shows that even lower levels of
lead cause adverse health effects.” In the last decade, new scientific information has become available
with respect to neurotoxic effects of low levels of exposure to lead. This prompted the EPA to lower its air
quality standard, the CDC to replace its Level of Concern with a reduced reference value level, and the
Joint WHO and FAO Committee on Food Additives (JECFA) to withdraw its Provisional Tolerable Level for
lead. In the meantime, the FDA has been reviewing its provisional level.
https://www.fda.gov/Food/FoodborneIllnessContaminants/Metals/ucm557424.htm
Medifast/Optavia samples tested contain more lead than over 93% of peers tested, on average
Among the Optavia products tested that contain lead (nearly all did), the Optavia samples contain more
lead than 93% of 133 of America’s best-selling protein powders tested by the Clean Label Project in March
2018. The Clean Label Project pulled over 130 of America’s best-selling protein powders in accordance
with Nielson data, the Amazon.com best seller list, and supplemented that list with top sellers in the
natural/organic retail channel and consumer favorites mentioned on fitness blogs and websites.
Page 13 of 69
The worst Optavia sample contained more lead than nearly all 133 peer products:
130
125
120
115
110
105
100
95
90
85
Optavia Sample #6
80
Lead level in ug/kg
75
70
65
60
55
50
45
40
35
30
25
20
15
10
5
0
1 4 7 10 13 16 19 22 25 28 31 34 37 40 43 46 49 52 55 58 61 64 67 70 73 76 79 82 85 88 91 94 97 100 103 106 109 112 115 118 121 124 127 130 133
Clean Label Project Protein Powders Optavia
Why the comparison between Optavia fuelings and 133 protein shakes is appropriate and concerning
So why are we comparing Optavia fuelings to protein shakes? Earlier this year, The Clean Project
completed a study of 134 protein powder products. Clean Label Project had the top-selling protein powder
products – animal-based, whey, and plant-based – tested and reviewed by a third party analytical
chemistry laboratory for industrial and environmental contaminants and nutritional superiority elements
like antioxidant activity. The study showed that many of the top-selling powders and drinks may contain
concerning levels of heavy metals.
The following reasons lead us to believe the comparison is appropriate:
• Many Optavia fuelings are high enough in protein (as far as % of calories for protein is concerned)
to be deemed what the FDA calls “protein products”.
• Protein powders have been known to contain high levels of toxic metals (even before the results
of the Clean Label Study were released in March 2018), particularly those containing plant-based
proteins. Some Optavia products also contain plant-based proteins.
The following reasons lead us to believe the comparison is concerning:
• Optavia samples tested contain more lead than most of these already at-risk products.
• Many Optavia customers are required to consume 5 servings per day; we suspect that the average
consumers of the protein products tested under the Clean Label Project do not consumer
anywhere near 5 servings of those products per day.
• The Optavia samples contain less % of calories from protein than the protein powders tested by
the Clean Label Study, on average, raising concerns as to where the lead is originating from.
• Optavia is represented as a high-quality product and is priced far higher on a per serving and per
calorie basis, than protein powders (and even all diet shakes we could find).
Page 14 of 69
Optavia samples contain more lead on average than all 283 everyday foods tested by the FDA
The Optavia products that were tested contain more lead on average than all 283 everyday foods that
were tested by the FDA in its 2013 study (updated 2017), titled FDA Total Diet Study – Element Results
Summary Statistics. The below table shows the top 10 foods that tested highest for average lead (see
column Mean (mg/kg)):
TDS N of N of Non- N of Mean Std Dev Median Min Max LOD LOQ
Element Food TDS Food Name Analyses detects Trace (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg)
No.
LEAD 295 Syrup, chocolate 32 1 31 0.016 0.005 0.016 0 0.027 0.007 0.030
LEAD 221 BF, sweet potatoes 32 5 26 0.013 0.008 0.014 0 0.034 0.007 0.030
LEAD 254 Peach, canned in light syrup 32 4 26 0.012 0.008 0.011 0 0.038 0.007 0.030
LEAD 348 Apricots, canned in heavy/light syrup 32 6 25 0.012 0.008 0.013 0 0.036 0.007 0.030
LEAD 723 BF, arrowroot cookies 32 11 21 0.012 0.010 0.014 0 0.031 0.010 0.040
LEAD 358 Sweet potatoes, canned 32 2 30 0.012 0.005 0.012 0 0.023 0.007 0.030
LEAD 187 Candy bar, milk chocolate, plain 32 10 22 0.011 0.008 0.014 0 0.027 0.010 0.040
LEAD 291 Brownie 32 7 24 0.010 0.007 0.010 0 0.032 0.007 0.030
LEAD 87 Fruit cocktail, canned in light syrup 32 7 25 0.010 0.007 0.011 0 0.025 0.007 0.030
LEAD 244 Shrimp, boiled 32 25 5 0.009 0.033 0 0 0.180 0.010 0.040
LEAD 317 BF, teething biscuits 31 17 14 0.009 0.011 0 0 0.033 0.010 0.040
LEAD 712 BF, juice, grape 32 4 26 0.009 0.005 0.010 0 0.020 0.004 0.020
Shrimp was the only everyday food sample that tested higher than the Optavia samples for lead, but only
LEAD 704 BF, juice, apple-cherry 16 3 10 0.008 0.008 0.006 0 0.023 0.004 0.020
LEAD 161 Dill cucumber pickles 32 19 12 0.007 0.011 0 0 0.049 0.010 0.040
when comparing the worst shrimp sample (the “max” sample) against the worst Optavia sample; when
LEAD 93 Pineapple, canned in juice 32 10 21 0.007 0.009 0.006 0 0.046 0.005 0.020
LEAD 255 Pear, canned in light syrup 32 13 18 0.007 0.007 0.008 0 0.030 0.007 0.030
comparing the Optavia sample average lead content against average and median results for all 283 foods,
LEAD 199 Wine, dry table, red/white 32 4 27 0.007 0.005 0.007 0 0.029 0.004 0.020
Optavia is by far the worst.
LEAD 178 Cake, chocolate with icing 32 17 15 0.006 0.007 0 0 0.021 0.007 0.030
Clam chowder, New England, canned,
LEAD 285 32 14 18 0.006 0.006 0.008 0 0.020 0.007 0.030
condensed, prepared with whole milk
MED
LEAD failure
183 to reduce lead levels from a 2008
Chocolate chip cookies 13 tests19suggests
0.006 disregard
32 0.006 for food
0.008 0 quality
0.018 + safety
0.007 0.030
Grape juice, frozen concentration,
LEAD 257 32 10 22 0.006 0.005 0.006 0 0.015 0.004 0.020
reconstituted
Every
LEAD
company makes mistakes. The question17is: why13are these
230 BF, juice, apple 32
0.005
lab results
0.007 0
eerily
0
similar to lab0.004
0.029
results from
0.020
over 10 years ago? The below table shows the results from that lab test from 10 years ago:
LEAD 703 BF, juice, apple-banana 6 8 15
0.005 0.007 0.004 0 0.022 0.004 0.020
LEAD 705 BF, juice, apple-grape 16 7 9 0.005 0.006 0.005 0 0.019 0.004 0.020
LEAD 357 Lettuce, leaf, raw 32 16 16 0.005 0.005 0.003 0 0.017 0.005 0.020
LEAD 293 Candy, hard, any flavor 32 Lab
30 Report
0 0.004 0.014 Serving
0 Size
0 Lead per
0.065 0.020 0.050
LEAD 211 BF, vegetables and beef 32 26 5 0.004 0.012 0 0 0.064 0.007 0.030
LEAD 216 Medifast
BF, turkey and rice Product Name 32 20 Date 11 Lead
0.004 (µg/g)
0.007 0 (g) 0 Serving
0.035 (µg/g)
0.007 0.030
LEAD 95 Medifast
Raisins 70 Dutch Chocolate Shake 32 9/12/2008
24 9 0.0458
0.004 0.007 0 32.4 0 0.0231.5 0.010 0.040
LEAD 251 Crackers, graham 32 23 9 0.004 0.007 0 0 0.020 0.010 0.040
LEAD 184 Sandwich cookies w/ crème filling 32 9/16/2008
21 11 0.0449
0.004 0.005 0 32.4 0 0.0191.5 0.007 0.030
LEAD 107 Spinach, fresh/frozen, boiled 32 9/19/2008
20 12 0.0282
0.004 0.005 0 32.4 0 0.0180.9 0.007 0.030
LEAD 172 Honey 32 23 9 0.004 0.006 0 0 0.018 0.010 0.040
LEAD 218
Medifast
BF, carrots
70 French Vanilla Shake
32
9/12/2008
20 12
0.0312
0.004 0.006 0
31.2 0 0.018
1.0 0.007 0.030
LEAD 376
Salad dressing, creamy/buttermilk type,
32
9/16/2008
24 8
0.0400
0.004 0.007 0
31.2 0 0.018
1.2 0.012 0.040
low-calorie
LEAD 711 BF, juice, pear 32
9/19/2008
13 19
0.0167
0.004 0.004 0.005
31.2 0 0.015
0.5 0.004 0.020
LEAD 162 Margarine, regular (not lowfat), salted 32 30 1 0.003 0.013 0 0 0.065 0.020 0.060
LEAD • 168the average lead levels per serving, ~1
Cream substitute, non-dairy,
26 ug per
32
5 day, are 0.010
0.003 approximately
0 0 equal0.050
to the0.010
average lead
0.040
liquid/frozen
LEAD 164levels per serving found in the Optavia
Butter, regular (not lowfat), salted29 products
32
3 we had0.009
0.003 tested0 for lead.0 0.031 0.020 0.060
LEAD 250 English muffin, plain, toasted 28 32
4 0.003 0.008 0 0 0.024 0.010 0.040
LEAD • 728Medifast sued those critics for defamation.
BF, vegetables and turkey 23 32
9 0.003 0.006 0 0 0.020 0.007 0.030
LEAD
LEAD
• 103In the complaint filing, the Company did
182 Sweet roll/Danish pastry
Prune juice, bottled
23
21
32
9
not11dispute
32
0.003 0.005
the0.004
0.003
accuracy0
0
0
of the
0
0.019
lab’s0.014 0.007
lead results,
0.005
0.030
though
0.020
LEAD 350it vigorously disputed the accuracy

Fruit juice blend (100% juice),
canned/bottled
of
16 most 32
16 allegations
0.003 found
0.004 in
0.002 the0 critics’ reports.
0.014 0.004 It is a fair
0.020
LEAD 720inference that MED believed the 2009

BF, peach cobbler/dessert 23 lead 9tests 0.003
32 were correct.
0.005 0 0 0.012 0.007 0.030
LEAD 724 BF, zweiback toast 11 14
3 0.003 0.005 0 0 0.012 0.010 0.040
LEAD • 710Michael MacDonald, MED’s current10non-executive
BF, juice, mixed fruit 16
6 0.003 Chairman
0.003 0 of the 0 Board 0.008of Directors,
0.004 0.020was
LEAD 22 Lamb chop, pan-cooked with oil 30 32
1 0.002 0.007 0 0 0.040 0.010 0.040
LEAD 173
previously CEO
Tomato catsup
of MED. He + family members
28 32
4
have been
0.002
involved
0.007 0
with
0
MED for
0.038
many
0.010
years.0.040
LEAD
• 372Given Macdonald’s involvement with30MED, we
Popcorn, microwave, butter-flavored
Egg, cheese, and ham on English muffin,
32
2
believe
0.002
the
0.008
company
0
has
0
known0.038
about lead0.050
0.014
issues
LEAD 278 29 32
3 0.002 0.006 0 0 0.030 0.010 0.040
for a long time and have failed to disclose or correct the problem.
fast-food
Doughnut, cake-type, any flavor, from
LEAD 290There is no shame in making mistakes…only
28 4 in not
32 correcting
0.002 0.005 0them. 0 0.027 0.007 0.030
donut store
LEAD 108 Collards, fresh/frozen, boiled 32 28 4 0.002 0.005 0 0 0.025 0.007 0.030
LEAD 77 Oat ring cereal 32 28 4 0.002 0.005 0 0 0.023 0.010 0.040
LEAD 88 Grapes (red/green), raw 32 27 5 0.002 0.004 0 0 0.019 0.005 0.020
LEAD 259 Carrot, fresh, peeled, boiled 32 27 5 0.002 0.004 0 0 0.019 0.007 0.030
LEAD 346 Macaroni salad, from grocery/deli 32 28 4 0.002 0.004 0 0 0.016 0.010 0.040
LEAD 186 Pie, pumpkin, fresh/frozen 32 27 5 0.002 0.004 0 0 0.015 0.010 0.040
LEAD 74 Raisin bran cereal 32 28 4 0.002 0.004 0 0 0.014 Page 15 of 69
0.010 0.040
LEAD 212 BF, vegetables and chicken 32 27 5 0.002 0.004 0 0 0.014 0.007 0.030
Bread, multigrain (formerly cracked
LEAD 248 32 28 4 0.002 0.004 0 0 0.014 0.010 0.040
wheat)
LEAD 299 Black olives 32 24 8 0.002 0.005 0 0 0.014 0.007 0.030
LEAD 370 Granola bar, with raisins 32 28 4 0.002 0.004 0 0 0.014 0.010 0.040
LEAD 298 Mustard, yellow, plain 32 24 8 0.002 0.004 0 0 0.012 0.007 0.030
Optavia is a very bad deal compared to other products, given these quality and safety concerns
Given the issues we’ve discussed thus far in this report, one might expect Optavia to be a low-cost product
line, meant to appeal to budget-conscious consumers. Based on our examination of prices of similar goods
and diet programs, Optavia actually looks like a very bad deal: competing meal replacement powders cost
between 40%-80% less than Optavia’s:
Competing meal replacement powders cost as much as 85% less per calorie compared to Optavia Select powders
SlimFast Original Meal Replacement Shake Mix - Rich Chocolate Royale 0.005 -83% -85%
SlimFast Advanced Nutrition Meal Replacement - Creamy Chocolate 0.009 -69% -71%
Herbalife Formula 1 Dutch Chocolate 0.015 -44% -49%
Herbalife Non-GM Formula 1 Vanilla 0.017 -38% -43%
Optavia powders are notably more expensive than even Herbalife’s, a company that has been accused of
ripping off customers and selling overpriced goods. Based on our pricing studies, Herbalife is between
38%-49% less expensive than Optavia! The pricing differences are even more dramatic when compared
against SlimFast products, as shown in the table above.
Even when comparing Optavia to a slightly different program, Nutrisystem, Optavia is more expensive:
MED is more expensive per day than Nutrisystem's Core Plan. (Core Plan includes Nutrisystem support)
Company Name of Kit Price Servings Days of Food Price Per Day
Optavia Essential Optimal Kit (5&1 Plan®) $356.15 119 24 $14.96
Nutrisystem Core Plan with Auto-Delivery: Women $317.98 112 28 $11.36
Nutrisystem Core Plan with Auto-Delivery: Men $357.98 140 28 $12.79
Optavia Price Premium vs. Nutrisystem for Women 32%
Optavia Price Premium vs. Nutrisystem for Men 17%
Days of food for MED is assuming user is on the 5 and 1 plan, 5 servings of MED per day
Women have 4 NTRI meals a day while Men have 5 - this is why the price differs on the two NTRI plans
Each company's 1st month promotional meals are not included in the comparison
Shipping is free for both companies when you buy a kit
While the protein powders tested by the Clean Label Project may not be used by its customers primarily
for weight loss purposes, these powders contain as many (if not more) calories from protein as Optavia
products do. Therefore, these protein powders could be just as effective at helping its users lose weight
via ketosis, as Optavia claims its diets do. And these products are notably less expensive – between 50%-
84% less expensive – than Optavia’s:
The top 5 protein powders tested by Clean Label Project cost 50-84% less per calorie compared to Optavia Select powders
Body Fortress Super Advanced Vanilla Whey Protein 0.005 -83% -84%
PERFORMIX Pro WHEY+ Protein Powder with Time Release Amino Beads 0.005 -82% -84%
Pure Protein 100% Whey Powder - Vanilla Cream 0.005 -80% -82%
Biochem Vanilla 100% Whey Protein 0.010 -63% -66%
Puori PW1 Vanilla Pure Whey Protein 0.015 -45% -50%
Page 16 of 69
MED does not provide a warning label about lead or its dangers as we believe is required per Prop 65
We have not seen, nor are aware of, any of Medifast or Optavia-branded products containing a warning
label regarding the dangers of lead, as is required for companies selling products in California containing
lead exceeding the maximum allowable dosage levels. These products’ labels should say something like:
Not only does MED not provide a warning label about lead on its packaging, we also see no mention of
lead in the Optavia/Medifast websites. MED makes no representations or assurances about its lead
products’ content.
Unlike Herbalife, one of Medifast’s Competitors, MED provides no assurances about lead levels
On the other hand, Herbalife makes the following representations about lead in its products:
Why we believe MED is in violation of Prop 65, Faces Liability, & its Products will Require Warning Labels
Proposition 65, a.k.a. Safe Drinking Water and Toxic Enforcement Act of 1986
Gotham City Research believes Medifast/Optavia is in violation of Proposition 65, and will face
consumer and legal scrutiny for the following reasons:
• Lab test results for lead in 2018 exceed the maximum allowable dosage levels (on a per serving,
as well as on per day consumed basis), per Prop 65, as discussed earlier in this section.
• Optavia/Medifast products do not carry the required warning label.
• This is not a first time offense for MED, as Lab test results from 2008 detected lead.
• Gotham City Research believes Optavia/Medifast do not qualify for any of the exemptions that
would relieve the company from carrying the warning labels.
In the appendix, we explain why Gotham City Research believes Optavia does not qualify for the
exemptions.
Page 17 of 69
Possible Causes Part I: Supply Chain Is Suspect
Suspect supply chains can compromise product safety and quality
Why do the tested Optavia fuelings contain undisclosed toxic metals? Particularly, why do they contain
higher levels of toxic metals than nearly all similar high product products, everyday foods, and against
regulatory standards? And how is this all possible when Optavia powder prices are 2x-5x more expensive?
These are significant anomalies, in our view.
The answer may lie in a suspect supply chain. Companies do not always disclose their products’ origins (or
are deceptive about their origins), especially if there are known quality concerns. This was exactly the case
with Tile Shop, where one of its main suppliers was an undisclosed related party based in China.
In other cases, underinvestment or insufficient spending on quality control leads to problems. We saw
this problem with a web hosting company called Endurance International Group. Endurance had spent far
less on core intrastructure spending versus its primary competitor, Godaddy. Consequently, its customers
experienced an unusually frequent number of service outages versus Godaddy customers.
In the case of MED, we have reason to believe that both underinvestment AND insufficient spending on
quality control may have contributed to the problems with MED products. In this section, we focus on
why we believe the supply chain is suspect.
The Company claims that 100% of powders are made in the Owings Mills, MD Facility
According to the most recent 10K filing, MED manufactures all powder-based products at its
manufacturing facility located in Owings Mills, MD and subcontract the production of all other products:
This claim (as well as the claim powders = 42%-44% of sales) has been remarkably consistent over time:
MED 10K filings: 2013 2014 2015 2016 2017
Claim re: The Company’s facility in Owings The Company’s facility in Owings The Company’s facility in Owings The Company’s facility in Owings We manufacture all powder-
powder-based Mills, Maryland manufactures all Mills, Maryland manufactures all Mills, Maryland manufactures all Mills, Maryland manufactures all based products at our
products powder based products and the powder based products and the powder-based products and the powder-based products and the manufacturing facility located in
Company subcontracts the Company subcontracts the Company subcontracts the Company subcontracts the Owings Mills, Maryland and
production of all other products. production of all other products. production of all other products. production of all other products. subcontract the production of all
other products.
Claim re: % Jason Pharmaceuticals, Inc., the Jason Pharmaceuticals, Inc., the Jason Pharmaceuticals, Inc., the Jason Pharmaceuticals, Inc., the Jason Pharmaceuticals, Inc., the
powder-based Company’s wholly owned Company’s wholly owned Company’s wholly-owned Company’s wholly-owned Company’s wholly-owned
product manufacturing subsidiary, subsidiary, manufactures and subsidiary, manufactures and subsidiary, manufactures and subsidiary, manufactures and
manufactured produces approximately 44% of produces approximately 43% of produces all Medifast powder- produces all Medifast powder- produces all Medifast powder-
Medifast products in their Medifast products in their based products, which is based products, which accounts based products, which account
Employees & “coaches” we spoke with echo this claim. Summarized below are some of their comments:
manufacturing facility in Owings manufacturing facility in Owings approximately 42% of Medifast’s for approximately 43% of for approximately 42% of
Mills, Maryland. Mills, Maryland. product revenues, in the Medifast’s product revenues, in Medifast’s unit sales, in the
Employees and Coaches either echo or overstate this
manufacturing facility in Owings claim: the manufacturing facility in manufacturing facility in Owings
Optavia Coach Support Rep The Optavia packets say "Manufactured for Optavia". Are you saying they are both
Mills, made at the same facility?Owings
Maryland. "yes, yes"
Mills, Maryland. Mills, Maryland.
Are all Optavia products made in-house or are any of them made by 3rd parties? "No, none of them are made by 3rd parties"
So all of them are made at the Maryland, is it Owings Mills? "At the Owings Mills location, yes"
Optavia Coach #1 I'd like to know where the products are made, especially the Optavia chocolate and vanilla shake mixes. "all our products are made in the US! Baltimore, Maryland"
Optavia Coach #2 Who makes the shakes and other foods for this diet? "the products are made in our facility in Maryland"
Nutrition Support Supervisor "all of our powdered products come from Medifast"
"correct, we make none of the bars"
"the crunchy stuff is made elsewhere"
Nutrition Support Rep #1 "all of the products are manufactured in our manufacturing facility in Owings Mills"
"the ingredients might not be...but they are all brought to the manufacturing facility in Owings Mills to make the product, there"
Nutrition Support Rep #2 "we have a location in Owings Mills, they do that"
"we make the majority of our dried products. Most of our bars are made through our 3rd party manufacturing company"
Page 18 of 69
Medifast-branded powder box labels are consistent with the “100% of powders are made in the Owings
Mills, MD Facility” claim as well:
In case there’s any confusion: Jason Pharmaceuticals is a fully owned subsidiary of Medifast. That entity
name is often found in regulatory matters (see the FTC settlement from 2012, as an example). MED =
Jason Pharmaceuticals, Jason Pharmaceuticals = MED.
More than 40% of Medifast/Optavia’s supply may not be as the company represents
Gotham City Research believes 40%-82% of the company’s supply chain is suspect, and that this explains
– in part – the undisclosed toxic metals. We specifically believe that:
• Optavia-branded powders are made in an undisclosed location and/or made by a third party,
contrary to MED’s claim it manufacturers all its powders (42% of revenue) in Maryland.
• “Made in China” may be more substantively correct for some (possibly all) Medifast and Optavia
branded powders and bars, contrary to the unqualified “Made in USA” found on their labels.
Our investigation reveals the following:
• MED’s raw materials warehouse contained and/or contains Optavia branded powders that
appeared to be shipped from elsewhere.
• The box labels on Optavia branded powders state “manufactured for Optavia”, which is the
language that the FDA states should be used when the firm listed on the label is not the
manufacturer.
• Yet, Medifast branded powder labels state that MED is the manufacturer.
• Jason Pharmaceuticals Inc (Texas) is listed as a foreign importer of foods according to the FDA,
yet MED makes no mention of any manufacturing and warehousing activity outside of Maryland.
• Nellson Nutraceuticals, believed to be one of MED’s largest contract manufacturers, may be
manufacturing Optavia-branded powders for MED out of Utah.
• Nellson is suspect because the FDA has cited it multiple times and because Nellson appears to
source ingredients from China based on shipping records we reviewed.
• The unqualified “Made in the USA” claim may require modification, even removal in at least
some – possibly all – Optavia/Medifast products.
Page 19 of 69
Optavia Powder Products in the Arbutus Warehouse Indicate They were Not Made in Owings Mills
In August, we commenced an investigation into all MED’s facilities, including the raw materials warehouse
as described in the company’s 10K filing:
Our investigation into the raw materials warehouse reveals:
• The raw materials warehouse contains Optavia powder tubs that look like finished goods, in
contrast with all the other goods that look like raw ingredients in the warehouse.
• The Optavia tubs look like they were manufactured FOR the company…not BY the company.
• The Optavia tubs look like they were shipped from elsewhere.
• There are no manufacturing activities nor any manufacturing or packaging equipment in the
warehouse that might explain why finished goods would otherwise be found in this facility.
• The only other major equipment found in the facility are forklifts used to move boxes.
If the Company claims to manufacturer all its powdered products, why would it store finished good
Optavia powdered products in its raw materials warehouse in Arbutus?
Optavia powder box labels indicate “Manufactured for Optavia” NOT Manufactured by Optavia
The simplest explanation might be the obvious one: the Optavia powder pouches & boxes claim
‘manufactured for Optavia’, NOT manufactured BY Optavia:
Page 20 of 69
In contrast, the Medifast powder label does not contain similar “Manufactured for Medifast” language;
instead, its label conforms to FDA standards for indicating that the company itself is the manufacturer:
‘Manufactured for’ Indicates the firm listed on label is not the manufacturer: the FDA
We checked that language – “manufactured for Optavia” – with the FDA and found that the FDA offers
regulation and guidance on labeling, specifically regarding that ‘manufactured for’ phrase:
Page 21 of 69
All other Optavia-branded products (non powders) contain that ‘manufactured for Optavia’ language
found on the Optavia powder labels. This representation found on non powder Optavia product labels
seem compliant with the FDA guidance and regulations, AND consistent with Medifast/Optavia’s
representation that all products that are not powder-based are manufactured by third parties:
Page 22 of 69
Our due diligence reveals that Nellson LLC manufactures bars for MED, and possibly powders as well
Nellson LLC (also known as Nellson Nutraceuticals) describes itself as “the only full-service bar and powder
nutrition provider.” Nellson has powder operations in Utah, and significantly expanded these operations
on December 4, 2017, by acquiring Genysis (also based in Utah), a manufacturer of functional powders.
Here is what our investigation reveals about Nellson and its relationship with Medifast/Optavia:
• Nellson Nutraceuticals made or makes bars for Medifast/Optavia. Bars account for 40% of MED
revenue, making Nellson one of MED’s most important contract manufacturers.
• Medifast/Optavia formulated plans to shift powder product manufacturing to Nellson, under
certain situations.
• Medifast under the Jason Pharmaceuticals entity, may be conducting undisclosed warehousing
and/or manufacturing activities in Utah and Texas as discussed below.
If MED is secretly using Nellson to make bars, the following adverse facts would explain why the
Medifast would hide this information from the public:
• Nellson’s safety and quality control record is concerning, as evidenced by the total # of FDA
citations shown in the below table (Genysis and NBTY are fully owned subsidiaries of Nellson).
• Nellson products use a significant portion of its ingredients from China, per shipping records.
PIERS Country of Total PIERS Country of Origin = # of FDA

