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Wednesday, 9 March 2011
Amazon UK are still breaking the law
This is Karin Mont, a homeopath who lives in Sussex.
Karin isn't the kind of homeopath who restricts their practise to treating nebulous "symptoms".
In actual fact, she's the kind of homeopath who advocates homeopathy as a treatment for cancer.
"I have always enjoyed the writings of Catherine Coulter... In A Homeopathic Approach To Cancer... she concentrates on bringing together the case notes and clinical observations of the well-known Indian homeopath, Dr. Ramakrishnan [who] has treated literally thousands of cases of cancer..."
Wisely, these words don't appear anywhere in her advertising, but in a book review published in the April 2003 edition of Homeopathy in Practice.
How seriously does Karin believe should the "treatments" be considered? The words below, as well as the words above, are hers:
"In the second chapter, the main cancer remedies are identified, then sub-divided into three groups to facilitate referencing... 1. Nosodes, mainly Carcinosin and Scirrinum... 2. Remedies used in cancers of many types, such as Arsenicum, Conium and Thuja... 3. Organ-specific remedies, including Ceanothus (spleen, pancreas, liver), Terebinthina (bladder), Plumbum iodatum (brain), Hecla lava (bone, bone marrow), Sabal serrulata (prostate), and Hydrastis (stomach)..."
Wait a moment - we're getting to the best bit -
"There are a number of examples given of the successful treatment of cancer."
Promoting a cure for cancer would normally an offence under the Cancer Act 1939, but this is a book review, and an eight-year-old one at that. Perhaps Karin's enthusiasm was a one-off folly of youth?
To help you decide, here are some more of her writings:
"Homeopathy's success at treating the Spanish flu outbreak of 1918 is well documented, especially in the USA. The medical records of hospitals across the country consistently show a mortality rate of above 28% in sufferers treated conventionally, as opposed to a mortality rate of just over 1% of those treated with homeopathy."
It goes without saying that these ravings - which appear in an article by another author - are not in any way congruent with reality.
Karin is described as having a "thriving" practice, but I can find few details about it. Most of her energy seems to be spent on one of the few clubs willing to have her as a member - the comparably loony Alliance of Registered Homeopaths, of which she is a founder.
But - getting back to that dodgy cancer claim - in these days of heightened regulatory pressure, would anyone dare make such a claim now?
Here is one company who would. Perhaps you've heard of them. They're a little bookshop near Milton Keynes called 'Amazon', and this is the second time I've written about them.
ASA complaint follows!
"I'm writing to complain about marketing claims made on the Amazon UK website, www.amazon.co.uk
A search for "cancer" on the site turns up hundreds of adverts for books which can be bought through the site, some from Amazon directly, some from independent booksellers.
I think that in a great many cases the adverts, as distinct from the contents of the books, are in breach of the CAP Code.
To avoid labouring a point, I've included here only the first five adverts I found.
1
URL:
http://www.amazon.co.uk/Cancer-curable-under-Homeopathic-treatment/dp/B003ZYXA14/ref=sr_1_1?ie=UTF8&qid=1299698108&sr=8-1
Mirrored at:
http://www.freezepage.com/1299699921JLZMEMRVBN
Book title:
"Cancer curable under Homeopathic treatment" by Dr P.S Kamthan
Product description:
Dr Kamthan was an eminant physician with a busy practice. He is the author of many small books on various Homeopathic subjects having gained his experience from many years of clinical practice. This interesting book gives Homeopathic remedies and their indications for many types of cancers including: - brain tumour, eye tumours and ulcers, malignant ulceration of the nose, throat, mouth, tongue, lips, larynx, lungs, breast, stomach, liver, female genitals, penis, scrotum, rectal and bladder cancers. He gives the name of the person who made the observation for each of the indications.
Complaint:
Does the CAP Code permit the advertising of this book? Does the product description exaggerate the validity of the book's contents?
2
URL:
http://www.amazon.co.uk/Homoeopathic-Approach-Cancer-U-Ramakrishnan/dp/1576261557/ref=sr_1_7?ie=UTF8&qid=1299698108&sr=8-7
Mirrored at:
http://www.freezepage.com/1299699997BMGLEUDDBV
Book title:
"A homoeopathic Approach to Cancer" by A.U.Ramakrishnan, Catherine R Coulter
Complaint:
Does the CAP Code permit the advertising of this book?
