Many of you are aware of the current ad on the Mead Johnson website in 
which the title tab of the site states "The Breast Milk 
Formula-Enfamil." You can see this at 
http://www.enfamil.com/app/iwp/enfamil/productDetail.do?dm=enf&id=-10733&iwpst=B2C&ls=0&csred=1&r. 
I sent a complaint to the Federal Trade Commission at www.FTC.gov which 
you can read below. Please consider sending a letter. It is quick and 
easy. The FTC needs hundreds of letters regarding this breech of the 
law. You are welcome to use my letter as a template or in any way you 
see fit. We all become outraged when we see this type of ad but it is 
time to do something about it. Now is the time. Breastfeeding is under 
fire from all sides and we need to speak in large numbers for those who 
cannot. NABA and the Cornucopia Institute jointly filed a petition to 
the FTC about how companies were marketing formula with DHA/ARA in it, 
which can can read at www.cornucopia.org in a report entitled 
"Replacing mother-imitating human breast milk in the laboratory." If we 
could get 1000 letters sent about the Mead Johnson website, perhaps the 
FTC will start looking into this. Time to act!

Marsha Walker, RN, IBCLC
Weston, MA


I wish to register a complaint regarding text contained at the 
following Mead Johnson website:
http://www.enfamil.com/app/iwp/enfamil/productDetail.do?dm=enf&id=-10733&iwpst=B2C&ls=0&csred=1&r
Mead Johnson manufactures infant formula and markets it in a manner 
that is false and misleading to consumers. The title tab at the above 
website states "The Breast Milk Formula-Enfamil." This deceptive text 
could lead consumers to believe that Enfamil formula is the same as 
breastmilk and cause them to purchase this product thinking that it 
will produce the same health outcomes as feeding an infant human milk. 
Enfamil formula contains fungal and algal sources of DHA and ARA which 
are metabolized differently than human milk-derived DHA and ARA. Mead 
Johnson has been cautioned by the FTC to refrain from overstating the 
health benefits from these fatty acids yet has escalated the claims to 
the point where the company represents infant formula as the same thing 
as human milk.

My organization, the National Alliance for Breastfeeding Advocacy 
(NABA) and the Cornucopia Institute jointly filed a petition with the 
FTC on January 24, 2008 requesting the investigation into false and 
misleading claims by formula manufacturers regarding these fatty acids 
as possible violations of the law (15 USC 45). This particular ad is 
misleading, as scientific data to support the claim is inconclusive. 
There is no data that supports infant formula being equivalent to human 
milk. There is grave likelihood that consumers will reply on misleading 
claims about DHA/ARA when making important decisions about infant 
feeding methods. The US Department of Health and Human Services states 
improvement in breastfeeding goals for the nation in its Healthy People 
2010 document. The US government invests hundreds of millions of 
dollars to support breastfeeding which is neutralized when deceptive 
claims for infant formula are allowed to dupe parents into thinking 
that infant formula is the same as breastmilk.

The FTC is under a legal duty to end misleading advertisements under 
Section 5 of the Federal Trade Commission Act, 15 USC 45. The FTC has 
described a misleading advertisement as a representation, omission, or 
practice that is likely to mislead the consumer. In the case of DHA/ARA 
as advertised on this website, there is a high likelihood that 
consumers will be mislead into believing that this formula offers 
benefits to their infant's development, when scientific research shows 
that this is an unproven conclusion. This deception can cause harm to 
both mother and infant by falsely claiming that infant formula is an 
equally good way of feeding an infant.

I urge the FTC to thoroughly investigate this matter pursuant to your 
authority, including but not limited to the issuance of a civil 
investigative demand. Implying that Enfamil formula is human milk in a 
can is a practice that is likely to affect the consumer's conduct or 
decision with regard to purchasing this product. Abandoning the 
provision of human milk has been shown to result in less optimal health 
outcomes and the expenditure of billions of health care dollars for 
diseases and conditions preventable by breastfeeding.

I respectfully urge the FTC to take immediate action against Mead 
Johnson in fulfillment of 15 USC 45.

Marsha Walker, RN, IBCLC

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