Entity Origin = China Records China (% of total) Citations
Nellson 85 97 87.6% 10
Genysis 268 269 99.6% 45
NBTY 282 382 73.8% 39
• Nellson filed for chapter 11 bankruptcy in 2008.

• Nellson is currently owned by a private equity firm and appears to be acquisitive (i.e. it’s
engaging in a roll-up strategy). In our experience, private equity owned, acquisitive companies
often face financial pressures that can compromise product quality and safety.
• Nellson represents the ability to pack powdered products in bulk tubs, bags, and sachets. Given
the parameters shown below, they would fit the specifications of Optavia sachets.
• Senior executives of Genysis don’t seem to have supply chain or manufacturing backgrounds
prior to their tenure at Genysis:
o VP of Manufacturing - https://www.linkedin.com/in/beau-stoker-81b9b582/
o Vice President of Supply Chain at Genysis Brand Solutions, pet foods
https://www.linkedin.com/in/scottdcrawford/?locale=de_DE
Page 23 of 69
Unreported Manufacturing + Warehouse Activities – MED’s Utah Operations May be the Missing Link
if all powders are NOT manufactured by Medifast at its Owings Mills, MD manufacturing facility, where
are they manufactured? Who manufactures them? Nellson? Utah may hold the answers. Here is what we
know so far about the ties between MED + Utah:
▪ Nellson makes bars for MED. Nellson may make powders for MED.
▪ Nellson’s powder activities are based in Utah and were expanded with the Gensys Acquisition.
▪ MED’s CEO Daniel Chard is from and (we believe) currently based in Utah.
Jason Pharmaceuticals Pursues Manufacturing Activities in Utah, according to Utah Corporate Filings
Jason Pharmaceuticals is a fully owned subsidiary of Medifast. That entity name is often found in
regulatory matters (see the FTC settlement from 2012, as an example). So just to avoid any conclusion:
MED = Jason Pharmaceuticals, Jason Pharmaceuticals = MED. According to a search for ‘Jason
Pharmaceuticals’ in Utah corporate filings, Jason Pharmaceuticals’ stated business purposes was
“manufacturing and selling of weight loss and management products”, as of September 2013:
In a Utah filing dated 12/07/2016, Jason Pharmaceuticals appears to have changed its NAICS – Business
Purpose to “Other Food Manufacturing”:
Page 24 of 69
How MED’s activities in Utah and Texas might explain the supply chain irregularities
The following facts might explain how MED has either (I) secret and undisclosed manufacturing activities
outside of Maryland, or (II) Nellson or another third party manufacturers powder based products for MED:
▪ Utah records suggest MED is conducting manufacturing activities in Utah.

▪ FDA records suggest MED is conducting dry goods warehousing activities in Texas.
▪ FDA records also suggest that MED is specifically importing foreign-sourced ingredients.
▪ MED has not disclosed either of these activities as occurring outside of Maryland, in its SEC filings.
▪ MED has disclosed distribution center and call center activities in Texas.
▪ Given Texas and Utah are in (relatively) proximity (especially relative to Maryland!), our
hypotheses would be plausible.
Jason Pharmaceuticals, Texas is listed as an importer of foreign food
The FDA has released a list of importers that import food from foreign suppliers:
Jason Pharmaceuticals, MD, and Jason Pharmaceuticals, TX are both listed as importers:
Source: https://www.fda.gov/food/guidanceregulation/importsexports/importing/ucm597095.htm
Page 25 of 69
The only Texas-based activities as described in the 10K, are related to a distribution center & call center:
Jason’s stated purpose of doing business in Texas: ‘to open a distribution center to handle product
shipments to/from our customers across the country (mainly west coast)’, consistent with SEC filings:
Page 26 of 69
Optavia and Medifast branded products claim “Made in the USA”
Optavia and Medifast branded products sport unqualified “Made in the USA” on their labels:
Page 27 of 69
Why Gotham City Research Believes MED Should Qualify its Made in the USA Claim (At Best)
The Federal Trade Commission, in its Enforcement Policy Statement on U.S. Origin Claims said:
IV. SUBSTANTIATING U.S. ORIGIN CLAIMS: THE "ALL OR VIRTUALLY ALL" STANDARD
Based on its review of the traditional use of the term "Made in USA," and the record as a whole, the
Commission concludes that consumers are likely to understand an unqualified U.S. origin claim to
mean that the advertised product is "all or virtually all" made in the United States. Therefore, when
a marketer makes an unqualified claim that a product is "Made in USA," it should, at the time the
representation is made, possess and rely upon a reasonable basis that the product is in fact all or
virtually all made in the United States.(12), (13)
A product that is all or virtually all made in the United States will ordinarily be one in which all
significant parts(14) and processing that go into the product are of U.S. origin. In other words, where
a product is labeled or otherwise advertised with an unqualified "Made in USA" claim, it should
contain only a de minimis, or negligible, amount of foreign content.
https://www.ftc.gov/public-statements/1997/12/enforcement-policy-statement-us-origin-claims
Based on our review of some of the MED products, we believe the company will at the very least modify
its labels. MED may have to labels the way Herbalife does ("Made in the USA with imported ingredients"):
https://edge.myherbalife.com/download/web/prodsku-label/locale_en_us/sku_3092/3092_label.pdf
In addition to scrutiny from the FTC, MED may face scrutiny and liability from the following:
• State-level requirements and restrictions against deceptive trade practices. It would not take
much for an attorney general to probe the toxic metals issue.
• Private party litigation and an active plaintiffs’ class-action bar.
Gotham City Research believes in the above stated opinions for the following reasons:
• At least 7 Optavia fuelings we’ve documented contain calcium caseinate as a main ingredient.
• Medifast imports calcium caseinate from Denmark-based Arla Foods, according to shipping
records.
• Yet all 7 of those fuelings containing calcium caseinate as a main ingredient unreservedly claim
“Made In the USA” on their product labels.
Shipping Records Reveal that Medifast imports Calcium Caseinate from Denmark (Arla Foods)
Page 28 of 69
Based on shipping records, Medifast imports calcium caseinate from Denmark’s Arla Foods…and in
significant amounts, as gauged by the weight in Kilograms:
PIERS Import Records from ARLA FOODS to Jason Pharmaceuticals

Arrival Date Country of Origin Shipper Consignee Consignee Address 1 Consignee Address 2 Weight (in Kg) Commodity Short Description
8/12/2018 DENMARK ARLA FOODS AMBA JASON PHARMACEUTICALS 11445 CRONHILL DRIVE OWINGS MILLS MD 21117 UNITED STATES 12,516 CALCIUM CASEINATE
The following products contain calcium caseinate; their labels unreservedly claim “Made in the USA”:
Name Ingredient Label claim

Optavia Caramel Macchiato Shake Calcium caseinate Made in the USA
Optavia Calorie Burn Cappuccino: Calcium caseinate Made in the USA
Optavia Velvety Hot Chocolate Calcium caseinate Made in the USA
Medifast Calorie Burn Cappuccino Calcium caseinate Made in the USA
Chipotle mac and cheese Calcium caseinate Made in the USA
Essential Velvety Hot Chocolate Calcium caseinate Made in the USA
Optavia Chocolate Fudge Pudding Calcium caseinate Made in the USA
Optavia Caramel Macchiato Shake (Calcium Caseinate is #1 ingredient!):
The below pictures show an example of one of the products listed above (amusingly, the order of sugar
and fructose are different between the actual product package and the ingredients listing on the Optavia
website). See the appendix for the remaining 6 examples whose labels we believe are deceptive.
Gotham City Research Believes Some MED Products Have More Ingredients From China than USA
Page 29 of 69
We believe some of Medifast/Optavia’s products – specifically its bars – may be more Made in China
than Made in the USA, as gauged by origin of ingredients, for the following reasons:
• Nellson LLC is believed to manufacture bars for MED and may make powders for MED (as
discussed previously).
• Bars account for 40% of MED revenue, making Nellson one of MED’s most important contract
manufacturers (we think top 2 largest among MED’s contract manufacturers).
• Nellson products are mostly made in China, at least if the proportion of supplies from China is a
fair proxy for the proportion of Chinese vs other origins.

Nellson 85 97 87.6% 10
Genysis 268 269 99.6% 45
NBTY 282 382 73.8% 39
We see two scenarios, both of which are concerning from a product safety + quality perspective, and
both would explain a lot:
• Nellson is a significant manufacturer of Medifast/Optavia’s powders and bars. Given the large
number of FDA citations that Nellons and its subsidiaries have received, this is concerning.
• Nellson-made goods are composed mostly of China sourced ingredients and then mixed in the
USA.
Why Does Medifast Unreservedly Claim Made in the USA?
Here are the reasons Medifast might unreservedly claimed “Made in the USA” on its products:
• US government officials may view the company more favorably, if they believe that MED’s
“Made in the USA” representations are true.
• Prospective customers, with a preference for American made goods, might be enticed to
purchase their products; existing customers might remain more loyal than they otherwise would
if they knew the products’ ingredients were largely sourced from the United States.
• Consumers might perceive “Made in the USA” as a premium trait, and therefore be less
skeptical about Optavia’s aggressive pricing premiums versus its peers.
Page 30 of 69
Possible causes Part II: Underinvestment
Underinvestment may also explain product safety and quality concerns
Other than a suspect supply chain, which would largely explain product safety and quality issues at
Medifast, why else would Optavia fuelings contain undisclosed toxic metals? Particularly, why would they
contain undisclosed toxic metals in excess of most similar goods, everyday foods, and regulatory
standards? These are significant anomalies, in our view.
We have observed that underinvestment or insufficient spending on quality control can lead to problems.
We saw this problem with a web hosting company called Endurance International Group. Endurance had
spent far less on core intrastructure spending versus its primary competitor, Godaddy. Consequently, its
customers experienced an unusually frequent number of service outages versus Godaddy customers.
Gotham City Research believes that other than the supply chain issues discussed, underinvestment and a
cultural shift away from R&D and towards marketing contribute to quality and safety concerns. The
following support our opinions:
• Property, plant and equipment have declined more than 50% over the last 5 years.
• MED’s Capex + R&D spend as a percentage of revenue is less than half that of its peers.
• Disclosed intellectual property assets on the balance sheet have declined to zero.
• Concurrently, stock buy backs and dividends have increased 3x.
• Mention of the word ‘patent’ has disappeared from MED 10K filings.
Property, plant and equipment declined over 50% from $40 million to $18-$19 million:
The company’s property, plant, and equipment (net) balance has declined by over 50%, from over $40
million as of 2012, to $18 million of June 2018:
MED's PP&E has declined every single year since 2012

USD, in MMs Dec'12 Dec'13 Dec'14 Dec'15 Dec'16 Dec'17 Jun'18
Net PP&E 40.109 34.476 33.477 29.029 19.753 18.611 18.22
% YoY Change (14.0%) (2.9%) (13.3%) (32.0%) (5.8%) (1.5%)
Herbalife and other peers spend over 2x more on capital expenditures and research & development:
Herbalife has been criticized for underspending on R&D and capex, but it spent twice as much on R&D
and capex as % revenue than MED did, per our estimates. The same goes for the rest of the peers:
Net CapEx + R&D as % of revenue 2015 2016 2017

MED 1.69% 1.53% 1.55%
Peer Group 3.60% 4.07% 3.38%
Peer Investment Relative to MED 2.13x 2.66x 2.19x
Peer Group: Nu Skin, USANA, Herbalife, Weight Watchers, Nutrisystem
Page 31 of 69
Underinvestment and stock buybacks compromise product quality and safety
Instead of significantly boosting capex or R&D spending, which might improve product safety and
quality, MED has chosen instead to dramatically boost stock buybacks and dividends:
MED Share Repurchases and Cash Dividends
USD, in MMs 2015 2016 2017 2018 YTD
Share Repurchases $10.5 $0.0 $0.0 $20.0
Net Shares Repurchased for Employee Taxes $1.3 $1.3 $2.5 $0.2
Cash Dividends Paid to Stockholders $0.0 $11.9 $15.4 $11.7
Total $11.8 $13.2 $17.9 $31.9
Intellectual property assets have disappeared from the MED Balance Sheet
As of 2012, MED had intellectual property assets on its balance sheet:
The value declined to zero by 2013. By 2016/2017 that asset category disappeared altogether:
Trademarks and Intangibles in 2002 used to provide higher balances and disclosures:
Mention of the word ‘patent’ has declined from 10 mentions in the 2002 10K to zero recently:
10K Filing Year: 2002 2013 2017

Mentions of the word "patent": 10 5 0
Page 32 of 69
Allergens, Cadmium, and Other Safety Concerns
Safety Concerns are Not Limited to Lead
Gotham City Research believes that the product quality and safety concerns are not limited to the lead
related findings, covered earlier in this report. Here are other causes for concern:
• Optavia products that were tested contain cadmium, in levels that exceed most other peer
products and nearly all everyday foods tested by the FDA.
• Optavia products may contain more exposure to allergens then disclosed in its labeling.
• The FDA citation record for two companies believed to MED’s largest contract manufacturers is
very concerning.
• Optavia does not recommend eating fruit, as part of its 5 for 1 plan.
• Cigarette smokers are exposed to toxic metals in cigarettes and may be more vulnerable to
consuming Optavia products.
Optavia and Medifast Products and Allergens: the Coverup is Worse Than the Crime
Medifast/Optavia warned its top performing sales force (those who generate revenue) that the Company
has all major allergens in its manufacturing facility in Owens Mills, Maryland:
Archived here: https://web.archive.org/web/20180815034449/http://www.optaviaevents.com/new-

fibc-summit-august.html
In fact, the GMP Agreement the company asks guests to sign before allowing them to tour the
manufacturing facility, states:
• we handle all major allergens (except shellfish)