3
URL: http://www.amazon.co.uk/Family-Guide-Homeopathy-Medicine-Future/dp/0241135729/ref=sr_1_10?ie=UTF8&qid=1299698108&sr=8-10
Mirrored at:
http://www.freezepage.com/1299700041ZEHZHMRPIM
Book title:
"The Family Guide to Homeopathy: The Safe Form of Medicine for the Future"
Product description:
"A comprehensive guide to homeopathic medicine. Practical and realistic advice on safe treatments for every condition from colds to cancer. It also provides nutritional and lifestyle advice and a section on prevention of disease and health maintenance."
Complaint:
Does the product description exaggerate the validity of the book's contents? Can the claim that there are homeopathic treatments for colds and cancer be substantiated?
4
URL:
http://www.amazon.co.uk/Tlacote-Water-30C-Homeopathic-Tablets/dp/B003YM9HGE/ref=sr_1_11?ie=UTF8&qid=1299698108&sr=8-11
Mirrored at:
http://www.freezepage.com/1299700151KNJHALSWBK
Product:
"Tlacote Water 30C Homeopathic Tablets x 125"
Product features:
"...Famous remedy made from healing water. Reputed to have a wide range of activity in curing disease...."
Complaint:
Does the advert contain therapeutic indications not found on the product's label?
5.
URL:
http://www.amazon.co.uk/Natural-Herbal-Cures-Remedies-Discover/dp/B0046LV9FY/ref=sr_1_41?ie=UTF8&qid=1299699145&sr=8-41
Mirrored at:
http://www.freezepage.com/1299700202UNRCLAXCEJ
Book Title:
"Natural Herbal Cures & Remedies - Discover the Natural Herbal Cures and Remedies Used to Treat Illness and Disease for Hundreds of Years!"
Product Description:
Discover the Natural Herbal Cures and Remedies Used to Treat Illness and Disease for Hundreds of Years - STOP Using Unnecessary Drugs and Pills, and Learn the Natural Cures Doctors Never Informed You About!
"What the Drug and Pill Companies Don't Want You to Know About!"
Considering the mass amount of doctors and specialists in the medical industry, only a handful of specialists in various parts the world promote the use of natural remedies to treat disease. The fact is, there are alternative ways to cure and prevent disease - Also, erradicate them. There are also natural, non-drug and non-surgical ways to cure and prevent virtually every disease, but drug and food companies never promote these methods of treatment because pharmaceutical drugs and treatments are big money...and that's the truth.
Until now, the public has been deceived by a highly organized and extremely well financed advertising from the media. Fake claims have been passed off and we now believe that the only way to treat any symptoms of illness or disease to purchase off-the-counter drugs. This is simply not true!
"What's The Wisest Way to Cure Your Disease?"
Based on scientific evidence, it is clear that the safest and most effective treatment for various diseases are right in our households...A mixture of natural fruits, vegetables and herbs are some of things needed to prevent or cure disease. I'm not teaching you how to make a fruit salad - With the right combination of ingredients, a cure can be created in the privacy of your own home!
Complaint:
Can the claims in the product description be substantiated? Does the advert discourage consumers from seeking essential medical treatment?"
More Homeopaths Caught In The Act
The task of spotting misleading claims on homeopathic websites is proving even easier than anyone thought.
Of the three thousand or so homeopaths who are already on my little list, I've chosen three, entirely at random. Let's find out whether they're complying with their responsibilities.
(This is quite a long post, but stay with me. There's a good punchline coming up.)
Pictured above is Sue Berry who runs an "Online Homeopathic Consultation" service. Leaving aside the ethics of dispensing licensed medicines to people who might be anywhere in the world except sitting in front of you - how does Sue's sales pitch bear up?
"So, when I am asked, 'what can you treat' my answer is anyone experiencing symptoms of dis-ease."
No problems so far. The placebo effect can be very convincing.
But wait, there's more!
"WHAT HOMEOPATHIC TREATMENT CAN DO FOR YOU - Help with many health problems, physical, mental or emotional - Treat all dis-ease..."
Sue doesn't clarify exactly which "all dis-eases" she imagines she can "treat", but the claims she makes for her Homeopathic First Aid Remedy Kits are rather less vague.
"Perfect for treating people experiencing the most common... injuries, such as common cold, shock, insect bites, upset stomach and fevers... treats measles and meningitis... Treats infections and infected wounds... Treats mouth ulcers and colds... Treats bronchitis, laryngitis and haemorrhages... Supports the liver... Aids bone and teeth formation... treats colic... Excellent remedy for (whooping) cough..."
The second test subject is June Sayer, who runs a complementary health clinic in Southend. According to her own biography:
"June's enthusiasm and passion for homeopathy has given her the opportunity of treating a variety of people who have been suffering from a wide range of complaints both acute and chronic during the 18 years she has been in practice"
June isn't reticent in naming them.