• IF YOU HAVE ANY TYPE OF FOOD ALLERGY DO NOT ENTER THE MANUFACTURING FACILITY
MED does not provide the same warnings to its customers as it does to its revenue generators
Medifast/Optavia’s allergen disclosures do not afford customers the same degree of caution as the
company has to its top producers; the company makes no such representations that its products are
manufactured in a facility that contains allergens, in either the product labels or its websites, based on
our examination. The inconsistent disclosure is not consistent with industry norms.
Page 33 of 69
For example, we found that the following companies provide advisory disclosures when there is a risk that
allergens may be present during the manufacturing process:
• Herbalife voluntarily discloses when a product it sells was produced in a facility that processes
nuts or gluten or milk http://herbalife.custhelp.com/app/answers/detail/a_id/684/~/eight-
major-allergens
• Nutrisystem states that those with peanut allergies, mild or severe, cannot be on its program
https://leaf.nutrisystem.com/faqs/diet-food-nutrition-and-science/nutrisystem-diet-food-
peanuts/
• Nutrisystem also lists peanut, soy, and latex allergies as reasons not to use its program
https://www.nutrisystem.com/pdf/Information_for_your_doctor.pdf
If Optavia and Medifast branded products are manufactured in the same Owings Mills manufacturing
facility where visiting salespeople are explicitly instructed not to enter (if they have any allergies) then:
Why doesn’t the company provide its customers with the same degree of courtesy as it does to its visiting
salespeople?
Optavia’s allergen disclosure practices may be legally permissible, but these practices don’t seem
consistent with the practices of a premium, safety-first brand.
Cadmium levels tested exceed the maximum allowable dosage level by 178%
If a customer were to adhere to the 5 in one 1 Plan, and consume Optavia products that contain the same
amount of cadmium as those that were tested, their daily consumption would exceed the maximum
allowable dosage level of 4.1 µg/day by 178%, on average:
Cadmium Cadmium Cadmium

Concentration per Serving per Day
Report Date Sample # (µg/kg) (in µg) (in µg)
8/17/2018 Sample: 1 35 1.12 5.60
8/17/2018 Sample: 2 96 3.07 15.36
8/22/2018 Sample: 3 34 1.09 5.44
8/22/2018 Sample: 4 23 0.74 3.68
8/22/2018 Sample: 5 20 0.64 3.20
8/22/2018 Sample: 6 70 2.10 10.50
AVERAGE 46 1.46 7.30
We believe Medifast should be providing a warning level regarding cadmium, particularly in this case
because it sells the products as part of diet plan, and whose adherence would lead to consumption of
cadmium exceeding the Prop 65 levels.
Page 34 of 69
The Optavia product samples contained more Cadmium than most tested protein products
The Optavia samples that were tested contain more cadmium than 76% of comparable protein products
as tested by the Clean Label Project. The below graph shows the worst Optavia sample, which contains
more cadmium than 91% of its peers:
330
320
310
300
290
280
270
260
250
240
230
220
210
Cadmium level in ug/kg
200
190
180
170
160
150
140
130
120
110
Optavia Sample #2
100
90
80
70
60
50
40
30
20
10
0
1 4 7 10 13 16 19 22 25 28 31 34 37 40 43 46 49 52 55 58 61 64 67 70 73 76 79 82 85 88 91 94 97 100 103 106 109 112 115 118 121 124 127 130 133
Clean Label Project Protein Powders Optavia
The Optavia samples contain more Cadmium than nearly all foods tested by the FDA for Cadmium
The Optavia products tested contain more cadmium than 97% of everyday foods that were tested by the
FDA for cadmium. While the relative ranking is not as bad as it was for lead – as the Optavia products
contained more lead than ALL the everyday foods – Optavia’s ranking is still very poor:
No.
CADMIUM 343 Sunflower seeds (shelled), roasted, salted 32 0 0 0.389 0.120 0.379 0.215 0.874 0.003 0.010
CADMIUM 107 Spinach, fresh/frozen, boiled 32 0 0 0.183 0.226 0.122 0.038 1.100 0.002 0.005
CADMIUM 357 Lettuce, leaf, raw 32 0 0 0.066 0.038 0.058 0.012 0.175 0.001 0.004
CADMIUM 27 Liver (beef/calf), pan-cooked with oil 32 0 0 0.056 0.036 0.045 0.021 0.171 0.003 0.010
CADMIUM 138 Potato chips 32 1 0 0.054 0.029 0.052 0 0.145 0.003 0.010
CADMIUM 73 Shredded wheat cereal 32 0 0 0.054 0.013 0.053 0.035 0.081 0.002 0.007
CADMIUM 109 Lettuce, iceberg, raw 32 0 0 0.051 0.035 0.039 0.010 0.157 0.001 0.004
CADMIUM 48 Peanuts, dry roasted, salted 32 0 0 0.044 0.018 0.038 0.020 0.084 0.003 0.010
CADMIUM 108 Collards, fresh/frozen, boiled 32 0 0 0.043 0.063 0.028 0.010 0.368 0.002 0.005
CADMIUM 258 French fries, fast-food 32 0 0 0.042 0.014 0.039 0.022 0.072 0.003 0.010
Page 35 of 69
Hearthside Food Solutions and Nellson LLC – very concerning FDA citation record
Standard Functional Foods Group (now known as Hearthside Food Solutions) and Nellson LLC are believed
to be the two largest Medifast contract manufacturers. Both of their FDA citation histories are very
concerning:
10 FDA citations for Nellson (far more under its subsidiaries’ names):
Inspection
End Date Firm Name City State Act/CFR Number Full Description
3/10/2014 Nellson Nutraceutical, Inc. (Powder Division) Salt Lake City UT 21 CFR 111.205(a) You did not prepare and follow a written master manufacturing record for each batch size of a
dietary supplement that you manufactured.
3/10/2014 Nellson Nutraceutical, Inc. (Powder Division) Salt Lake City UT 21 CFR 111.210(f) Your master manufacturing record did not include a statement of the theoretical yield for each
point, step, or stage of the manufacturing process to ensure quality control and the expected yield
of the finished dietary supplement.
3/10/2014 Nellson Nutraceutical, Inc. (Powder Division) Salt Lake City UT 21 CFR 111.210(h)(5) The written instructions in your master manufacturing did not include instructions for corrective
action plans to use when specifications are not met.
3/10/2014 Nellson Nutraceutical, Inc. (Powder Division) Salt Lake City UT 21 CFR 111.260(j)(2) Your batch production records did not include initials of the persons performing each step.
3/10/2014 Nellson Nutraceutical, Inc. (Powder Division) Salt Lake City UT 21 CFR 111.260(b) Your batch production records did not include the identity of equipment and processing lines used
in producing the batch.
3/10/2014 Nellson Nutraceutical, Inc. (Powder Division) Salt Lake City UT 21 CFR 111.210(h)(1) The written instructions in your master manufacturing record did not include specifications for
each point, step, or stage in the manufacturing process where control is necessary to ensure the
quality of the dietary supplement.
11/21/2012 Nellson Nutraceutical, LLC Irwindale CA 21 CFR 110.40(b) Failure to have smoothly bonded or well maintained seams on food contact surfaces, to minimize
accumulation of food particles, dirt, and organic matter and the opportunity for growth of
microorganisms.
1/20/2010 Nellson Nutraceutical, Inc. (Powder Division) Salt Lake City UT 21 CFR 111.210(g) Your master manufacturing record did not include a a representative label, or a cross-reference to
the physical location of the actual or representative label.
1/20/2010 Nellson Nutraceutical, Inc. (Powder Division) Salt Lake City UT 21 CFR 111.260(j)(2) Your batch production records did not include initials of the persons performing each step.
1/20/2010 Nellson Nutraceutical, Inc. (Powder Division) Salt Lake City UT 21 CFR 111.27(a) You did not use equipment or utensils of appropriate design, construction, and workmanship to
enable them to be adequately cleaned.
22 FDA citations for Hearthside:

Inspection
6/24/2013 Hearthside Food Solutions, LLC Kentwood MI 21 CFR 110.35(a) Failure to maintain buildings, fixtures, or other physical facilities in a sanitary condition.
6/24/2013 Hearthside Food Solutions, LLC Kentwood MI 21 CFR 110.37(b)(3) Plumbing constitutes a source of contamination to water supplies.
6/24/2013 Hearthside Food Solutions, LLC Kentwood MI 21 CFR 110.40(a) The use of equipment and utensils fails to preclude the adulteration of food with contaminants.
3/12/2012 Hearthside Food Solutions Kentwood MI 21 CFR 110.37(b)(5) Systems that discharge waste water or sewage are cross-connected to systems that carry water
for food or food manufacturing.
4/23/2010 Hearthside Food Solutions, Llc Grand Rapids MI 21 CFR 110.80(b)(7) Failure to construct, handle, and maintain equipment, containers and utensils used to convey
food in a manner that protects against contamination.
4/23/2010 Hearthside Food Solutions, Llc Grand Rapids MI 21 CFR 110.37(b)(5) Lack of backflow protection from piping systems that discharge sewage.
4/16/2010 Hearthside Food Solutions, LLC Nashville TN 21 CFR 110.10(b)(5) Gloves used in food handling are not maintained in an intact, clean, and sanitary condition.
4/16/2010 Hearthside Food Solutions, LLC Nashville TN 21 CFR 110.37(e) Hand-washing facilities lack running water of a suitable temperature.
4/16/2010 Hearthside Food Solutions, LLC Nashville TN 21 CFR 110.10(b)(1) Suitable outer garments are not worn that protect against contamination of food and food
packaging materials.
3/15/2010 Hearthside Food Solutions, LLC Lakeville MN 21 CFR 211.188(b)(8) Batch production and control records do not include complete labeling control records,
including specimens or copies of all labeling used for each batch of drug product produced.
3/15/2010 Hearthside Food Solutions, LLC Lakeville MN 21 CFR 211.137(a) Drug products do not bear an expiration date determined by appropriate stability data to
assure they meet applicable standards of identity, strength, quality and purity at the time of
use.
3/15/2010 Hearthside Food Solutions, LLC Lakeville MN 21 CFR 211.84(d)(6) Each lot of a component liable to objectionable microbiological contamination is deficiently
subjected to microbiological tests before use.
3/15/2010 Hearthside Food Solutions, LLC Lakeville MN 21 CFR 211.25(a) Employees engaged in the manufacture, processing, packing, and holding of a drug product lack
the education, training, and experience required to perform their assigned functions.
3/15/2010 Hearthside Food Solutions, LLC Lakeville MN 21 CFR 211.84(d)(2) Establishment of the reliability of the component supplier's report of analyses is deficient in
that the test results are not appropriately validated at appropriate intervals.
3/15/2010 Hearthside Food Solutions, LLC Lakeville MN 21 CFR 211.68(b) Input to and output from the computer are not checked for accuracy.
3/15/2010 Hearthside Food Solutions, LLC Lakeville MN 21 CFR 211.125(f) Procedures describing in sufficient detail the controls employed for the issuance of labeling are
not written.
3/15/2010 Hearthside Food Solutions, LLC Lakeville MN 21 CFR 211.198(a) Procedures describing the handling of written and oral complaints related to drug products are
not written or followed.
3/15/2010 Hearthside Food Solutions, LLC Lakeville MN 21 CFR 211.186(a) The master production and control records for each batch size of drug product are not
prepared, dated, and signed by one person with a full handwritten signature and independently
checked, dated, and signed by a second person.
3/15/2010 Hearthside Food Solutions, LLC Lakeville MN 21 CFR 211.22(a) The quality control unit lacks the responsibility and authority to approve and reject all
components, drug product containers, closures, in process materials, packaging material,
labeling, and drug products.
3/15/2010 Hearthside Food Solutions, LLC Lakeville MN 21 CFR 211.22(d) The responsibilities and procedures applicable to the quality control unit are not in writing.
3/15/2010 Hearthside Food Solutions, LLC Lakeville MN 21 CFR 211.166(a) There is no written testing program designed to assess the stability characteristics of drug
products.
3/15/2010 Hearthside Food Solutions, LLC Lakeville MN 21 CFR 211.67(b) Written procedures are not established for the cleaning and maintenance of equipment,
including utensils, used in the manufacture, processing, packing or holding of a drug product.
Page 36 of 69
45 FDA citations for Nellson under its Genysis subsidiary:
Inspection
3/3/2017 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.95(b)(2) You did not make and keep documentation of your qualification of a supplier.
3/3/2017 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.553 You did not follow written procedures for the requirements to review and investigate a product
complaint.
3/3/2017 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.15(i) Your hand-washing facilities do not furnish running water at a suitable temperature.
3/3/2017 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.15(d)(2) You did not take effective measures to protect against contamination of components, dietary
supplements, and contact surfaces on the premises by pests.
3/5/2014 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.15(i) Your hand-washing facilities are not adequate.
3/5/2014 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.75(c) You did not verify that your finished batch of dietary supplement meets product specifications for
purity and limits on contamination that may adulterate or that may lead to adulteration of the
dietary supplement.
3/5/2014 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.10(b) Your personnel did not use hygienic practices to the extent necessary to protect against
contamination of components, dietary supplements, or contact surfaces.
3/5/2014 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.255(b) Your batch production record did not include complete information relating to the production and
control of each batch.
4/8/2013 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.25(c) You did not establish written procedures for maintaining, cleaning, and sanitizing, equipment,
utensils, and any other contact surfaces that are used to manufacture, package, label, or hold
components or dietary supplements.
4/8/2013 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.27(b) You did not calibrate instruments or controls used in manufacturing or testing a component or
dietary supplement at the frequency specified in writing by the manufacturer or at routine
intervals or as necessary to ensure the accuracy and precision of the instruments or controls.
4/8/2013 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.255(b) Your batch production record did not include complete information relating to the production and
control of each batch.
4/8/2013 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.95(b)(2) You did not make and keep documentation of your qualification of a supplier.
4/8/2013 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.130(d) Your quality control operations for returned dietary supplements did not include determining
whether a reprocessed dietary supplement meets product specifications and either approving for
release, or rejecting, any returned dietary supplement that was reprocessed.
4/8/2013 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.16 You did not follow written procedures for pest control.
strength and composition.
4/8/2013 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.155(e) You did not hold components under conditions that will protect against contamination.
4/8/2013 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.15(d)(2) You did not take effective measures to exclude pests from the physical plant.
4/8/2013 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.12 The personnel you identified to perform quality control operations do not have the education,
training or experience to perform the assigned functions.
4/8/2013 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 110.10(c) Appropriate training in food handling techniques and food protection principles has not been
provided to food handlers.
4/8/2013 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.205(a) You did not prepare and follow a written master manufacturing record for each batch size of a
dietary supplement that you manufactured.
4/8/2013 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.353 You did not establish written procedures for manufacturing operations.
4/8/2013 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.315(d) You did not establish and follow laboratory control processes for use of criteria for selecting
standard reference materials used in performing tests and examinations.
4/8/2013 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.403 You did not establish written procedures for labeling operations.
4/8/2013 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.453 You did not establish procedures for holding and distributing operations.
4/8/2013 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.403 You did not establish written procedures for packaging operations.
6/15/2010 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.35(b)(4) You did not make and keep written records of calibrations, inspections, or checks of automated,
mechanical, or electronic equipment.
identity.
6/15/2010 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.403 You did not establish written procedures for packaging operations.
6/15/2010 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.403 You did not establish written procedures for labeling operations.
6/15/2010 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.103 You did not establish and follow written procedures for quality control operations.
6/15/2010 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.75(a)(2) You did not conduct appropriate tests or examinations or rely on a certificate of analysis to
determine whether components met established specifications.
6/15/2010 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.70(e) You did not establish product specifications for the strength and composition of the finished
dietary supplement.
6/15/2010 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.535(b)(4) You did not make and keep records of documentation of the reevaluation by quality control
personnel of a dietary supplement that was reprocessed and of the determination by quality
control personnel of whether the reprocessed dietary supplement met established product
specifications.
6/15/2010 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.205(a) You did not prepare a written master manufacturing record for each batch size of a dietary
supplement that you manufactured.
6/15/2010 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.210(f) Your master manufacturing record did not include a statement of the theoretical yield for each
point, step, or stage of the manufacturing process to ensure quality control
6/15/2010 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.210(h)(5) The written instructions in your master manufacturing did not include instructions for corrective
action plans to use when specifications are not met.
6/15/2010 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.117(b) Your quality control operations did not include periodically reviewing all records for calibration of
instruments and controls.
6/15/2010 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.353 You did not establish and follow written procedures for manufacturing operations.
6/15/2010 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.155(e) You did not hold components under conditions that will protect against contamination.
6/15/2010 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.30(e) You did not establish appropriate controls to ensure that your automated, mechanical, or
electronic equipment functions in accordance with its intended use.
6/15/2010 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.503 You did not establish and follow written procedures for when a returned dietary supplement is
received.
6/15/2010 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.15(d)(2) You did not take effective measures to exclude pests from the physical plant.
6/15/2010 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.15(i) Your hand-washing facilities do not furnish running water at a suitable temperature.
6/15/2010 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.8 You did not establish written procedures for determining personnel qualification requirements.
6/15/2010 VMI Nutrition, Inc. dba Genysis Brand Solutions Salt Lake City UT 21 CFR 111.25(c) You did not establish written procedures for maintaining, cleaning, and sanitizing, equipment,
utensils, and any other contact surfaces that are used to manufacture, package, label, or hold
components or dietary supplements.
Page 37 of 69
39 FDA citations for Nellson under its NBTY subsidiary:
Inspection
9/27/2016 NBTY, Inc. Boca Raton FL 21 CFR 111.75(b)(1) You did not monitor the in-process points, steps, or stages, where control is necessary to ensure
that the quality of the finished batch of dietary supplement, to determine whether the in-
process specifications are met.
9/27/2016 NBTY, Inc. Boca Raton FL 21 CFR 111.260(e) Your batch production records did not include the weight or measure of each component used.
12/20/2013 NBTY Inc. Bohemia NY 21 CFR 111.325(a) You did not make and keep written procedures for laboratory operations.
9/21/2012 NBTY, Inc. Boca Raton FL 21 CFR 211.198(b) Complaint procedures are deficient in that written complaint files are not maintained at the
manufacturing site nor were they readily available from their off-site location.
9/21/2012 NBTY, Inc. Boca Raton FL 21 CFR 211.192 Drug product production and control records, are not reviewed and approved by the quality
control unit to determine compliance with all established, approved written procedures before
a batch is released or distributed.
9/21/2012 NBTY, Inc. Boca Raton FL 21 CFR 211.125(b) Labeling materials issued for a batch were not carefully examined for identity and conformity to
the labeling specified in the master or batch production records.
9/21/2012 NBTY, Inc. Boca Raton FL 21 CFR 211.122(c) Records kept for each different labeling and packaging material shipment fail to include the
receipt and a statement of whether the shipment was accepted or rejected.
9/21/2012 NBTY, Inc. Boca Raton FL 21 CFR 111.10(b)(1) Your personnel did not wear outer garments in a manner that protects against contamination
of components, dietary supplements or contact surfaces.
9/21/2012 NBTY, Inc. Deerfield Beach
FL 21 CFR 111.415 You did not fill in a way that ensured that the dietary supplement is packaged and labeled as
specified in the master manufacturing record.
9/21/2012 NBTY, Inc. Deerfield Beach
FL 21 CFR 111.10(b) Your personnel did not use hygienic practices to the extent necessary to protect against
contamination of components, dietary supplements, or contact surfaces.
9/13/2012 NBTY Manufacturing LLC d/b/a Capsuleworks Bayport NY 21 CFR 111.15(f)(5) The plumbing in your physical plant allows backflow from and cross connection between piping
systems that discharge waste water or sewage and piping systems that carry water used for
manufacturing dietary supplements, for cleaning contact surfaces, or for use in bathrooms or
hand-washing facilities.
9/13/2012 NBTY Manufacturing LLC d/b/a Capsuleworks Bayport NY 21 CFR 111.210(h)(1) The written instructions in your master manufacturing record did not include specifications for
each point, step, or stage in the manufacturing process where control is necessary to ensure the
quality of the dietary supplement.
9/13/2012 NBTY Manufacturing LLC d/b/a Capsuleworks Bayport NY 21 CFR 111.360 You did not conduct manufacturing operations in accordance with adequate sanitation
principles.
9/13/2012 NBTY Manufacturing LLC d/b/a Capsuleworks Bayport NY 21 CFR 111.205(c) You did not keep a master manufacturing record for the required time period.
9/13/2012 NBTY Manufacturing LLC d/b/a Capsuleworks Bayport NY 21 CFR 111.15(i) Your hand-washing facilities are not adequate.
9/13/2012 NBTY Manufacturing LLC d/b/a Capsuleworks Bayport NY 21 CFR 111.10(b)(3) Your personnel did not thoroughly wash and wash and sanitize their hands in an adequate
hand-washing facility at any time when the hands may have become soiled or contaminated.
7/19/2012 NBTY Acquisition LLC Garden Grove CA 21 CFR 111.260(b) Your batch production records did not include the identity of equipment and processing lines
used in producing the batch.
7/2/2012 NBTY, Inc. and subsidiaries Bohemia NY 21 CFR 111.303 You did not establish and follow written procedures for the tests and examinations conducted
to determine whether specifications are met.
7/2/2012 NBTY, Inc. and subsidiaries Bohemia NY 21 CFR 111.260(e) Your batch production records did not include the weight or measure of each component used.
7/2/2012 NBTY, Inc. and subsidiaries Bohemia NY 21 CFR 111.210(g) Your master manufacturing record did not include a description of the packaging and a
representative label, or a cross-reference to the physical location of the actual or representative
label.
7/2/2012 NBTY, Inc. and subsidiaries Bohemia NY 21 CFR 111.10(b)(3) Your personnel did not thoroughly wash their hands in an adequate hand-washing facility
before starting work.
7/2/2012 NBTY, Inc. and subsidiaries Bohemia NY 21 CFR 111.20(d)(1)(iv)Your physical plant did not have equipment that controls temperature and humidity when it is
necessary to ensure the quality of the dietary supplement.
5/29/2012 NBTY, Inc. dba Leiner Health Products Valencia CA 21 CFR 123.10 No one associated with your firm has completed the required HACCP training or is HACCP
qualified through job experience.
5/29/2012 NBTY, Inc. dba Leiner Health Products Valencia CA 21 CFR 111.260(g) Your batch production records did not include the actual results obtained during a monitoring
operation.
3/1/2012 NBTY, Inc. Bohemia NY 21 CFR 1250.42(a) A water system not protected against backflow.
3/1/2012 NBTY, Inc. Bohemia NY 21 CFR 110.10(b)(9) Failure to take necessary precautions to protect against contamination of food with foreign
substances.
3/1/2012 NBTY, Inc. Bohemia NY 21 CFR 111.180(b)(3) You did not make and keep documentation that the requirements that apply to production and
process control for components of dietary supplements were met.
3/1/2012 NBTY, Inc. Bohemia NY 21 CFR 111.60(b) Your production and in-process control system was not reviewed and approved by quality
control personnel.
10/29/2010 Nutro Laboratories, a div of NBTY, Inc. S Plainfield NJ 21 CFR 111.70(b)(2) You did not establish component specifications for composition.
10/29/2010 Nutro Laboratories, a div of NBTY, Inc. S Plainfield NJ 21 CFR 111.455(a) You did not hold components under appropriate conditions of temperature, humidity, or light
so that their identity, purity, strength, and composition are not affected.
10/29/2010 Nutro Laboratories, a div of NBTY, Inc. S Plainfield NJ 21 CFR 111.70(c)(2) You did not provide adequate documentation of your basis for why meeting the in-process
specifications, in combination with meeting component specifications, will help ensure that the
specifications are met for limits on contamination that may adulterate or may lead to
adulteration of the finished dietary supplement.
10/29/2010 Nutro Laboratories, a div of NBTY, Inc. S Plainfield NJ 21 CFR 111.75(a)(2)(ii)(A)
You did not qualify a supplier of a component by establishing the reliability of the supplier's
certificate of analysis through confirmation of the results of their tests or examinations.
8/23/2010 Nutro Laboratories, a div of NBTY, Inc. S Plainfield NJ 21 CFR 111.453 You did not follow written procedures for holding and distributing operations.
6/3/2010 NBTY, Inc. Bohemia NY 21 CFR 1250.42(a) A water system not protected against backflow.
6/3/2010 NBTY, Inc. Bohemia NY 21 CFR 110.35(b)(1) Use of cleaning compounds and sanitizing agents which are not safe and adequate under the
conditions of use.
6/3/2010 NBTY, Inc. Bohemia NY 21 CFR 111.27(b) You did not calibrate instruments or controls used in manufacturing or testing a component or
dietary supplement to ensure the accuracy and precision of the instruments or controls.
6/3/2010 NBTY, Inc. Bohemia NY 21 CFR 111.360 You did not conduct manufacturing operations in accordance with adequate sanitation
principles.
6/3/2010 NBTY, Inc. Bohemia NY 21 CFR 111.180(b)(3) You did not make and keep documentation that the requirements that apply to production and
process control for components of dietary supplements were met.
6/3/2010 NBTY, Inc. Bohemia NY 21 CFR 111.255(c) Your batch production record did not accurately follow the appropriate master manufacturing
record.
Page 38 of 69
Optavia and its Unhealthy Habits for Life
Questions: Is it true that fruit is not allowed under the Optavia diet?
Answer: One could infer this based upon the guidelines of MED’s 5 and 1 weight loss plan. On the 5
and 1 plan, no fruits are listed on the approved snack list (note sugar free appears to be emphasized). No
fruits would be consumed in the lean and green meal either since this consists of a protein and veggie dish.
http://answers.optavia.com/help/optimal-weight-5-1-plan-what-snacks-can-i-have
Questions: Given that cigarettes contain high levels of toxic metals, does Optavia provide any warning
for smokers?
Answer: The Company does not address the danger of simultaneously smoking and adhering to the
Optavia 5 in 1 plan, from a toxic metals perspective. It provides a generic answer about smoking instead:
http://www.medifast1.com/faqs/starting_your_medifast_program.jsp
To read more about toxic metals in cigarettes please read:

https://iubmb.onlinelibrary.wiley.com/doi/pdf/10.1080/15216540500459667?cookieSet=1
Page 39 of 69
Valuation: shares are worth no more than $79 per share
The art of valuation is only as good as the assumptions behind one’s calculations. As a result, we are not
dogmatic about artificial precision. We do strongly believe, however, that investors’ interests are served
best when they seek to understand the quality of the company, its true business model, and value drivers.
Because we believe MED sales are inflated for the concerns discussed in this report, we believe product
quality and safety concerns will be the primary drivers of MED’s long-term value. Other considerations –
such as pyramid scheme allegations or their ambitions in China – will pale in comparison.
As a result, Gotham City Research believes MED shares face significant downside. We believe shares are
worth no more than $79 per share and arrive at a price target between $30 and $79 per share.
Our price target may seem low at first glance, yet this would place shares just where they were trading 6
months ago – the same price levels that the activist investor completely sold their stake.
Valuation Method and Assumptions: scenarios-based approach
We don’t believe that Medifast/Optavia is a true “growth at any price” company, as it has been perceived
to be in recent quarters, for the following reasons:
• The Weight loss industry is an old and cyclical industry, driven by fads and the flavor du jour
(anyone remember the Atkins Diet? Or South Beach?). Easy come, easy go.
• The Weight loss industry is highly competitive. We see some very capable operators in the space,
as well as some very compelling alternative diet solutions.
• MLMs exhibit low quality of earnings, like highly levered companies, and investors tend to
(astutely) pay below-market multiples for businesses exhibiting such unstable earnings.
Our weighted average price target of $79 is arrived at by a 3-scenario approach:
EPS Multiple Probability Price

Bull Scenario $6.00 30.0x 15% $180
Base Scenario $4.00 17.0x 70% $68
Boom Bust Scenario $2.00 15.0x 15% $30
Weighted average price target: $79

Price, as of 9/19/2018: $208
Downside risk : -62%
Downside risk : -86%
• Bull scenario – Consumers and coaches disregard product quality and safety concerns and
earnings rise year-over-year in 2019. A 30x multiple, nearly double that of S&P 500’s multiple,
seems appropriate. We assign a 15% probability to this scenario.
• Base scenario – Some Optavia customers and coaches show concern for product safety and
quality issues. Sales plateau, but do not crash. Due to MED’s MLM feature and margin pressures
resulting from the concerns (e.g. increased spending on capex and R&D, simply to conform to
industry levels) earnings decline despite flat (or slightly up/down) sales. Consequently, MED’s P/E
multiple normalizes to the market multiple of 17x. We assign a 70% probability here.
Page 40 of 69
3-scenario approach (continued):
• Boom bust scenario – In this scenario, consumers and coaches show concern for product safety
and quality issues. Other problems related to product safety and concern not addressed in this
report arise. Sales earnings decline modestly to 2017 levels. We conservatively apply a 15x P/E
multiple in this case.
Additional Valuation Considerations – Legal/Regulatory, and China
Gotham City Research believes there are two important considerations – wild card – that may prove to
be important value drivers for the stock in coming quarters:
• Legal/Regulatory – Our 3-scenarios approach does not incorporate any product liability, personal
injury lawsuits, regulatory action, or increased costs resulting from additional quality assurance
requirements (beyond normalization of MED’s R&D + capex spending to peers’ levels).
Based on the company’s and its peers’ history with various regulators, significant financial
penalties, private litigation settlements, legal costs, and restrictions on marketing activities, are
very credible and realistic outcomes. In our opinion, these will happen as the result of the
company’s actions, especially given that MED has been given many 2nd chances to clean up its act.
Out of an abundance of caution, however, we are short MED shares assuming none of these
transpire. Those adverse scenarios would lower the range of our estimates for intrinsic value.
• China Plans – The company has announced that it intends to expand into China next year. The
financial markets have expressed enthusiasm into these plans, as evidenced by MED’s stock price
this year. MED may or may not gain traction in China: no one knows. Here is why we are skeptical:
▪ The financial markets may have a short attention span, but MED’s historical attempts to
penetrate this market have all failed to persist.
▪ Chinese officials and consumers are hyper sensitive to product quality and safety
concerns. Chinese companies and executives have faced harsh criminal penalties for food
quality and safety related issues.
▪ If Chinese officials and consumers were to learn that Optavia prices are 2x-5x that of
similar American nutrition products/programs, they may not be receptive to Optavia
products, in light of safety and product quality concerns.
▪ MED CEO Daniel Chard was formerly with Nu Skin as a sales executive. During his last few
years at Nu Skin, Nu Skin’s Chinese revenues grew rapidly, and then subsequently
collapsed. Additonally, Nu Skin in China faced regulatory scrutiny. Though financial
markets currently view Chard’s Nu Skin experience as a positive with respect to China,
Chinese officials and consumers may see it differently.
▪ Other than Chard, we are not aware of any MED veterans with significant (or any)
experience expanding overseas. The regional consumer taste/cultural aspects, supply
chain expertise, and regulatory/legal knowhow outside of the US are not evident to us.
Page 41 of 69
Appendix A: We Believe the Prop 65 Exemptions Do Not Apply
This section explains why we believe MED does not qualify for any of the Proposition 65 exemptions.
"Naturally occurring" AND reduced to the "lowest level currently feasible"
California’s Attorney General website lists exemptions to Proposition 65. It says the following regarding
“Exposures to listed chemicals that occur naturally in foods”:
In other words, if lead exceeding the Prop 65 levels were detected in a company’s product, the business
would have to prove that the lead is naturally occurring. The burden of proof is on the business.
Furthermore, “naturally occurring” is not a sufficient condition. The business must also prove that it has
reduced lead to the “lowest level currently feasible.”
We find similar language and criterion within the full text of § 25501. Exposure to a Naturally Occurring
Chemical in a Food, Article 5, Chapter 1. Safe Drinking Water and Toxic Enforcement Act of 1986:
§ 25501. Exposure to a Naturally Occurring Chemical in a Food.
The following section (taken from the above text) mirrors the language found in the AG’s website:
(4) Where a chemical contaminant can occur naturally in a food, the chemical is naturally occurring only to
the extent that it was not avoidable by good agricultural or good manufacturing practices. The producer,
manufacturer, distributor, or holder of the food shall at all times utilize quality control measures that
reduce natural chemical contaminants to the “lowest level currently feasible,” as this term is used in Title
21, Code of Federal Regulations, Section 110.110, subdivision (c) (2001).
Page 42 of 69
“lowest level currently feasible” is used in Title 21, Code of Federal Regulations, Section 110.110,
subdivision (c) (2001) in the following manner:
The manufacturer, distributor, and holder of food shall at all times
utilize quality control operations that reduce natural or unavoidable
defects to the lowest level currently feasible.
The following reasons lead us to believe that Medifast has not, at all times, utilized quality control
operations that reduce natural or unavoidable defects to the lowest level currently feasible:
• Comparable protein products as tested by the Clean Label Project should contain more lead, yet
contain less lead than the tested Optavia products; if 93% of protein products of these at-risk
products contain less lead than Optavia, why is not feasible for Med to reduce lead content?
• Lead was detected in Medifast products in 2008 (similar levels as were detected by our samples),
and the company has spent relatively on R&D and capex versus peers which would raise the
question: has MED failed to correct a problem, because it seeked to lower costs?
As a matter of practicality, proving that a chemical is naturally occurring is very difficult and expensive:
Unfortunately, the bar to prove that a chemical is naturally occurring is very high and extremely difficult
to achieve in some circumstances. Moreover, the burden is on the supplement company to prove the Prop
65 chemical is naturally occurring, so it is an expensive proposition. Even if a supplement company is able
to establish that the Prop 65 chemical is naturally occurring in their product, the company still must show
that they are using good manufacturing practices and have the best quality control measures in place to
limit exposure to the Prop 65 chemical to the lowest feasible level.
Source: http://www.anh-usa.org/wp-content/uploads/2013/04/Prop-65-manual.pdf
Note that Out of state manufacturers are not exempt from Proposition 65:
Page 43 of 69
The other PROP 65 EXEMPTIONS: Why we believe they do not apply
In the below table we’ve summarized the other, technical exemptions to complying with Prop 65:
EXEMPTION APPLICABLE COMMENT

TO MED?
Federal law governs warning in a NO There is no federal law regarding lead
manner that preempts state authority warning that preempts Prop 65
Exposure takes place less than twelve NO Lead was first added to Prop as a listed
months subsequent to the listing of the chemical in 1987 for reproductive and
chemical in question developmental toxicity.
Exposures do not exceed “significant risk NO One serving of MED exceeds the MADL of
level” or “maximum allowable dose 0.5mcg/day for lead
level” or “MADL”
Governmental agencies and public NO MED is neither a governmental agency nor

water utilities are exempt public water utility
Businesses with nine or fewer NO MED employed 399 employees per its 2017
employees 10K
Discharges that do not result in NO MED is not discharging or releasing lead
“significant amount” of the listed into water or land that will pass into a
chemical entering into any source of source of drinking water. The issue with
drinking water MED is lead from ingestion of its weight
loss food products.
Sources and useful links for more information:
1. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=HSC&sectionNum
=25249.10
2. https://oag.ca.gov/prop65/faqs-view-all#3BR
3. https://govt.westlaw.com/calregs/Browse/Home/California/CaliforniaCodeofRegulations?guid=I
42D79370D45011DEA95CA4428EC25FA0&originationContext=documenttoc&transitionType=De
fault&contextData=%28sc.Default%29
4. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=HSC&sectionNum
=25249.6
5. https://govt.westlaw.com/calregs/Document/I482B19F0D45011DEA95CA4428EC25FA0?viewTy
pe=FullText&originationContext=documenttoc&transitionType=CategoryPageItem&contextData
=(sc.Default)
Page 44 of 69
Appendix B: Optavia is “Healthy”, “Safe”, and “High Quality”?
Appendix B contains various screenshots of the Medifast and Optavia website (including videos and diet
plan guides for sub-groups like nursing mothers, teens, seniors, etc) where the company has represented
its products/programs as healthy, safe, nutrient dense, and high quality.
The words “Health” or “Healthy” are used throughout Optavia’s homepage:
http://www.optavia.com/index.jsp
Page 45 of 69
See below, Optavia’s use of the terms “high quality”. “Nutrient dense” also infers a level of quality:
http://www.optaviamedia.com/images/shop/OPTAVIA-chart-comparisons.jpg
“all of the good stuff and none of the bad”, “high quality, complete protein”
http://www.optavia.com/shop/ideal-weight-nutrition.jsp
Page 46 of 69
Optavia Video: “we teach you what good nutrition looks like”, “high quality protein”
http://www.optavia.com/weight-loss-products-programs/ideal-weight-5-1.jsp
Optavia Teen Boys Plan uses the word “safely”
So does the Teen Girls Plan:
http://optaviamedia.com/pdf/learn/OPTAVIA-GUI-Teens-Boys-Plan.pdf
Page 47 of 69
“Safely” is also used when marketing to Nursing Mothers:
http://answers.optavia.com/help/i-just-gave-birth-can-i-go-on-the-optavia-program
Diabetes Plan uses “safely”:
http://optaviamedia.com/pdf/learn/50052_OPTAVIA_Guide-Diabetes.pdf
Age 65 or older, “safely” once again is used:
http://optaviamedia.com/pdf/learn/50053_GUI_OPTAVIA-Seniors.pdf
Medifast, “How You Lose Weight – Quickly and Safely with Medifast”:
Page 48 of 69
“Safe weight loss results”:
http://www.medifast1.com/Products/medifast-diet-plans/meals/crunchy/prd~68250.jsp
http://www.medifast1.com/Products/medifast-diet-plans/meals/crunchy/prd~68260.jsp
“Medifast is safe and effective”:
http://www.medifast1.com/weight-loss-plans/how-you-lose-weight.jsp
Medifast Diabetes guide uses “safe” or “safely” 5 times, refer to file saved for all 5:
http://www.medifastmedia.com/shared/docs/diabetes_guide.pdf
Page 49 of 69
Medifast for Seniors uses “safe”:
http://www.medifastmedia.com/shared/docs/seniors_guide.pdf
Medifast for Nursing mothers uses safe twice:
http://www.medifastmedia.com/shared/docs/nursing_mothers_guide.pdf
Medifast plan for Gout, “safely”:
http://www.medifastmedia.com/shared/docs/gout_guide.pdf
Optavia for Gout, “safely”:
http://optaviamedia.com/pdf/learn/OPTAVIA-GUI-Gout-Guide.pdf
Page 50 of 69
Appendix C: Made in the USA?
<This section contains screenshots of Medifast and Optavia product labels (from the website and physical
product box photos) where the company has represented its products as Made in the USA, unreservedly.
calcium caseinate a major ingredient listed in these products, originate from outside the USA, according
to shipping records.
Made in the USA claim vs our understanding
Bars
Source: ebay https://www.ebay.com/itm/Optavia-Chocolate-Mint-Cookie-Crisp-Bar-7-