"Homeopathy is known to be able to treat many conditions - a few of those that have been successfully helped by homeopathic treatment are: A[ttention] D[eficit] H[yperactivity] D[isorder]... Allergies (food sensitivities)... Asthma... Acne... Eczema... Hay-fever and other seasonal allergies... Psoriasis... Female problems..."
Our last hope is Nigel Bird. Nigel is a qualified pharmacist who moonlights as a magical potion salesman. His mastery of modern pharmacology is neatly summarised in his own words:
"There [are] over 4,500 remedies available tro [sic] treat all disease from babies and children to adults of any age"
Yes, he really did say all disease. To underline the point, he claims that homeopathy is "proven" to treat
"...malaria..."
That particular delusion was the final straw for me. This afternoon I quickly fired off letters of protest to the Advertising Standards Authority (ASA).
I've also raised the matter with Trading Standards and lodged formal complaints with the trio's professional organisation, the hilariously-titled Alliance of Registered Homeopaths (ARH).
By an astonishing coincidence, the three homeopaths that I chose "entirely at random" from a "list of three thousand" happen to be the, errr... the Board of Directors of the Alliance of Registered Homeopaths!
Nigel is in charge of annoying real doctors, June is the "Company Secretary" and Sue is responsible for "Ethics and Welfare". Which presumably means that she'll soon be investigating herself!
SUE BERRY - ASA COMPLAINT
I'm writing to complain about the marketing claims I read today (9th March 2011, at 1pm) on the website www.hrfa.co.uk
The site - which redirects to another UK-based site, www.homeopathyremediesforall.com - promotes the services of Susan Berry, a homeopath who lives in Sussex.
The pages in question are too big for a screenshot, so I've used a mirroring website. The ASA online complaints form doesn't accept HTML files yet, but I have saved a copy and can send them to you, if necessary.
1. The main page of the site makes a number of health claims for homeopathy. I'd like to challenge if the advertiser can substantiate any of them.
http://www.homeopathyremediesforall.com/index.asp
http://www.freezepage.com/1299675983VHBLERZSIJ
(i) "So, when I am asked, 'what can you treat' my answer is anyone experiencing symptoms of dis-ease."
(ii) "Homeopathic treatment helps our bodies to heal."
(iii) "WHAT HOMEOPATHIC TREATMENT CAN DO FOR YOU - Help with many health problems, physical, mental or emotional - Treat all dis-ease, together with conventional medicine, or on its own..."
(iv) "...homeopathy can also help your pets..."
2. Another page promotes "Homeopathic First Aid Remedy Kits". The kits are introduced as follows:
http://www.homeopathyremediesforall.com/Homeopathic_First_Aid_Remedy_Kits.asp
http://www.freezepage.com/1299676038WOQTXIVVDW
"Homeopathy for All's First Aid Remedy Kits are ideal for home use. Each kit contains a selection of 10 remedies to treat common symptoms. Each remedy is contained in a bottle, which holds approximately 35 doses in pillule form... Each of our remedy kits cost £15 (plus £3.50 UK... postage and packaging)"
3. I'd like to challenge whether the advertiser can substantiate any of the following health claims. I'd also like to challenge whether the claims are misleading, whether the advertising contains claims about licensed homeopathic remedies which do not appear on the labels, whether the claims that homeopathy "treats" life-threatening conditions such as "measles", "meningitis", "shock" and "infected wounds" are irresponsible, and whether the advertising fails to include a warning to consult a medical doctor if symptoms persist (not including the claim for meningitis):
(i) The "First Aid Remedy Kit" is "Perfect for treating people experiencing the most common... injuries, such as common cold, shock, insect bites, upset stomach and fevers"
(ii) The "Remedy" Apis "Also treats... measles and meningitis"
(iii) The "Remedy" Hepar-Sulph 30 "Treats infections... and infected wounds"
(iv) The "Remedy" Mercury "Treats mouth ulcers and colds"
(v) The "Remedy" Phosphorus "Treats bronchitis, laryngitis and haemorrhages"
(vi) The "Remedy" Chelidonium 6X "Supports the liver"
(vii) The "Remedy" Ledum and Hypericum can treat "wounds that will not heal"
(viii) The "Remedy" Ant Tart "Treats coughs, fever and mucus in the airways"
(ix) The "Remedy" Calc Carb "Aids bone and teeth formation"
(x) The "Remedy" Chamomilla is the "No. 1 remedy for teething children" and "treats colic"
(xi) The "Remedy" Pulsatilla "Treats emotional mood swings in babies"
(xii) The "Remedy" Drosera is an "Excellent remedy for (whooping) cough"
4. I can confirm that I have no connections with the alternative medicine industry.
SUE BERRY - ARH COMPLAINT
Dear Sir/Madam,
I write to lodge a formal complaint against Sue Berry, MARH.