Servings/192543572719?hash=item2cd47dc2ef:g:NGwAAOSw8Mda~fdR
Optavia Calorie Burn Cappuccino:
Page 51 of 69
https://www.amazon.com/Optavia-Rich-Dark-Chocolate-Shake/dp/B07D6WQ46F
Optavia Velvety Hot Chocolate:
https://www.ebay.com/itm/253444397957?ul_noapp=true
Medifast Calorie Burn Cappuccino:
Page 52 of 69
https://www.ebay.com/p/4-Calorie-Burn-Cappuccino-Medifast-Meal-Replacements/1200581678
Did not find a box photo but calcium caseinate is #2 on this one:
Did not find a box photo but calcium caseinate is #3 on this one:
https://www.optavia.com/Products/optavia-products/optimalweight/essential/drinks/prd~78050.jsp
Page 53 of 69
Appendix D: Lead in Everyday Foods as Tested by the FDA
No.
LEAD 295 Syrup, chocolate 32 1 31 0.016 0.005 0.016 0 0.027 0.007 0.030
LEAD 221 BF, sweet potatoes 32 5 26 0.013 0.008 0.014 0 0.034 0.007 0.030
LEAD 254 Peach, canned in light syrup 32 4 26 0.012 0.008 0.011 0 0.038 0.007 0.030
LEAD 348 Apricots, canned in heavy/light syrup 32 6 25 0.012 0.008 0.013 0 0.036 0.007 0.030
LEAD 723 BF, arrowroot cookies 32 11 21 0.012 0.010 0.014 0 0.031 0.010 0.040
LEAD 358 Sweet potatoes, canned 32 2 30 0.012 0.005 0.012 0 0.023 0.007 0.030
LEAD 187 Candy bar, milk chocolate, plain 32 10 22 0.011 0.008 0.014 0 0.027 0.010 0.040
LEAD 291 Brownie 32 7 24 0.010 0.007 0.010 0 0.032 0.007 0.030
LEAD 87 Fruit cocktail, canned in light syrup 32 7 25 0.010 0.007 0.011 0 0.025 0.007 0.030
LEAD 244 Shrimp, boiled 32 25 5 0.009 0.033 0 0 0.180 0.010 0.040
LEAD 317 BF, teething biscuits 31 17 14 0.009 0.011 0 0 0.033 0.010 0.040
LEAD 712 BF, juice, grape 32 4 26 0.009 0.005 0.010 0 0.020 0.004 0.020
LEAD 704 BF, juice, apple-cherry 16 3 10 0.008 0.008 0.006 0 0.023 0.004 0.020
LEAD 161 Dill cucumber pickles 32 19 12 0.007 0.011 0 0 0.049 0.010 0.040
LEAD 93 Pineapple, canned in juice 32 10 21 0.007 0.009 0.006 0 0.046 0.005 0.020
LEAD 255 Pear, canned in light syrup 32 13 18 0.007 0.007 0.008 0 0.030 0.007 0.030
LEAD 199 Wine, dry table, red/white 32 4 27 0.007 0.005 0.007 0 0.029 0.004 0.020
LEAD 178 Cake, chocolate with icing 32 17 15 0.006 0.007 0 0 0.021 0.007 0.030
LEAD 285 32 14 18 0.006 0.006 0.008 0 0.020 0.007 0.030
LEAD 183 Chocolate chip cookies 32 13 19 0.006 0.006 0.008 0 0.018 0.007 0.030
LEAD 257 32 10 22 0.006 0.005 0.006 0 0.015 0.004 0.020
reconstituted
LEAD 230 BF, juice, apple 32 17 13 0.005 0.007 0 0 0.029 0.004 0.020
LEAD 703 BF, juice, apple-banana 15 6 8 0.005 0.007 0.004 0 0.022 0.004 0.020
LEAD 705 BF, juice, apple-grape 16 7 9 0.005 0.006 0.005 0 0.019 0.004 0.020
LEAD 357 Lettuce, leaf, raw 32 16 16 0.005 0.005 0.003 0 0.017 0.005 0.020
LEAD 293 Candy, hard, any flavor 32 30 0 0.004 0.014 0 0 0.065 0.020 0.050
LEAD 211 BF, vegetables and beef 32 26 5 0.004 0.012 0 0 0.064 0.007 0.030
LEAD 216 BF, turkey and rice 32 20 11 0.004 0.007 0 0 0.035 0.007 0.030
LEAD 95 Raisins 32 24 9 0.004 0.007 0 0 0.023 0.010 0.040
LEAD 251 Crackers, graham 32 23 9 0.004 0.007 0 0 0.020 0.010 0.040
LEAD 184 Sandwich cookies w/ crème filling 32 21 11 0.004 0.005 0 0 0.019 0.007 0.030
LEAD 107 Spinach, fresh/frozen, boiled 32 20 12 0.004 0.005 0 0 0.018 0.007 0.030
LEAD 172 Honey 32 23 9 0.004 0.006 0 0 0.018 0.010 0.040
LEAD 218 BF, carrots 32 20 12 0.004 0.006 0 0 0.018 0.007 0.030
LEAD 376 32 24 8 0.004 0.007 0 0 0.018 0.012 0.040
low-calorie
LEAD 711 BF, juice, pear 32 13 19 0.004 0.004 0.005 0 0.015 0.004 0.020
LEAD 162 Margarine, regular (not lowfat), salted 32 30 1 0.003 0.013 0 0 0.065 0.020 0.060
LEAD 168 32 26 5 0.003 0.010 0 0 0.050 0.010 0.040
liquid/frozen
LEAD 164 Butter, regular (not lowfat), salted 32 29 3 0.003 0.009 0 0 0.031 0.020 0.060
LEAD 250 English muffin, plain, toasted 32 28 4 0.003 0.008 0 0 0.024 0.010 0.040
LEAD 728 BF, vegetables and turkey 32 23 9 0.003 0.006 0 0 0.020 0.007 0.030
LEAD 182 Sweet roll/Danish pastry 32 23 9 0.003 0.005 0 0 0.019 0.007 0.030
LEAD 103 Prune juice, bottled 32 21 11 0.003 0.004 0 0 0.014 0.005 0.020
LEAD 350 32 16 16 0.003 0.004 0.002 0 0.014 0.004 0.020
canned/bottled
LEAD 720 BF, peach cobbler/dessert 32 23 9 0.003 0.005 0 0 0.012 0.007 0.030
LEAD 724 BF, zweiback toast 14 11 3 0.003 0.005 0 0 0.012 0.010 0.040
LEAD 710 BF, juice, mixed fruit 16 10 6 0.003 0.003 0 0 0.008 0.004 0.020
LEAD 22 Lamb chop, pan-cooked with oil 32 30 1 0.002 0.007 0 0 0.040 0.010 0.040
LEAD 173 Tomato catsup 32 28 4 0.002 0.007 0 0 0.038 0.010 0.040
LEAD 372 Popcorn, microwave, butter-flavored 32 30 2 0.002 0.008 0 0 0.038 0.014 0.050
LEAD 278 32 29 3 0.002 0.006 0 0 0.030 0.010 0.040
fast-food
LEAD 290 32 28 4 0.002 0.005 0 0 0.027 0.007 0.030
donut store
LEAD 108 Collards, fresh/frozen, boiled 32 28 4 0.002 0.005 0 0 0.025 0.007 0.030
LEAD 77 Oat ring cereal 32 28 4 0.002 0.005 0 0 0.023 0.010 0.040
LEAD 88 Grapes (red/green), raw 32 27 5 0.002 0.004 0 0 0.019 0.005 0.020
LEAD 259 Carrot, fresh, peeled, boiled 32 27 5 0.002 0.004 0 0 0.019 0.007 0.030
LEAD 346 Macaroni salad, from grocery/deli 32 28 4 0.002 0.004 0 0 0.016 0.010 0.040
LEAD 186 Pie, pumpkin, fresh/frozen 32 27 5 0.002 0.004 0 0 0.015 0.010 0.040
LEAD 74 Raisin bran cereal 32 28 4 0.002 0.004 0 0 0.014 0.010 0.040
LEAD 212 BF, vegetables and chicken 32 27 5 0.002 0.004 0 0 0.014 0.007 0.030
LEAD 248 32 28 4 0.002 0.004 0 0 0.014 0.010 0.040
wheat)
LEAD 299 Black olives 32 24 8 0.002 0.005 0 0 0.014 0.007 0.030
LEAD 370 Granola bar, with raisins 32 28 4 0.002 0.004 0 0 0.014 0.010 0.040
LEAD 298 Mustard, yellow, plain 32 24 8 0.002 0.004 0 0 0.012 0.007 0.030
LEAD 345 Breakfast tart/toaster pastry 32 27 5 0.002 0.004 0 0 0.012 0.007 0.030
Page 54 of 69
No.
Cake, white with icing (formerly yellow
LEAD 369 32 25 7 0.002 0.003 0 0 0.009 0.007 0.030
cake)
Macaroni and cheese, prepared from
LEAD 146 32 31 0 0.001 0.008 0 0 0.046 0.010 0.040
box mix
BF, cereal, rice, dry, prepared with
LEAD 324 32 31 0 0.001 0.007 0 0 0.040 0.010 0.040
water
LEAD 300 Sour cream 32 31 1 0.001 0.006 0 0 0.034 0.010 0.040
LEAD 39 Pork and beans, canned 32 30 1 0.001 0.006 0 0 0.033 0.007 0.030
LEAD 237 Cream cheese 32 31 1 0.001 0.006 0 0 0.033 0.010 0.040
LEAD 166 Mayonnaise, regular, bottled 32 31 3 0.001 0.005 0 0 0.031 0.020 0.060
LEAD 97 Avocado, raw 32 31 1 0.001 0.005 0 0 0.030 0.020 0.050
LEAD 347 Spaghetti, enriched, boiled 32 30 2 0.001 0.005 0 0 0.027 0.007 0.030
BF, cereal, oatmeal with fruit, prepared
LEAD 725 32 29 3 0.001 0.005 0 0 0.025 0.010 0.040
with water
Quarter-pound hamburger on bun, fast-
LEAD 147 32 31 1 0.001 0.004 0 0 0.024 0.010 0.040
food
LEAD 148 Meatloaf, beef, homemade 32 31 1 0.001 0.004 0 0 0.024 0.010 0.040
LEAD 152 Chicken potpie, frozen, heated 32 31 1 0.001 0.004 0 0 0.024 0.010 0.040
LEAD 167 Cream, half & half 32 31 1 0.001 0.004 0 0 0.024 0.020 0.050
LEAD 17 Ham, cured (not canned), baked 32 31 2 0.001 0.004 0 0 0.023 0.020 0.050
LEAD 27 Liver (beef/calf), pan-cooked with oil 32 31 1 0.001 0.004 0 0 0.023 0.020 0.050
LEAD 294 Pretzels, hard, salted 32 31 1 0.001 0.004 0 0 0.023 0.020 0.050
LEAD 169 Sugar, white, granulated 32 31 1 0.001 0.004 0 0 0.022 0.020 0.060
LEAD 320 BF, squash 32 29 3 0.001 0.005 0 0 0.022 0.007 0.030
LEAD 20 Pork bacon, oven-cooked 32 31 1 0.001 0.004 0 0 0.021 0.020 0.050
LEAD 79 Orange (navel/Valencia), raw 32 30 2 0.001 0.004 0 0 0.021 0.007 0.030
LEAD 92 Grapefruit, raw 32 30 1 0.001 0.004 0 0 0.021 0.005 0.020
LEAD 142 Spaghetti with meat sauce, homemade 32 31 1 0.001 0.004 0 0 0.021 0.007 0.030
LEAD 219 BF, green beans 32 29 3 0.001 0.005 0 0 0.021 0.007 0.030
LEAD 276 Fish sandwich on bun, fast-food 32 30 2 0.001 0.004 0 0 0.021 0.010 0.040
LEAD 377 Salad dressing, Italian, regular 32 30 2 0.001 0.005 0 0 0.021 0.018 0.060
LEAD 730 BF, apples with berries 32 29 3 0.001 0.004 0 0 0.021 0.007 0.030
Soup, chicken noodle, canned,
LEAD 155 32 29 3 0.001 0.004 0 0 0.02 0.007 0.030
condensed, prepared with water
LEAD 220 BF, mixed vegetables 32 28 4 0.001 0.004 0 0 0.020 0.007 0.030
LEAD 378 Olive oil 32 31 1 0.001 0.004 0 0 0.020 0.018 0.060
LEAD 119 Tomato sauce, plain, bottled 32 29 3 0.001 0.004 0 0 0.019 0.010 0.040
LEAD 252 Crackers, butter-type 32 31 1 0.001 0.003 0 0 0.019 0.010 0.040
Quarter-pound cheeseburger on bun,
LEAD 275 32 29 3 0.001 0.004 0 0 0.019 0.010 0.040
fast-food
LEAD 340 Tuna, canned in water, drained 32 29 3 0.001 0.004 0 0 0.019 0.010 0.040
LEAD 60 Cornbread, homemade 32 31 1 0.001 0.003 0 0 0.018 0.010 0.040
LEAD 71 Corn flakes cereal 32 30 2 0.001 0.004 0 0 0.018 0.010 0.040
LEAD 121 Green beans, fresh/frozen, boiled 32 31 1 0.001 0.003 0 0 0.018 0.007 0.030
LEAD 124 Summer squash, fresh/frozen, boiled 32 31 1 0.001 0.003 0 0 0.018 0.007 0.030
LEAD 207 BF, chicken and broth/gravy 32 30 2 0.001 0.004 0 0 0.018 0.007 0.030
LEAD 235 Yogurt, lowfat, fruit-flavored 32 28 4 0.001 0.004 0 0 0.018 0.007 0.030
LEAD 334 Beef steak, loin/sirloin, broiled 32 30 2 0.001 0.004 0 0 0.018 0.010 0.040
LEAD 109 Lettuce, iceberg, raw 32 31 1 0.001 0.003 0 0 0.017 0.005 0.020
Pineapple juice, frozen concentrate,
LEAD 256 32 29 3 0.001 0.003 0 0 0.017 0.004 0.020
reconstituted
LEAD 131 Beets, canned 32 30 2 0.001 0.003 0 0 0.016 0.007 0.030
LEAD 145 Chili con carne with beans, canned 32 29 3 0.001 0.004 0 0 0.016 0.010 0.040
LEAD 236 Cheese, Swiss, natural 32 30 2 0.001 0.004 0 0 0.016 0.010 0.040
LEAD 268 Mixed vegetables, frozen, boiled 32 30 2 0.001 0.003 0 0 0.016 0.007 0.030
LEAD 344 Pancakes, frozen, heated 32 31 1 0.001 0.003 0 0 0.016 0.010 0.040
Soup, Oriental noodles (ramen noodles),
LEAD 367 32 30 2 0.001 0.003 0 0 0.016 0.007 0.030
prepared with water
LEAD 86 Strawberries, raw/frozen 32 29 3 0.001 0.004 0 0 0.015 0.005 0.020
LEAD 205 BF, beef and broth/gravy 32 30 2 0.001 0.004 0 0 0.015 0.007 0.030
LEAD 335 Luncheon meat (chicken/turkey) 32 30 2 0.001 0.003 0 0 0.015 0.007 0.030
LEAD 128 Onion, mature, raw 32 29 3 0.001 0.003 0 0 0.014 0.007 0.030
LEAD 272 Tuna noodle casserole, homemade 32 30 2 0.001 0.003 0 0 0.014 0.007 0.030
LEAD 731 BF, apples with fruit other than berries 32 30 2 0.001 0.003 0 0 0.014 0.007 0.030
LEAD 69 Noodles, egg, enriched, boiled 32 28 4 0.001 0.003 0 0 0.013 0.007 0.030
LEAD 75 Crisped rice cereal 32 30 2 0.001 0.003 0 0 0.013 0.010 0.040
LEAD 185 Pie, apple, fresh/frozen 32 29 3 0.001 0.004 0 0 0.013 0.010 0.040
LEAD 194 Carbonated beverage, cola, low-calorie 32 29 3 0.001 0.003 0 0 0.013 0.004 0.020
LEAD 361 Lasagna with meat, frozen, heated 32 30 2 0.001 0.003 0 0 0.013 0.010 0.040
Squash, winter (Hubbard/acorn),
LEAD 126 31 27 4 0.001 0.003 0 0 0.012 0.007 0.030
fresh/frozen, boiled
LEAD 233 BF, fruit dessert/pudding 22 20 2 0.001 0.003 0 0 0.012 0.007 0.030
Beef stroganoff with noodles,
LEAD 269 32 28 4 0.001 0.003 0 0 0.012 0.007 0.030
homemade
Beef with vegetables in sauce, from
LEAD 362 32 29 3 0.001 0.003 0 0 0.012 0.007 0.030
Chinese carry-out
LEAD 729 BF, macaroni and cheese 32 29 3 0.001 0.003 0 0 0.012 0.007 0.030
Page 55 of 69
No.
LEAD 62 Bread, whole wheat 32 30 2 0.001 0.003 0 0 0.011 0.010 0.040
LEAD 84 Applesauce, bottled 32 29 3 0.001 0.003 0 0 0.011 0.007 0.030
LEAD 214 BF, chicken noodle dinner 32 27 5 0.001 0.003 0 0 0.011 0.007 0.030
LEAD 215 BF, macaroni, tomato and beef 32 28 4 0.001 0.003 0 0 0.011 0.007 0.030
Taco/tostada with beef and cheese,
LEAD 279 32 30 2 0.001 0.003 0 0 0.011 0.010 0.040
from Mexican carry-out
LEAD 292 Sugar cookies 32 30 2 0.001 0.002 0 0 0.011 0.007 0.030
LEAD 309 BF, Infant formula, soy-based, RTF 32 28 4 0.001 0.003 0 0 0.011 0.004 0.020
LEAD 373 Sweet & sour sauce 32 30 2 0.001 0.002 0 0 0.011 0.007 0.030
LEAD 726 BF, chicken with rice 32 27 5 0.001 0.003 0 0 0.011 0.007 0.030
LEAD 177 Ice cream, light, vanilla 32 30 2 0.001 0.002 0 0 0.010 0.007 0.030
LEAD 190 Gelatin dessert, any flavor 32 30 2 0.001 0.002 0 0 0.010 0.007 0.030
LEAD 232 BF, custard/pudding 23 21 2 0.001 0.003 0 0 0.010 0.007 0.030
LEAD 296 Jelly, any flavor 32 29 3 0.001 0.003 0 0 0.010 0.007 0.030
LEAD 351 Cranberry juice cocktail, canned/bottled 32 27 5 0.001 0.003 0 0 0.010 0.004 0.020
LEAD 714 BF, plums/prunes with apples or pears 32 27 5 0.001 0.003 0 0 0.010 0.007 0.030
LEAD 721 BF, fruit yogurt dessert 32 27 5 0.001 0.003 0 0 0.010 0.007 0.030
LEAD 85 Pear, raw (with peel) 32 30 2 0.001 0.002 0 0 0.009 0.007 0.030
LEAD 225 BF, applesauce 32 30 2 0.001 0.002 0 0 0.009 0.007 0.030
LEAD 261 Tomato juice, bottled 32 28 4 0.001 0.002 0 0 0.009 0.005 0.020
LEAD 266 Turnip, fresh/frozen, boiled 32 30 2 0.001 0.002 0 0 0.009 0.007 0.030
LEAD 356 Carrot, baby, raw 32 30 2 0.001 0.002 0 0 0.009 0.007 0.030
LEAD 359 Tomato salsa, bottled 32 30 2 0.001 0.002 0 0 0.009 0.007 0.030
LEAD 713 BF, pears and pineapple 32 28 4 0.001 0.003 0 0 0.009 0.007 0.030
LEAD 719 BF, banana dessert 15 13 2 0.001 0.003 0 0 0.009 0.007 0.030
LEAD 100 Grapefruit juice, bottled 31 29 2 0.001 0.002 0 0 0.008 0.004 0.020
LEAD 264 Mushrooms, raw 32 30 2 0.001 0.002 0 0 0.008 0.007 0.030
Chicken with vegetables in sauce, from
LEAD 363 32 30 2 0.001 0.002 0 0 0.008 0.007 0.030
Chinese carry-out
LEAD 722 BF, Dutch apple/apple cobbler 10 9 1 0.001 0.003 0 0 0.008 0.007 0.030
LEAD 99 Apple juice, bottled 32 28 4 0.001 0.002 0 0 0.007 0.004 0.020
Meal replacement, liquid RTD, any
LEAD 331 32 29 3 0.001 0.002 0 0 0.007 0.004 0.020
flavor
LEAD 116 Cauliflower, fresh/frozen, boiled 32 31 1 0.0005 0.003 0 0 0.015 0.007 0.030
LEAD 37 Eggs, boiled 32 31 1 0.0004 0.002 0 0 0.014 0.007 0.030
LEAD 61 Biscuits, refrigerated-type, baked 32 31 1 0.0004 0.002 0 0 0.014 0.010 0.040
LEAD 193 Fruit drink, from powder 32 31 1 0.0004 0.002 0 0 0.014 0.004 0.020
Chicken thigh, oven-roasted (skin
LEAD 337 32 31 1 0.0004 0.002 0 0 0.014 0.007 0.030
removed)
LEAD 371 Candy bar, chocolate, nougat, and nuts 32 31 1 0.0004 0.002 0 0 0.014 0.010 0.040
LEAD 18 Pork chop, pan-cooked with oil 32 31 1 0.0004 0.002 0 0 0.013 0.010 0.040
LEAD 339 Catfish, pan-cooked with oil 32 31 1 0.0004 0.002 0 0 0.013 0.010 0.040
LEAD 64 Bread, rye 32 31 1 0.0004 0.002 0 0 0.012 0.010 0.040
LEAD 137 Potato, baked (with peel) 32 31 1 0.0004 0.002 0 0 0.012 0.007 0.030
Chicken filet (broiled) sandwich on bun,
LEAD 366 32 31 1 0.0004 0.002 0 0 0.012 0.010 0.040
fast-food
Bottled drinking water (mineral/spring), not
LEAD 380 32 31 1 0.0004 0.002 0 0 0.012 0.004 0.020
carbonated or flavored
LEAD 360 Stew, beef and vegetable, canned 23 22 1 0.0004 0.002 0 0 0.009 0.007 0.030
LEAD 267 Okra, fresh/frozen, boiled 32 30 2 0.0004 0.002 0 0 0.007 0.007 0.030
LEAD 14 Beef roast, chuck, oven-roasted 32 31 1 0.0003 0.002 0 0 0.011 0.010 0.040
LEAD 38 Pinto beans, dry, boiled 32 31 1 0.0003 0.002 0 0 0.011 0.007 0.030
LEAD 58 Bread, white, enriched 32 31 1 0.0003 0.002 0 0 0.011 0.010 0.040
LEAD 73 Shredded wheat cereal 32 31 1 0.0003 0.002 0 0 0.011 0.010 0.040
Pizza, cheese and pepperoni, regular
LEAD 281 32 31 1 0.0003 0.002 0 0 0.011 0.010 0.040
crust, from pizza carry-out
LEAD 333 Sour cream dip, any flavor 32 31 1 0.0003 0.002 0 0 0.011 0.010 0.040
LEAD 34 Fish sticks or patty, frozen, oven-cooked 32 31 1 0.0003 0.002 0 0 0.010 0.010 0.040
LEAD 72 Fruit-flavored cereal, presweetened 32 31 1 0.0003 0.002 0 0 0.010 0.010 0.040
LEAD 76 Granola with raisins 32 31 1 0.0003 0.002 0 0 0.010 0.010 0.040
LEAD 89 Cantaloupe, raw/frozen 32 31 1 0.0003 0.002 0 0 0.010 0.005 0.020
LEAD 122 Green beans, canned 32 31 1 0.0003 0.002 0 0 0.010 0.007 0.030
LEAD 249 Bagel, plain, toasted 32 31 1 0.0003 0.002 0 0 0.010 0.010 0.040
LEAD 287 Sherbet, fruit-flavored 32 31 1 0.0003 0.002 0 0 0.010 0.005 0.020
LEAD 338 Chicken leg, fried, fast-food (with skin) 32 31 1 0.0003 0.002 0 0 0.010 0.010 0.040
Potato salad, mayonnaise-type, from
LEAD 353 32 31 1 0.0003 0.002 0 0 0.010 0.010 0.040
grocery/deli
LEAD 374 Brown gravy, canned or bottled 32 31 1 0.0003 0.002 0 0 0.010 0.010 0.040
LEAD 382 Tea, decaffeinated, from tea bag 32 31 1 0.0003 0.002 0 0 0.010 0.004 0.020
LEAD 115 Asparagus, fresh/frozen, boiled 32 31 1 0.0003 0.002 0 0 0.009 0.007 0.030
LEAD 286 Ice cream, regular (not lowfat), vanilla 32 31 1 0.0003 0.002 0 0 0.009 0.007 0.030
Cottage cheese, creamed, lowfat (2%
LEAD 332 32 31 1 0.0003 0.002 0 0 0.009 0.007 0.030
milk fat)
LEAD 1 Milk, whole, fluid 32 31 1 0.0003 0.001 0 0 0.008 0.007 0.030
Page 56 of 69
No.
LEAD 2 Milk, lowfat (2%), fluid 32 31 1 0.0003 0.001 0 0 0.008 0.007 0.030
LEAD 3 Milk, chocolate, lowfat, fluid 32 31 1 0.0003 0.001 0 0 0.008 0.007 0.030
LEAD 7 Milk shake, chocolate, fast-food 32 31 1 0.0003 0.001 0 0 0.008 0.007 0.030
LEAD 226 BF, peaches 32 31 1 0.0003 0.001 0 0 0.008 0.007 0.030
LEAD 227 BF, pears 32 31 1 0.0003 0.001 0 0 0.008 0.007 0.030
LEAD 265 Eggplant, fresh, peeled, boiled 32 31 1 0.0003 0.001 0 0 0.008 0.007 0.030
Soup, bean with bacon/pork, canned,
LEAD 283 32 31 1 0.0003 0.001 0 0 0.008 0.007 0.030
LEAD 198 Beer 32 30 2 0.0003 0.001 0 0 0.006 0.004 0.020
LEAD 352 Orange juice, bottled/carton 32 30 2 0.0003 0.001 0 0 0.006 0.004 0.020
LEAD 83 Peach, raw/frozen 32 31 1 0.0002 0.001 0 0 0.007 0.007 0.030
LEAD 125 Pepper, sweet, green, raw 32 31 1 0.0002 0.001 0 0 0.007 0.007 0.030
LEAD 223 BF, peas 32 31 1 0.0002 0.001 0 0 0.007 0.007 0.030
LEAD 354 Potatoes, mashed, prepared from fresh 32 31 1 0.0002 0.001 0 0 0.007 0.007 0.030
LEAD 717 BF, apricots with mixed fruit 32 31 1 0.0002 0.001 0 0 0.007 0.007 0.030
LEAD 114 Celery, raw 32 31 1 0.0002 0.001 0 0 0.005 0.005 0.020
Fruit drink (10% juice), canned or
LEAD 307 32 31 1 0.0002 0.001 0 0 0.005 0.004 0.020
bottled
LEAD 4 Milk, skim, fluid 32 32 0 0 0 0 0 0 0.005 0.020
LEAD 10 Cheese, American, processed 32 32 0 0 0 0 0 0 0.020 0.050
LEAD 12 Cheese, cheddar, natural (sharp/mild) 32 32 0 0 0 0 0 0 0.020 0.050
LEAD 13 Beef, ground, regular, pan-cooked 32 32 0 0 0 0 0 0 0.010 0.040
LEAD 19 Pork sausage (link/patty), oven-cooked 32 32 0 0 0 0 0 0 0.020 0.050
LEAD 21 Pork roast, loin, oven-roasted 32 32 0 0 0 0 0 0 0.010 0.040
LEAD 26 Turkey breast, oven-roasted 32 32 0 0 0 0 0 0 0.007 0.030
LEAD 28 Frankfurter (beef/pork), boiled 32 32 1 0 0 0 0 0 0.020 0.050
LEAD 29 Bologna (beef/pork) 32 32 0 0 0 0 0 0 0.020 0.050
LEAD 30 Salami, luncheon-meat type (not hard) 32 32 0 0 0 0 0 0 0.020 0.050
LEAD 35 Eggs, scrambled with oil 32 32 0 0 0 0 0 0 0.007 0.030
LEAD 42 Lima beans, immature, frozen, boiled 32 32 0 0 0 0 0 0 0.007 0.030
LEAD 46 Peas, green, fresh/frozen, boiled 32 32 0 0 0 0 0 0 0.007 0.030
LEAD 47 Peanut butter, smooth/creamy 32 32 0 0 0 0 0 0 0.020 0.050
LEAD 48 Peanuts, dry roasted, salted 32 32 0 0 0 0 0 0 0.020 0.050
LEAD 50 Rice, white, enriched, cooked 32 32 0 0 0 0 0 0 0.007 0.030
LEAD 51 Oatmeal, plain, cooked 32 32 0 0 0 0 0 0 0.007 0.030
Cream of wheat (farina), enriched,
LEAD 52 32 32 0 0 0 0 0 0 0.007 0.030
cooked
LEAD 53 Corn/hominy grits, enriched, cooked 32 32 0 0 0 0 0 0 0.007 0.030
LEAD 54 Corn, fresh/frozen, boiled 32 32 0 0 0 0 0 0 0.007 0.030
LEAD 55 Corn, canned 32 32 0 0 0 0 0 0 0.007 0.030
LEAD 63 Tortilla, flour 32 32 0 0 0 0 0 0 0.010 0.040
LEAD 65 Muffin, blueberry 32 32 0 0 0 0 0 0 0.010 0.040
LEAD 66 Crackers, saltine 32 32 0 0 0 0 0 0 0.020 0.050
LEAD 67 Corn/tortilla chips 32 32 0 0 0 0 0 0 0.020 0.050
LEAD 78 Apple (red), raw (with peel) 32 32 0 0 0 0 0 0 0.007 0.030
LEAD 80 Banana, raw 32 32 0 0 0 0 0 0 0.007 0.030
LEAD 81 Watermelon, raw/frozen 32 32 0 0 0 0 0 0 0.005 0.020
Orange juice, frozen concentrate,
LEAD 98 32 32 0 0 0 0 0 0 0.004 0.020
reconstituted
Lemonade, frozen concentrate,
LEAD 105 32 32 0 0 0 0 0 0 0.004 0.020
reconstituted
LEAD 110 Cabbage, fresh, boiled 32 32 0 0 0 0 0 0 0.005 0.020
LEAD 113 Broccoli, fresh/frozen, boiled 32 32 0 0 0 0 0 0 0.007 0.030
LEAD 117 Tomato, raw 32 32 0 0 0 0 0 0 0.005 0.020
LEAD 123 Cucumber, peeled, raw 32 32 0 0 0 0 0 0 0.005 0.020
LEAD 136 Potato, boiled (without peel) 32 32 0 0 0 0 0 0 0.007 0.030
LEAD 138 Potato chips 32 32 0 0 0 0 0 0 0.020 0.050
Soup, tomato, canned, condensed,
LEAD 156 32 32 0 0 0 0 0 0 0.007 0.030
prepared with water
Soup, vegetable beef, canned,
LEAD 157 32 32 0 0 0 0 0 0 0.007 0.030
LEAD 170 Syrup, pancake 32 32 0 0 0 0 0 0 0.010 0.040
LEAD 191 Carbonated beverage, cola, regular 32 32 0 0 0 0 0 0 0.004 0.020
LEAD 197 Tea, from tea bag 32 32 0 0 0 0 0 0 0.004 0.020
BF, Infant formula, milk-based, iron
LEAD 202 32 32 0 0 0 0 0 0 0.005 0.020
fortified RTF (formerly high iron)
BF, Infant formula, milk-based, low iron,
LEAD 203 10 10 0 0 0 0 0 0 0.005 0.020
RTF
LEAD 213 BF, vegetables and ham 4 4 0 0 0 0 0 0 0.007 0.030
LEAD 239 Luncheon meat, ham 32 32 0 0 0 0 0 0 0.014 0.050
Chicken breast, oven-roasted (skin
LEAD 240 32 32 0 0 0 0 0 0 0.010 0.040
removed)
LEAD 241 Chicken nuggets, fast-food 32 32 0 0 0 0 0 0 0.010 0.040
LEAD 258 French fries, fast-food 32 32 0 0 0 0 0 0 0.020 0.050
LEAD 263 Brussels sprouts, fresh/frozen, boiled 32 32 0 0 0 0 0 0 0.007 0.030
Page 57 of 69
No.
LEAD 288 Popsicle, fruit-flavored 32 32 0 0 0 0 0 0 0.010 0.040
LEAD 305 Coffee, from ground 32 32 0 0 0 0 0 0 0.004 0.020
Carbonated beverage, fruit-flavored,
LEAD 306 32 32 0 0 0 0 0 0 0.004 0.020
regular
LEAD 313 BF, bananas 32 32 0 0 0 0 0 0 0.007 0.030
LEAD 318 Salmon, steaks/fillets, baked 32 32 0 0 0 0 0 0 0.010 0.040
BF, cereal, oatmeal, dry, prepared with
LEAD 323 32 32 0 0 0 0 0 0 0.010 0.040
water
BF, cereal, rice with apples, dry,
LEAD 325 13 13 0 0 0 0 0 0 0.010 0.040
prepared with water
LEAD 326 BF, veal and broth/gravy 17 17 0 0 0 0 0 0 0.007 0.030
LEAD 327 BF, lamb and broth/gravy 17 17 0 0 0 0 0 0 0.007 0.030
LEAD 328 BF, turkey and broth/gravy 32 32 0 0 0 0 0 0 0.007 0.030
Chicken breast, fried, fast-food (with
LEAD 336 32 32 0 0 0 0 0 0 0.010 0.040
skin)
LEAD 341 Refried beans, canned 32 32 0 0 0 0 0 0 0.010 0.040
LEAD 342 White beans, dry, boiled 32 32 0 0 0 0 0 0 0.007 0.030
Sunflower seeds (shelled), roasted,
LEAD 343 32 32 0 0 0 0 0 0 0.014 0.050
salted
Coleslaw, mayonnaise-type, from
LEAD 355 32 32 0 0 0 0 0 0 0.010 0.040
grocery/deli
Fried rice, meatless, from Chinese carry-
LEAD 364 32 32 0 0 0 0 0 0 0.010 0.040
out
Burrito with beef, beans and cheese,
LEAD 365 32 32 0 0 0 0 0 0 0.010 0.040
Pudding, ready-to-eat, flavor other than
LEAD 368 32 32 0 0 0 0 0 0 0.007 0.030
chocolate
LEAD 375 32 32 0 0 0 0 0 0 0.018 0.060
regular
LEAD 379 Vegetable oil 32 32 0 0 0 0 0 0 0.018 0.060
LEAD 381 Coffee, decaffeinated, from ground 32 32 0 0 0 0 0 0 0.004 0.020
BF, cereal, barley, dry, prepared with
LEAD 700 29 29 0 0 0 0 0 0 0.010 0.040
water
BF, cereal, mixed, dry, prepared with
LEAD 701 32 32 0 0 0 0 0 0 0.010 0.040
water
Page 58 of 69
No.
Sunflower seeds (shelled), roasted,
CADMIUM 343 32 0 0 0.389 0.120 0.379 0.215 0.874 0.003 0.010
salted
CADMIUM 107 Spinach, fresh/frozen, boiled 32 0 0 0.183 0.226 0.122 0.038 1.100 0.002 0.005
CADMIUM 357 Lettuce, leaf, raw 32 0 0 0.066 0.038 0.058 0.012 0.175 0.001 0.004
CADMIUM 27 Liver (beef/calf), pan-cooked with oil 32 0 0 0.056 0.036 0.045 0.021 0.171 0.003 0.010
CADMIUM 138 Potato chips 32 1 0 0.054 0.029 0.052 0 0.145 0.003 0.010
CADMIUM 73 Shredded wheat cereal 32 0 0 0.054 0.013 0.053 0.035 0.081 0.002 0.007
CADMIUM 109 Lettuce, iceberg, raw 32 0 0 0.051 0.035 0.039 0.010 0.157 0.001 0.004
CADMIUM 48 Peanuts, dry roasted, salted 32 0 0 0.044 0.018 0.038 0.020 0.084 0.003 0.010
CADMIUM 108 Collards, fresh/frozen, boiled 32 0 0 0.043 0.063 0.028 0.010 0.368 0.002 0.005
CADMIUM 258 French fries, fast-food 32 0 0 0.042 0.014 0.039 0.022 0.072 0.003 0.010
CADMIUM 47 Peanut butter, smooth/creamy 32 1 0 0.039 0.012 0.037 0 0.072 0.003 0.010
CADMIUM 74 Raisin bran cereal 32 0 0 0.037 0.009 0.037 0.023 0.057 0.002 0.007
CADMIUM 114 Celery, raw 32 0 1 0.036 0.02 0.035 0.002 0.085 0.001 0.004
CADMIUM 69 Noodles, egg, enriched, boiled 32 0 0 0.032 0.008 0.032 0.012 0.052 0.002 0.005
CADMIUM 347 Spaghetti, enriched, boiled 32 1 1 0.032 0.011 0.034 0 0.049 0.002 0.005