The matter concerns the contents of Ms Berry's websites www.hrfa.co.uk and www.homeopathyremediesforall.com - the first one redirects to the second, and both contain identical content; additionally, the first is promoted on the Alliance's "Find a Homeopath" register.
I argue that Ms Berry may be responsible for multiple breaches of the Alliance's "Code of Ethics and Practice", specifically Sections 31, 36 and 37.
INTRODUCTION
1. The Advertising Standards Authority (ASA) is the voluntary regulator for all marketing in the UK.
2. On 1st March 2011, the ASA's remit was extended to embrace online marketing activities, including "companies’ own marketing claims on their own websites and in other non-paid for space they control" (http://www.asa.org.uk/Media-Centre/2011/New-online-remit-enhances-consumer-protection.aspx)
3. For marketing communications promoting homeopathic products and services, the relevant sections of the British Code of Advertising Practice (CAP Code) include:
(i) Section 3.1 'Marketing communications must not materially mislead or be likely to do so.'
(ii) Section 3.7 'Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.'
(iii) Section 3.11 'Marketing communications must not mislead consumers by exaggerating the capability or performance of a product.'
(iv) Section 3.13 'Marketing communications must not suggest that their claims are universally accepted if a significant division of informed or scientific opinion exists.'
(v) Section 3.47 'Claims that are likely to be interpreted as factual and appear in a testimonial must not mislead or be likely to mislead the consumer.'
(vi) Section 12.1 'Objective [health] claims must be backed by evidence, if relevant consisting of trials conducted on people. If relevant, the rules in this section apply to claims for products for animals. Substantiation will be assessed on the basis of the available scientific knowledge...'
(vii) Section 12.2 'Marketers must not discourage essential treatment for conditions for which medical supervision should be sought.'
(viii) Section 12.5 'Marketers inviting consumers to diagnose their minor ailments must not make claims that might lead to a mistaken diagnosis.'
(ix) Section 12.6 'Marketers should not falsely claim that a product is able to cure illness, dysfunction or malformations.'
(x) Section 12.7 'References to the relief of symptoms or the superficial signs of ageing are acceptable if they can be substantiated.'
(xi) Section 12.10 'Marketing communications must not suggest that any product is safe or effective merely because it is “natural” or that it is generally safer because it omits an ingredient in common use.'
(xii) Section 12.14 'Marketers must not use fear or anxiety to promote a medicine or a recovery from illness and must not suggest that using or avoiding a product can affect normal health.'
(xiii) Section 12.15 'Illustrations of the effect or action of a product should be accurate.'
(xiv) Section 12.19 'Marketing communications for a medicine may not claim that its effects are as good as or better than those of another identifiable product.'
(xv) Section 12.20 'Homeopathic medicinal products must be registered in the UK. Any product information given in the marketing communication should be confined to what appears on the label. Marketing communications must include a warning to consult a doctor if symptoms persist. Marketing communications for an unlicensed product must not make a medicinal or therapeutic claim or refer to an ailment unless authorised by the MHRA to do so.'
4. Sections 36 and 37 of the Alliance's Code of Ethics state that all registrants are expected to observe the CAP Code in their marketing materials:
(i) '36. All advertising must be published in a way that conforms to the law and to the guidance issued in the British Code of Advertising Practice.'
(ii) '37. Professional advertising must be factual and not seek to mislead or deceive, or make unrealistic or extravagant claims...'
5. In addition, Section 31 states:
(i) '31. Registrants must observe and keep up to date with all legislation and regulations relating directly or indirectly to the practice of homeopathy.'
REGULATION
6. It is not in dispute that many of the Alliance's registrants hold the opinion that homeopathy is effective for a range of medical conditions; neither is it in dispute that these beliefs are held sincerely.
7. The only matter of importance is a registrant's compliance or non-compliance with the advertising regulations to which they are professionally bound.