CADMIUM 137 Potato, baked (with peel) 32 1 0 0.031 0.013 0.031 0 0.065 0.002 0.005
CADMIUM 251 Crackers, graham 32 0 0 0.029 0.011 0.027 0.014 0.068 0.002 0.007
CADMIUM 298 Mustard, yellow, plain 32 1 0 0.029 0.007 0.030 0 0.037 0.002 0.005
CADMIUM 295 Syrup, chocolate 32 1 0 0.025 0.011 0.025 0 0.054 0.002 0.005
CADMIUM 62 Bread, whole wheat 32 0 0 0.025 0.005 0.024 0.019 0.042 0.002 0.007
CADMIUM 66 Crackers, saltine 32 0 0 0.025 0.008 0.023 0.012 0.042 0.003 0.010
CADMIUM 252 Crackers, butter-type 32 0 0 0.024 0.009 0.024 0.008 0.045 0.002 0.007
CADMIUM 115 Asparagus, fresh/frozen, boiled 32 1 5 0.023 0.023 0.016 0 0.097 0.002 0.005
CADMIUM 294 Pretzels, hard, salted 32 0 0 0.023 0.011 0.021 0.011 0.066 0.003 0.010
CADMIUM 142 Spaghetti with meat sauce, homemade 32 1 0 0.023 0.007 0.022 0 0.040 0.002 0.005
CADMIUM 119 Tomato sauce, plain, bottled 32 0 0 0.022 0.006 0.020 0.012 0.043 0.002 0.007
CADMIUM 248 32 1 0 0.022 0.006 0.023 0 0.032 0.002 0.007
wheat)
CADMIUM 317 BF, teething biscuits 31 1 0 0.021 0.013 0.015 0 0.057 0.002 0.007
CADMIUM 187 Candy bar, milk chocolate, plain 32 0 0 0.021 0.008 0.019 0.009 0.040 0.002 0.007
CADMIUM 136 Potato, boiled (without peel) 32 0 0 0.021 0.008 0.02 0.01 0.039 0.002 0.005
CADMIUM 183 Chocolate chip cookies 32 2 0 0.020 0.010 0.021 0 0.042 0.002 0.005
CADMIUM 371 Candy bar, chocolate, nougat, and nuts 32 1 0 0.020 0.008 0.020 0 0.037 0.002 0.007
CADMIUM 259 Carrot, fresh, peeled, boiled 32 0 2 0.019 0.015 0.015 0.002 0.062 0.002 0.005
CADMIUM 58 Bread, white, enriched 32 1 0 0.019 0.006 0.019 0 0.030 0.002 0.007
CADMIUM 61 Biscuits, refrigerated-type, baked 32 0 1 0.019 0.006 0.019 0.006 0.029 0.002 0.007
CADMIUM 250 English muffin, plain, toasted 32 0 0 0.019 0.004 0.019 0.010 0.029 0.002 0.007
CADMIUM 361 Lasagna with meat, frozen, heated 32 0 1 0.019 0.004 0.019 0.004 0.029 0.002 0.007
CADMIUM 63 Tortilla, flour 32 0 0 0.019 0.005 0.019 0.009 0.028 0.002 0.007
CADMIUM 131 Beets, canned 32 1 0 0.018 0.009 0.017 0 0.057 0.002 0.005
CADMIUM 291 Brownie 32 0 0 0.018 0.007 0.017 0.009 0.041 0.002 0.005
Beef stroganoff with noodles,
CADMIUM 269 32 0 0 0.018 0.005 0.018 0.010 0.036 0.002 0.005
homemade
CADMIUM 184 Sandwich cookies w/ crème filling 32 0 1 0.018 0.007 0.018 0.004 0.035 0.002 0.005
CADMIUM 218 BF, carrots 32 1 0 0.017 0.012 0.015 0 0.059 0.002 0.005
CADMIUM 76 Granola with raisins 32 0 0 0.017 0.005 0.016 0.012 0.036 0.002 0.007
Pizza, cheese and pepperoni, regular
CADMIUM 281 32 0 0 0.017 0.003 0.017 0.011 0.022 0.002 0.007
crust, from pizza carry-out
CADMIUM 214 BF, chicken noodle dinner 32 0 0 0.016 0.011 0.014 0.008 0.070 0.002 0.005
CADMIUM 266 Turnip, fresh/frozen, boiled 32 0 1 0.016 0.007 0.015 0.003 0.039 0.002 0.005
Potato salad, mayonnaise-type, from
CADMIUM 353 32 0 0 0.016 0.007 0.014 0.007 0.035 0.002 0.007
grocery/deli
CADMIUM 64 Bread, rye 32 1 1 0.016 0.006 0.016 0 0.029 0.002 0.007
CADMIUM 249 Bagel, plain, toasted 32 1 0 0.016 0.004 0.017 0 0.024 0.002 0.007
CADMIUM 359 Tomato salsa, bottled 32 1 1 0.016 0.005 0.016 0 0.024 0.002 0.005
CADMIUM 86 Strawberries, raw/frozen 32 0 3 0.015 0.010 0.013 0.003 0.044 0.001 0.004
CADMIUM 354 Potatoes, mashed, prepared from fresh 32 0 0 0.015 0.006 0.013 0.006 0.031 0.002 0.005
CADMIUM 178 Cake, chocolate with icing 32 1 0 0.015 0.006 0.014 0 0.029 0.002 0.005
CADMIUM 267 Okra, fresh/frozen, boiled 32 0 0 0.015 0.005 0.014 0.008 0.029 0.002 0.005
CADMIUM 340 Tuna, canned in water, drained 32 0 0 0.015 0.004 0.015 0.009 0.028 0.002 0.007
CADMIUM 272 Tuna noodle casserole, homemade 32 0 1 0.015 0.004 0.015 0.003 0.021 0.002 0.005
CADMIUM 346 Macaroni salad, from grocery/deli 32 0 0 0.015 0.003 0.015 0.010 0.021 0.002 0.007
CADMIUM 125 Pepper, sweet, green, raw 32 0 6 0.014 0.012 0.012 0.003 0.057 0.002 0.005
CADMIUM 128 Onion, mature, raw 32 1 1 0.014 0.010 0.012 0 0.054 0.002 0.005
CADMIUM 356 Carrot, baby, raw 32 0 0 0.014 0.006 0.013 0.006 0.029 0.002 0.005
CADMIUM 285 32 0 1 0.014 0.005 0.013 0.004 0.025 0.002 0.005
Quarter-pound hamburger on bun, fast-
CADMIUM 147 32 1 0 0.014 0.004 0.015 0 0.023 0.002 0.007
food
CADMIUM 370 Granola bar, with raisins 32 0 1 0.014 0.004 0.014 0.005 0.022 0.002 0.007
CADMIUM 220 BF, mixed vegetables 32 0 1 0.013 0.007 0.012 0.003 0.039 0.002 0.005
Page 59 of 69
No.
Chicken filet (broiled) sandwich on bun,
CADMIUM 366 32 0 1 0.013 0.004 0.012 0.006 0.027 0.002 0.007
fast-food
CADMIUM 173 Tomato catsup 32 1 1 0.013 0.004 0.013 0 0.023 0.002 0.007
CADMIUM 212 BF, vegetables and chicken 32 0 0 0.013 0.005 0.013 0.005 0.023 0.002 0.005
CADMIUM 77 Oat ring cereal 32 0 0 0.013 0.003 0.013 0.008 0.021 0.002 0.007
CADMIUM 290 32 0 0 0.013 0.004 0.013 0.005 0.021 0.002 0.005
donut store
CADMIUM 215 BF, macaroni, tomato and beef 32 0 0 0.013 0.004 0.013 0.006 0.019 0.002 0.005
CADMIUM 97 Avocado, raw 32 2 19 0.012 0.012 0.008 0 0.054 0.003 0.010
CADMIUM 211 BF, vegetables and beef 32 1 0 0.012 0.005 0.011 0 0.024 0.002 0.005
Macaroni and cheese, prepared from
CADMIUM 146 32 0 6 0.012 0.005 0.011 0.005 0.022 0.002 0.007
box mix
Quarter-pound cheeseburger on bun,
CADMIUM 275 32 0 2 0.012 0.003 0.011 0.005 0.022 0.002 0.007
fast-food
CADMIUM 345 Breakfast tart/toaster pastry 32 1 0 0.012 0.004 0.012 0 0.021 0.002 0.005
CADMIUM 182 Sweet roll/Danish pastry 32 1 0 0.012 0.003 0.012 0 0.020 0.002 0.005
CADMIUM 265 Eggplant, fresh, peeled, boiled 32 0 6 0.011 0.006 0.011 0.002 0.028 0.002 0.005
CADMIUM 344 Pancakes, frozen, heated 32 0 3 0.011 0.003 0.011 0.006 0.020 0.002 0.007
CADMIUM 278 32 0 2 0.011 0.003 0.010 0.003 0.019 0.002 0.007
fast-food
CADMIUM 261 Tomato juice, bottled 32 1 0 0.011 0.003 0.011 0 0.018 0.001 0.004
Burrito with beef, beans and cheese,
CADMIUM 365 32 0 1 0.011 0.003 0.011 0.005 0.018 0.002 0.007
CADMIUM 276 Fish sandwich on bun, fast-food 32 0 2 0.011 0.002 0.010 0.005 0.017 0.002 0.007
CADMIUM 75 Crisped rice cereal 32 1 9 0.010 0.006 0.009 0 0.028 0.002 0.007
CADMIUM 292 Sugar cookies 32 1 1 0.01 0.005 0.009 0 0.023 0.002 0.005
CADMIUM 60 Cornbread, homemade 32 0 3 0.010 0.004 0.010 0.003 0.021 0.002 0.007
CADMIUM 360 Stew, beef and vegetable, canned 23 0 0 0.010 0.003 0.009 0.006 0.018 0.002 0.005
CADMIUM 213 BF, vegetables and ham 4 0 0 0.010 0.005 0.01 0.005 0.015 0.002 0.005
CADMIUM 116 Cauliflower, fresh/frozen, boiled 32 0 4 0.009 0.005 0.009 0.002 0.030 0.002 0.005
CADMIUM 113 Broccoli, fresh/frozen, boiled 32 0 2 0.009 0.005 0.008 0.004 0.025 0.002 0.005
Taco/tostada with beef and cheese,
CADMIUM 279 32 1 7 0.009 0.004 0.010 0 0.016 0.002 0.007
CADMIUM 34 Fish sticks or patty, frozen, oven-cooked 32 0 2 0.009 0.002 0.009 0.004 0.014 0.002 0.007
CADMIUM 145 Chili con carne with beans, canned 32 0 20 0.008 0.013 0.006 0.003 0.077 0.002 0.007
CADMIUM 117 Tomato, raw 32 2 7 0.008 0.007 0.007 0 0.029 0.001 0.004
CADMIUM 89 Cantaloupe, raw/frozen 32 0 3 0.008 0.004 0.008 0.002 0.018 0.001 0.004
CADMIUM 216 BF, turkey and rice 32 2 8 0.007 0.007 0.006 0 0.044 0.002 0.005
Chicken with vegetables in sauce, from
CADMIUM 363 32 0 11 0.007 0.004 0.006 0.002 0.018 0.002 0.005
Chinese carry-out
CADMIUM 263 Brussels sprouts, fresh/frozen, boiled 32 0 5 0.007 0.003 0.006 0.002 0.017 0.002 0.005
CADMIUM 268 Mixed vegetables, frozen, boiled 32 1 6 0.007 0.003 0.006 0 0.017 0.002 0.005
Fried rice, meatless, from Chinese carry-
CADMIUM 364 32 0 20 0.007 0.003 0.006 0.002 0.016 0.002 0.007
out
Beef with vegetables in sauce, from
CADMIUM 362 32 0 6 0.007 0.003 0.006 0.003 0.015 0.002 0.005
Chinese carry-out
CADMIUM 72 Fruit-flavored cereal, presweetened 32 2 14 0.007 0.003 0.007 0 0.014 0.002 0.007
CADMIUM 152 Chicken potpie, frozen, heated 32 2 6 0.007 0.003 0.008 0 0.013 0.002 0.007
CADMIUM 65 Muffin, blueberry 32 0 7 0.007 0.001 0.007 0.003 0.010 0.002 0.007
Soup, tomato, canned, condensed,
CADMIUM 156 32 0 2 0.007 0.001 0.007 0.004 0.009 0.002 0.005
prepared with water
CADMIUM 244 Shrimp, boiled 32 17 8 0.006 0.014 0 0 0.072 0.002 0.007
CADMIUM 264 Mushrooms, raw 32 0 15 0.006 0.007 0.005 0.002 0.040 0.002 0.005
CADMIUM 50 Rice, white, enriched, cooked 32 1 6 0.006 0.003 0.006 0 0.014 0.002 0.005
CADMIUM 372 Popcorn, microwave, butter-flavored 32 0 29 0.006 0.002 0.005 0.003 0.012 0.003 0.010
Cream of wheat (farina), enriched,
CADMIUM 52 32 1 10 0.006 0.002 0.006 0 0.011 0.002 0.005
cooked
Soup, vegetable beef, canned,
CADMIUM 157 32 1 12 0.006 0.002 0.005 0 0.011 0.002 0.005
CADMIUM 241 Chicken nuggets, fast-food 32 2 15 0.006 0.002 0.006 0 0.010 0.002 0.007
CADMIUM 186 Pie, pumpkin, fresh/frozen 32 2 20 0.006 0.002 0.006 0 0.009 0.002 0.007
Soup, Oriental noodles (ramen noodles),
CADMIUM 367 32 0 10 0.006 0.002 0.006 0.003 0.009 0.002 0.005
prepared with water
Squash, winter (Hubbard/acorn),
CADMIUM 126 31 3 20 0.005 0.006 0.003 0 0.03 0.002 0.005
fresh/frozen, boiled
CADMIUM 110 Cabbage, fresh, boiled 32 0 11 0.005 0.002 0.004 0.002 0.010 0.001 0.004
CADMIUM 185 Pie, apple, fresh/frozen 32 0 29 0.005 0.002 0.005 0.002 0.010 0.002 0.007
Cake, white with icing (formerly yellow
CADMIUM 369 32 0 15 0.005 0.001 0.005 0.003 0.008 0.002 0.005
cake)
CADMIUM 168 32 24 7 0.004 0.019 0 0 0.106 0.002 0.007
liquid/frozen
CADMIUM 29 Bologna (beef/pork) 32 7 25 0.004 0.002 0.004 0 0.008 0.003 0.010
CADMIUM 221 BF, sweet potatoes 32 1 16 0.004 0.002 0.004 0 0.008 0.002 0.005
BF, cereal, rice, dry, prepared with
CADMIUM 324 32 7 22 0.004 0.002 0.004 0 0.008 0.002 0.007
water
BF, cereal, rice with apples, dry,
CADMIUM 325 13 1 11 0.004 0.002 0.003 0 0.008 0.002 0.007
prepared with water
CADMIUM 338 Chicken leg, fried, fast-food (with skin) 32 3 27 0.004 0.002 0.003 0 0.008 0.002 0.007
Coleslaw, mayonnaise-type, from
CADMIUM 355 32 2 26 0.004 0.002 0.004 0 0.008 0.002 0.007
grocery/deli
CADMIUM 358 Sweet potatoes, canned 32 1 15 0.004 0.002 0.005 0 0.007 0.002 0.005
CADMIUM 55 Corn, canned 32 9 20 0.003 0.003 0.002 0 0.018 0.002 0.005
CADMIUM 28 Frankfurter (beef/pork), boiled 32 12 19 0.003 0.003 0.003 0 0.012 0.003 0.010
Chicken breast, fried, fast-food (with
Page 60 of 69
CADMIUM 336 32 6 24 0.003 0.003 0.003 0 0.012 0.002 0.007
skin)
CADMIUM 93 Pineapple, canned in juice 32 8 16 0.003 0.002 0.002 0 0.011 0.001 0.004
No.
Soup, chicken noodle, canned,
CADMIUM 155 32 2 25 0.003 0.002 0.003 0 0.01 0.002 0.005
CADMIUM 341 Refried beans, canned 32 6 24 0.003 0.002 0.003 0 0.009 0.002 0.007
CADMIUM 342 White beans, dry, boiled 32 5 22 0.003 0.002 0.003 0 0.008 0.002 0.005
CADMIUM 373 Sweet & sour sauce 32 4 23 0.003 0.002 0.003 0 0.007 0.002 0.005
CADMIUM 226 BF, peaches 32 3 26 0.003 0.001 0.003 0 0.006 0.002 0.005
CADMIUM 335 Luncheon meat (chicken/turkey) 32 6 23 0.003 0.002 0.003 0 0.005 0.002 0.005
CADMIUM 169 Sugar, white, granulated 32 29 2 0.002 0.007 0 0 0.042 0.004 0.012
CADMIUM 148 Meatloaf, beef, homemade 32 23 7 0.002 0.003 0 0 0.016 0.002 0.007
CADMIUM 333 Sour cream dip, any flavor 32 16 13 0.002 0.003 0.001 0 0.015 0.002 0.007
CADMIUM 20 Pork bacon, oven-cooked 32 20 10 0.002 0.003 0 0 0.011 0.003 0.010
CADMIUM 71 Corn flakes cereal 32 14 15 0.002 0.003 0.003 0 0.011 0.002 0.007
CADMIUM 124 Summer squash, fresh/frozen, boiled 32 15 14 0.002 0.002 0.002 0 0.011 0.002 0.005
CADMIUM 30 Salami, luncheon-meat type (not hard) 32 16 15 0.002 0.003 0.002 0 0.010 0.003 0.010
CADMIUM 67 Corn/tortilla chips 32 17 14 0.002 0.003 0 0 0.010 0.003 0.010
CADMIUM 170 Syrup, pancake 32 17 13 0.002 0.003 0 0 0.01 0.002 0.007
CADMIUM 320 BF, squash 32 17 12 0.002 0.002 0 0 0.010 0.002 0.005
CADMIUM 377 Salad dressing, Italian, regular 32 19 13 0.002 0.003 0 0 0.009 0.004 0.012
CADMIUM 46 Peas, green, fresh/frozen, boiled 32 12 15 0.002 0.002 0.002 0 0.008 0.002 0.005
CADMIUM 54 Corn, fresh/frozen, boiled 32 7 22 0.002 0.002 0.002 0 0.008 0.002 0.005
Pineapple juice, frozen concentrate,
CADMIUM 256 32 4 14 0.002 0.002 0.002 0 0.007 0.001 0.003
reconstituted
CADMIUM 83 Peach, raw/frozen 32 13 15 0.002 0.002 0.002 0 0.006 0.002 0.005
CADMIUM 123 Cucumber, peeled, raw 32 3 23 0.002 0.002 0.002 0 0.006 0.001 0.004
CADMIUM 376 32 14 18 0.002 0.002 0.003 0 0.006 0.003 0.008
low-calorie
CADMIUM 3 Milk, chocolate, lowfat, fluid 32 12 19 0.002 0.001 0.002 0 0.005 0.002 0.005
CADMIUM 81 Watermelon, raw/frozen 32 8 21 0.002 0.001 0.001 0 0.005 0.001 0.004
CADMIUM 161 Dill cucumber pickles 32 15 17 0.002 0.002 0.002 0 0.005 0.002 0.007
CADMIUM 223 BF, peas 32 13 16 0.002 0.002 0.002 0 0.005 0.002 0.005
Soup, bean with bacon/pork, canned,
CADMIUM 283 32 7 24 0.002 0.001 0.002 0 0.005 0.002 0.005
BF, cereal, oatmeal, dry, prepared with
CADMIUM 323 32 6 26 0.002 0.001 0.003 0 0.005 0.002 0.007
water
CADMIUM 38 Pinto beans, dry, boiled 32 6 26 0.002 0.001 0.002 0 0.004 0.002 0.005
CADMIUM 39 Pork and beans, canned 32 6 26 0.002 0.001 0.002 0 0.004 0.002 0.005
CADMIUM 51 Oatmeal, plain, cooked 32 5 27 0.002 0.001 0.002 0 0.004 0.002 0.005
CADMIUM 227 BF, pears 32 10 22 0.002 0.002 0.002 0 0.004 0.002 0.005
CADMIUM 78 Apple (red), raw (with peel) 32 27 3 0.001 0.004 0 0 0.022 0.002 0.005
CADMIUM 10 Cheese, American, processed 32 30 1 0.001 0.002 0 0 0.013 0.003 0.010
CADMIUM 288 Popsicle, fruit-flavored 32 29 2 0.001 0.002 0 0 0.011 0.002 0.007
CADMIUM 162 Margarine, regular (not lowfat), salted 32 25 7 0.001 0.003 0 0 0.010 0.004 0.012
CADMIUM 348 Apricots, canned in heavy/light syrup 32 24 7 0.001 0.002 0 0 0.010 0.002 0.005
CADMIUM 166 Mayonnaise, regular, bottled 32 26 6 0.001 0.003 0 0 0.009 0.004 0.012
CADMIUM 299 Black olives 32 19 12 0.001 0.002 0 0 0.008 0.002 0.005
CADMIUM 7 Milk shake, chocolate, fast-food 32 18 13 0.001 0.002 0 0 0.007 0.002 0.005
CADMIUM 87 Fruit cocktail, canned in light syrup 32 17 13 0.001 0.002 0 0 0.007 0.002 0.005
CADMIUM 225 BF, applesauce 32 26 4 0.001 0.002 0 0 0.007 0.002 0.005
CADMIUM 375 32 26 6 0.001 0.002 0 0 0.007 0.004 0.012
regular
CADMIUM 85 Pear, raw (with peel) 32 17 13 0.001 0.002 0 0 0.006 0.002 0.005
CADMIUM 121 Green beans, fresh/frozen, boiled 32 23 7 0.001 0.002 0 0 0.006 0.002 0.005
CADMIUM 172 Honey 32 27 5 0.001 0.001 0 0 0.006 0.002 0.007
CADMIUM 254 Peach, canned in light syrup 32 24 7 0.001 0.001 0 0 0.006 0.002 0.005
CADMIUM 313 BF, bananas 32 24 6 0.001 0.002 0 0 0.006 0.002 0.005
CADMIUM 17 Ham, cured (not canned), baked 32 28 4 0.001 0.001 0 0 0.005 0.003 0.010
CADMIUM 42 Lima beans, immature, frozen, boiled 32 23 8 0.001 0.001 0 0 0.005 0.002 0.005
CADMIUM 122 Green beans, canned 32 19 12 0.001 0.001 0 0 0.005 0.002 0.005
CADMIUM 164 Butter, regular (not lowfat), salted 32 26 6 0.001 0.002 0 0 0.005 0.004 0.012
CADMIUM 232 BF, custard/pudding 23 17 5 0.001 0.001 0 0 0.005 0.002 0.005
CADMIUM 296 Jelly, any flavor 32 19 12 0.001 0.001 0 0 0.005 0.002 0.005
CADMIUM 350 32 18 12 0.001 0.001 0 0 0.005 0.001 0.003
canned/bottled
CADMIUM 351 Cranberry juice cocktail, canned/bottled 32 8 17 0.001 0.001 0.001 0 0.005 0.001 0.003
CADMIUM 88 Grapes (red/green), raw 32 19 12 0.001 0.001 0 0 0.004 0.001 0.004
CADMIUM 318 Salmon, steaks/fillets, baked 32 24 8 0.001 0.001 0 0 0.004 0.002 0.007
Meal replacement, liquid RTD, any
CADMIUM 331 32 9 21 0.001 0.001 0.001 0 0.004 0.001 0.003
flavor
Pudding, ready-to-eat, flavor other than
CADMIUM 368 32 26 6 0.001 0.001 0 0 0.004 0.002 0.005
chocolate
CADMIUM 374 Brown gravy, canned or bottled 32 21 11 0.001 0.001 0 0 0.004 0.002 0.007
CADMIUM 80 Banana, raw 32 21 11 0.001 0.001 0 0 0.003 0.002 0.005
CADMIUM 199 Wine, dry table, red/white 32 17 14 0.001 0.001 0 0 0.003 0.001 0.003
CADMIUM 207 BF, chicken and broth/gravy 32 25 7 0.001 0.001 0 0 0.003 0.002 0.005
Page 61 of 69
No.
CADMIUM 219 BF, green beans 32 24 8 0.001 0.001 0 0 0.003 0.002 0.005
CADMIUM 233 BF, fruit dessert/pudding 22 13 9 0.001 0.001 0 0 0.003 0.002 0.005
CADMIUM 257 32 12 15 0.001 0.001 0.001 0 0.003 0.001 0.003
reconstituted
CADMIUM 309 BF, Infant formula, soy-based, RTF 32 13 19 0.001 0.001 0.001 0 0.002 0.001 0.003
CADMIUM 84 Applesauce, bottled 32 30 0 0.0004 0.002 0 0 0.008 0.002 0.005
Lemonade, frozen concentrate,
CADMIUM 105 32 26 5 0.0004 0.001 0 0 0.007 0.001 0.003
reconstituted
CADMIUM 79 Orange (navel/Valencia), raw 32 29 2 0.0004 0.001 0 0 0.006 0.002 0.005
CADMIUM 177 Ice cream, light, vanilla 32 28 3 0.0004 0.001 0 0 0.006 0.002 0.005
CADMIUM 167 Cream, half & half 32 29 3 0.0004 0.001 0 0 0.005 0.003 0.010
CADMIUM 99 Apple juice, bottled 32 24 6 0.0004 0.001 0 0 0.004 0.001 0.003
Fruit drink (10% juice), canned or
CADMIUM 307 32 25 5 0.0004 0.001 0 0 0.004 0.001 0.003
bottled
CADMIUM 339 Catfish, pan-cooked with oil 32 28 4 0.0004 0.001 0 0 0.004 0.002 0.007
CADMIUM 92 Grapefruit, raw 32 25 7 0.0004 0.001 0 0 0.003 0.001 0.004
BF, Infant formula, milk-based, low iron,
CADMIUM 203 10 7 3 0.0004 0.001 0 0 0.002 0.001 0.004
RTF
CADMIUM 236 Cheese, Swiss, natural 32 31 0 0.0003 0.002 0 0 0.009 0.002 0.007
Chicken breast, oven-roasted (skin
CADMIUM 240 32 30 2 0.0003 0.001 0 0 0.006 0.002 0.007
removed)
CADMIUM 293 Candy, hard, any flavor 32 30 2 0.0003 0.001 0 0 0.006 0.003 0.010
BF, Infant formula, milk-based, iron
CADMIUM 202 32 29 2 0.0003 0.001 0 0 0.005 0.001 0.004
fortified RTF (formerly high iron)
CADMIUM 237 Cream cheese 32 30 2 0.0003 0.001 0 0 0.005 0.002 0.007
Cottage cheese, creamed, lowfat (2%
CADMIUM 332 32 30 1 0.0003 0.001 0 0 0.005 0.002 0.005
milk fat)
CADMIUM 239 Luncheon meat, ham 32 29 3 0.0003 0.001 0 0 0.004 0.003 0.010
CADMIUM 286 Ice cream, regular (not lowfat), vanilla 32 29 3 0.0003 0.001 0 0 0.004 0.002 0.005
CADMIUM 352 Orange juice, bottled/carton 32 27 4 0.0003 0.001 0 0 0.004 0.001 0.003
CADMIUM 18 Pork chop, pan-cooked with oil 32 28 4 0.0003 0.001 0 0 0.003 0.002 0.007
CADMIUM 95 Raisins 32 29 3 0.0003 0.001 0 0 0.003 0.002 0.007
CADMIUM 255 Pear, canned in light syrup 32 27 5 0.0003 0.001 0 0 0.003 0.002 0.005
CADMIUM 300 Sour cream 32 29 3 0.0003 0.001 0 0 0.003 0.002 0.007
CADMIUM 328 BF, turkey and broth/gravy 32 28 4 0.0003 0.001 0 0 0.003 0.002 0.005
Orange juice, frozen concentrate,
CADMIUM 98 32 25 7 0.0003 0.001 0 0 0.002 0.001 0.003
reconstituted
CADMIUM 379 Vegetable oil 32 31 1 0.0002 0.001 0 0 0.006 0.004 0.012
CADMIUM 235 Yogurt, lowfat, fruit-flavored 32 30 1 0.0002 0.001 0 0 0.005 0.002 0.005
CADMIUM 2 Milk, lowfat (2%), fluid 32 30 1 0.0002 0.001 0 0 0.004 0.002 0.005
CADMIUM 198 Beer 32 28 3 0.0002 0.001 0 0 0.003 0.001 0.003
CADMIUM 334 Beef steak, loin/sirloin, broiled 32 29 3 0.0002 0.001 0 0 0.003 0.002 0.007
Chicken thigh, oven-roasted (skin
CADMIUM 337 32 30 2 0.0002 0.001 0 0 0.003 0.002 0.005
removed)
CADMIUM 53 Corn/hominy grits, enriched, cooked 32 29 3 0.0002 0.001 0 0 0.002 0.002 0.005
CADMIUM 103 Prune juice, bottled 32 28 4 0.0002 0.0004 0 0 0.002 0.001 0.004
CADMIUM 230 BF, juice, apple 32 27 5 0.0002 0.001 0 0 0.002 0.001 0.003
CADMIUM 327 BF, lamb and broth/gravy 17 15 2 0.0002 0.001 0 0 0.002 0.002 0.005
CADMIUM 378 Olive oil 32 31 1 0.0001 0.001 0 0 0.004 0.004 0.012
CADMIUM 19 Pork sausage (link/patty), oven-cooked 32 31 1 0.0001 0.001 0 0 0.003 0.003 0.010
CADMIUM 35 Eggs, scrambled with oil 32 31 1 0.0001 0.001 0 0 0.003 0.002 0.005
CADMIUM 1 Milk, whole, fluid 32 30 2 0.0001 0.001 0 0 0.002 0.002 0.005
CADMIUM 22 Lamb chop, pan-cooked with oil 32 31 1 0.0001 0.0004 0 0 0.002 0.002 0.007
CADMIUM 26 Turkey breast, oven-roasted 32 31 1 0.0001 0.0004 0 0 0.002 0.002 0.005
CADMIUM 100 Grapefruit juice, bottled 31 28 3 0.0001 0.0004 0 0 0.002 0.001 0.003
CADMIUM 191 Carbonated beverage, cola, regular 32 31 1 0.0001 0.0004 0 0 0.002 0.001 0.003
CADMIUM 197 Tea, from tea bag 32 29 3 0.0001 0.0004 0 0 0.002 0.001 0.003
CADMIUM 205 BF, beef and broth/gravy 32 30 2 0.0001 0.001 0 0 0.002 0.002 0.005
CADMIUM 287 Sherbet, fruit-flavored 32 31 1 0.0001 0.0004 0 0 0.002 0.001 0.004
Bottled drinking water (mineral/spring), not
CADMIUM 380 32 31 1 0.0001 0.0004 0 0 0.002 0.001 0.003
carbonated or flavored
CADMIUM 382 Tea, decaffeinated, from tea bag 32 29 3 0.0001 0.0004 0 0 0.002 0.001 0.003
CADMIUM 305 Coffee, from ground 32 29 3 0.0001 0.0003 0 0 0.001 0.001 0.003
CADMIUM 381 Coffee, decaffeinated, from ground 32 29 3 0.0001 0.0003 0 0 0.001 0.001 0.003
CADMIUM 194 Carbonated beverage, cola, low-calorie 32 31 1 0 0.0002 0 0 0.001 0.001 0.003
CADMIUM 4 Milk, skim, fluid 32 32 0 0 0 0 0 0 0.001 0.004
CADMIUM 12 Cheese, cheddar, natural (sharp/mild) 32 32 0 0 0 0 0 0 0.003 0.010
CADMIUM 13 Beef, ground, regular, pan-cooked 32 32 0 0 0 0 0 0 0.002 0.007
CADMIUM 14 Beef roast, chuck, oven-roasted 32 32 0 0 0 0 0 0 0.002 0.007
CADMIUM 21 Pork roast, loin, oven-roasted 32 32 0 0 0 0 0 0 0.002 0.007
CADMIUM 37 Eggs, boiled 32 32 0 0 0 0 0 0 0.002 0.005
CADMIUM 190 Gelatin dessert, any flavor 32 32 0 0 0 0 0 0 0.002 0.005
CADMIUM 193 Fruit drink, from powder 32 32 0 0 0 0 0 0 0.001 0.003
Carbonated beverage, fruit-flavored,
CADMIUM 306 32 32 0 0 0 0 0 0 0.001 0.003
regular
CADMIUM 326 BF, veal and broth/gravy 17 17 0 0 0 0 0 0 0.002 0.005
Page 62 of 69
Appendix E: Lead in Protein Powders - Clean Label Study Data
This section contains the lead and cadmium lab results for 133 protein powders tested in the 2018 clean
label project protein powder study.
LoQ = Level of Quantification ND = Not Detected
2018 Protein Powder Blinded Raw Data Ranked by Higest Lead Ranked by Highest Cadmium
Cadmium Lead Cadmium Lead LoQ Lead Lead LoQ Cadmium Cadmium
Sample (μg/kg) (µg/kg) LoQ (μg/kg) (µg/kg) Sample (µg/kg) (µg/kg) Sample (μg/kg) LoQ (μg/kg)
Sample 1 ND 6.6 2.0 4.0 Sample 9 123.5 4.0 Sample 16 306.5 2.0
Sample 2 25.7 8.0 2.0 4.0 Sample 92 105.2 4.0 Sample 107 219.6 2.0
Sample 4 5.2 ND 2.0 4.0 Sample 93 78.1 4.0 Sample 82 191.7 2.0
Sample 10 ND ND 2.0 4.0 Sample 111 32.3 4.0 Sample 92 130.8 2.0
Page 63 of 69
LoQ = Level of Quantification ND = Not Detected
2018 Protein Powder Blinded Raw Data Ranked by Higest Lead Ranked by Highest Cadmium
Cadmium Lead Cadmium Lead LoQ Lead Lead LoQ Cadmium Cadmium
Sample (μg/kg) (µg/kg) LoQ (μg/kg) (µg/kg) Sample (µg/kg) (µg/kg) Sample (μg/kg) LoQ (μg/kg)
Sample 96 17.7 27.8 2.0 4.0 Sample 4 ND 4.0 Sample 124 2.7 2.0
Sample 101 4.6 ND 2.0 4.0 Sample 23 ND 4.0 Sample 1 ND 2.0
Sample 102 55.1 12.3 2.0 4.0 Sample 25 ND 4.0 Sample 7 ND 2.0
Sample 105 ND ND 2.0 4.0 Sample 33 ND 4.0 Sample 13 ND 2.0
Sample 125 ND 10.7 2.0 4.0 Sample 103 ND 4.0 Sample 105 ND 2.0
Sample 130 52.9 6.0 2.0 4.0 Sample 122 ND 4.0 Sample 126 NDPage 642.0
of 69
Appendix F: Allergies and Medifast/Optavia Product
<This section contains examples found on the web of consumers who suffered from various
allergic/adverse reactions as a result of ingesting MED’s diet products.>
“I don’t have any trouble with whole soy foods--just the protein isolate.”
“I quit Medifast for a very strong soy intolerance. Didn't even realize I had it until I was on Medifast for a
week and gained weight.”
“It is too much soy to eat everyday consistently”
Source: https://www.3fatchicks.com/forum/medifast/233095-soy-protein-intolerance.html
Page 65 of 69
“I’ve been on Medifast for almost 8 weeks and have come down with itching and hive like rash”
“I got it too and it just went away by itself after a few weeks”
“I pretty much know he will insist I go off Medifast at least till the hives are gone and then try it again”
Source: http://www.slimkicker.com/threads/anyone-experiencing-itches-during-medifast#
Page 66 of 69
“The program I was on it is filled with artificial sweeteners which is horrible for gut health”
Source: https://www.consumeraffairs.com/nutrition/medifast.html
Page 67 of 69
Appendix G: Sourcing from China
Nellson LLC, believed to be one of MED’s main and largest contract manufacturers, sources a significant
portion of its ingredients from China, per shipping records:
Nellson 85 97 87.6% 10
Genysis 268 269 99.6% 45
NBTY 282 382 73.8% 39
Nellson and its sourcing from China:

Nellson PIERS Records by Unique Shipper
Country of Origin Shipper
PEOPLES REP OF CHINA ACETAR BIO TECH
PEOPLES REP OF CHINA HANGZHOU QUNLI GELATIN CHEMICAL
PEOPLES REP OF CHINA HUBEI GRAND LIFE SCIENCE AND
PEOPLES REP OF CHINA HUBEI GRAND LIFE SCIENCE AND TECHNOLO
PEOPLES REP OF CHINA NANTONG CHANGHAI FOOD ADDITIVE COMPANY
PEOPLES REP OF CHINA POWER INTERNATIONAL
PEOPLES REP OF CHINA QINGDAO RUNDE BIOTECHNOLOGY
PEOPLES REP OF CHINA RTCO HK
BELGIUM ATLAS COPCO AIRPOWER NV
DENMARK AASTED APS DK KC
FRANCE ORDER
FRANCE ROQUETTE FRERES
GERMANY SOLLICH KG
PERU AGROINDUSTRIA SAN VICENTE
UNITED KINGDOM SERCEL ENGLAND
Nellson subsidiary Genysis and its sourcing from China:

Genysis PIERS Records by Unique Shipper
PEOPLES REP OF CHINA B L LIFE SCIENCES
PEOPLES REP OF CHINA DU HOPE INTERNATIONAL
PEOPLES REP OF CHINA JIANGSU JUBANG PHARMACEUTICAL
PEOPLES REP OF CHINA KUNSHAN WISEPAC DESICCANT
PEOPLES REP OF CHINA NINGBO JINGYUAN TRADE
PEOPLES REP OF CHINA (not listed)
PEOPLES REP OF CHINA NINGBO ZHENHAI HAIDE BIOCHEM COTD
PEOPLES REP OF CHINA PRINCE INTERNATIONAL
PEOPLES REP OF CHINA PRINCEWARE
PEOPLES REP OF CHINA QINGDAO YILONG PACKAGING MACHINERY
PEOPLES REP OF CHINA R AND T COMPANY
PEOPLES REP OF CHINA RTCO HK
PEOPLES REP OF CHINA SHANDONG TIANYUAN HOME TEXTILE COMPANY
PEOPLES REP OF CHINA SHANGHAI GENSYU PRECISION
PEOPLES REP OF CHINA SHANGHAI GENYU PRECISION
PEOPLES REP OF CHINA SHANGHAI YONGLI BELTING PRODUCTS
PEOPLES REP OF CHINA SHENZHEN OURPACK SYSTEM EQUIPMENT
PEOPLES REP OF CHINA SUNRISE BUSINESS
PEOPLES REP OF CHINA SUZHOU SUNRISE IMPORT AND EXPORT
PEOPLES REP OF CHINA WISEPAC ACTIVE PACKAGING COMPONENTS
PEOPLES REP OF CHINA XINFA PHARMACEUTICAL
PEOPLES REP OF CHINA XINJIANG FUFENG BIOTECHNOLOGIES
PEOPLES REP OF CHINA YIFAN XINFU PHARMACEUTICAL
PEOPLES REP OF CHINA YUEQING VANCOL IMPORTS
THAILAND COFCO BIOCHEMICAL THAILAND
Page 68 of 69
Nellson subsidiary NBTY and its sourcing from China:
NBTY PIERS Records by Unique Shipper
PEOPLES REP OF CHINA AHLSTROM NONWOVENS
PEOPLES REP OF CHINA CHINA INTERNATIONAL FREIGHT
PEOPLES REP OF CHINA ED ORIGIN HONG KONG TECHNOLOGY
PEOPLES REP OF CHINA GARDEN BIOCHEMICAL HIGH TECH STOCK
PEOPLES REP OF CHINA INDUS INTERNATIONAL HK
PEOPLES REP OF CHINA JILIN CITY SHENGJI
PEOPLES REP OF CHINA NINGXIA YINGLITE HEBIN METALLURGY
PEOPLES REP OF CHINA NOVOSANA TAICANG
PEOPLES REP OF CHINA ORDER
PEOPLES REP OF CHINA PANJIN TIANYUAN PHARMACEUTICAL COMPANY
PEOPLES REP OF CHINA SAN MARK
PEOPLES REP OF CHINA SHANDONG PHARMACEUTICAL GLASS
PEOPLES REP OF CHINA SHANGHAI JBICHEM INTERNATIONAL TRADING
PEOPLES REP OF CHINA SHENZHEN XINYUE INTERNATIONAL TRADING
PEOPLES REP OF CHINA ULTIMATE BIOPHARMA
PEOPLES REP OF CHINA ZHEJIANG GARDEN BIOCHEMICAL
PEOPLES REP OF CHINA ZHEJIANG SHENGDA PHARMACEUTICAL
PEOPLES REP OF CHINA ZHEJIANG ZHENGDA TEXTILE PRINTINS
REPUBLIC OF CHINA COSTCO PRESIDENT TAIWAN
REPUBLIC OF CHINA HERBALIFE TAIWAN TAIWAN
AUSTRALIA AUSTRALIAN BOTANICAL PRODUCTS
BRAZIL SANRISIL SA INDUSTRIA E COMERCIO
FRANCE ROQUETTE FRERES
GERMANY GLATT
GERMANY GLATT SYSTEM TECHNIK
GERMANY MASCHINPEX MASCHINENBAU
GERMANY (not listed)
HONG KONG HANDIWARES COMPANY
HONG KONG JARLUNG H K
ITALY OIMA
ITALY ROMANO
JAPAN NITTA GELATIN NA
NETHERLANDS AKZO NOBEL CHEMICALS AG
NETHERLANDS METALERT SA E
NETHERLANDS ORDER
NETHERLANDS (not listed)
REPUBLIC OF KOREA JILIN CITY SHENGJI
REPUBLIC OF KOREA NORTHEAST PHARM IMPORT AND EXPORT
REPUBLIC OF KOREA (not listed)
SPAIN BTSABIOTECNOLOGIAS APLICADASSLU
UNITED KINGDOM HOLLAND AND BARRETT VITALITY HOUSE
UNITED KINGDOM OHSO GOODNESSE
UNITED KINGDOM ORDER
UNITED KINGDOM (not listed)
UNITED KINGDOM PR ORGANICS
UNITED KINGDOM ROT ORGANICS
UNITED KINGDOM TRUE ORGANICS
VIETNAM SHANGHAI JBICHEM INTERNATIONAL TRADING
VIETNAM SUNTZE CHEMICAL
Page 69 of 69

Medifast (NASDAQ: MED) : Like Lumber Liquidators, But With Undisclosed Toxic Metals, and A Supply Chain Twist PART I

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Medifast (NASDAQ: MED) : Like Lumber Liquidators, But With Undisclosed Toxic Metals, and A Supply Chain Twist PART I

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GOTHAM CITY RESEARCH LLC

Medifast (NASDAQ: MED): Like Lumber Liquidators,

Question #2 : 24 years later, is history about to rhyme?

GOTHAM CITY RESEARCH’S OBSERVATIONS Share price information:

Price as of 9/19/18: $208

New Brand, Same old tricks? Our Preliminary Suspicions

By cutting corners, as described above, Gotham City Research believes that:

• MED has violated its customers and coaches’ trust.

Clean Label Project Protein Powders Optavia

The following reasons lead us to believe the comparison is appropriate:

The following reasons lead us to believe the comparison is concerning:

LEAD 350it vigorously disputed the accuracy

LEAD 720inference that MED believed the 2009

Our investigation reveals the following:

Our investigation into the raw materials warehouse reveals:

PIERS Country of Total PIERS Country of Origin = # of FDA

• Nellson filed for chapter 11 bankruptcy in 2008.

▪ Utah records suggest MED is conducting manufacturing activities in Utah.

Jason Pharmaceuticals, Texas is listed as an importer of foreign food

PIERS Import Records from ARLA FOODS to Jason Pharmaceuticals

Name Ingredient Label claim

Optavia Caramel Macchiato Shake (Calcium Caseinate is #1 ingredient!):

PIERS Country of Total PIERS Country of Origin = # of FDA

Why Does Medifast Unreservedly Claim Made in the USA?

MED's PP&E has declined every single year since 2012

Net CapEx + R&D as % of revenue 2015 2016 2017

As of 2012, MED had intellectual property assets on its balance sheet:

10K Filing Year: 2002 2013 2017

Archived here: https://web.archive.org/web/20180815034449/http://www.optaviaevents.com/new-

• we handle all major allergens (except shellfish)

Cadmium Cadmium Cadmium

Clean Label Project Protein Powders Optavia

22 FDA citations for Hearthside:

To read more about toxic metals in cigarettes please read:

Valuation Method and Assumptions: scenarios-based approach

Our weighted average price target of $79 is arrived at by a 3-scenario approach:

EPS Multiple Probability Price

Weighted average price target: $79

Additional Valuation Considerations – Legal/Regulatory, and China

"Naturally occurring" AND reduced to the "lowest level currently feasible"

§ 25501. Exposure to a Naturally Occurring Chemical in a Food.

EXEMPTION APPLICABLE COMMENT

Governmental agencies and public NO MED is neither a governmental agency nor

Sources and useful links for more information:

The words “Health” or “Healthy” are used throughout Optavia’s homepage:

Optavia Teen Boys Plan uses the word “safely”

So does the Teen Girls Plan:

Diabetes Plan uses “safely”:

Age 65 or older, “safely” once again is used:

“Medifast is safe and effective”:

Medifast for Nursing mothers uses safe twice:

Medifast plan for Gout, “safely”:

Optavia for Gout, “safely”:

Made in the USA claim vs our understanding

Source: ebay https://www.ebay.com/itm/Optavia-Chocolate-Mint-Cookie-Crisp-Bar-7-

Optavia Calorie Burn Cappuccino:

Optavia Velvety Hot Chocolate:

Medifast Calorie Burn Cappuccino:

“It is too much soy to eat everyday consistently”

Nellson and its sourcing from China:

Nellson subsidiary Genysis and its sourcing from China:

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