8. At present, the Committee of Advertising Practice (CAP) do not accept that claims for the efficacy of homeopathy have been substantiated by rigorous clinical evidence:
(i) "Despite its popularity, CAP understands that no scientific rationale exists for assuming that remedies lacking in pharmacologically active molecules can produce clinical effects and is unaware of robust evidence that proves it does." (http://www.copyadvice.org.uk/Ad-Advice/Advice-Online-Database/Therapies-Homeopathy.aspx)
9. Section 12.1 of the CAP Code, quoted earlier, requires that all marketers hold substantiation, in the form of rigorous clinical evidence, before making health claims in their marketing materials.
COMPLAINT
10. I complain that Ms Berry may have breached the Alliance's Code of Ethics in respect of the following marketing claims found on her website, on March 9th 2011. (I give the full URL of the page, and a mirrored copy of the page as it was on that date.)
http://www.homeopathyremediesforall.com/index.asp
http://www.freezepage.com/1299675983VHBLERZSIJ
(i) "So, when I am asked, 'what can you treat' my answer is anyone experiencing symptoms of dis-ease."
(ii) "Homeopathic treatment helps our bodies to heal."
(iii) "WHAT HOMEOPATHIC TREATMENT CAN DO FOR YOU - Help with many health problems, physical, mental or emotional - Treat all dis-ease, together with conventional medicine, or on its own..."
(iv) "...homeopathy can also help your pets..."
http://www.homeopathyremediesforall.com/Homeopathic_First_Aid_Remedy_Kits.asp
http://www.freezepage.com/1299676038WOQTXIVVDW
(v) The "First Aid Remedy Kit" is "Perfect for treating people experiencing the most common... injuries, such as common cold, shock, insect bites, upset stomach and fevers"
(vi) The "Remedy" Apis "Also treats... measles and meningitis"
(vii) The "Remedy" Hepar-Sulph 30 "Treats infections... and infected wounds"
(viii) The "Remedy" Mercury "Treats mouth ulcers and colds"
(ix) The "Remedy" Phosphorus "Treats bronchitis, laryngitis and haemorrhages"
(x) The "Remedy" Chelidonium 6X "Supports the liver"
(xi) The "Remedy" Ledum and Hypericum can treat "wounds that will not heal"
(xii) The "Remedy" Ant Tart "Treats coughs, fever and mucus in the airways"
(xiii) The "Remedy" Calc Carb "Aids bone and teeth formation"
(xiv) The "Remedy" Chamomilla is the "No. 1 remedy for teething children" and "treats colic"
(xv) The "Remedy" Pulsatilla "Treats emotional mood swings in babies"
(xvi) The "Remedy" Drosera is an "Excellent remedy for (whooping) cough"
RESOLUTION
11. I have never been a patient of Ms Berry, nor do I have any connection with her, nor do I have any conflicts of interest to declare. I write in the capacity of a concerned member of the public.
12. Because I have no personal connections with Ms Berry which might admit of an informal resolution, I have considered the Code's advice (Section 59) and opted not to implement "Stage One" of the complaints process (Section 60) but am instead making a written complaint to the PCO (Section 61).
13. There are two possible routes which might lead to a speedy resolution of the complaint:
(i) Ms Berry might produce new clinical evidence, not yet considered by CAP and of sufficient quality to substantiate all the marketing claims she makes in her websites
(ii) Ms Berry might accept the PCO's advice that her claims are not substantiated, are not "factual", are "unrealistic" or "extravagant", and undertake to remove the claims from her websites and all future marketing materials
14. I will readily agree to any resolution proposed by the PCO or Ms Berry that achieves either of these two objectives.
JUNE SAYER - ASA COMPLAINT
I'm writing to complain about the marketing claims I read today (9th March 2011, at 1pm) on the website www.sapphirecentre.co.uk
The site promotes the services of June Sayer, a homeopath.
The pages in question are too big for a screenshot, so I've used a mirroring website. The ASA online complaints form doesn't accept HTML files yet, but I have saved a copy and can send them to you, if necessary.
1. The site promotes the "Sapphire Complementary Health and Training Centre" in Southend. The Centre offers a number of complementary health treatments.
2. The site explains June Sayer's role in the provision of its homeopathy services:
http://www.sapphirecentre.co.uk/index.php?page=about-sapphire-centre-southend
http://www.freezepage.com/1299676405ZMQHFSSEZK
(i) "The centre is run by June Sayer who has a wealth of experience within the field of complementary health."
http://www.sapphirecentre.co.uk/index.php?page=june-blog
http://www.freezepage.com/1299676476PHNEYWQJSL
(ii) "June's deep love of the healing art of Homeopathy culminated in her opening Sunningdale College of Homeopathy in 2003 as a training centre for people wishing to train for an independent career in homeopathy. The college is now known as Sapphire Complementary Health & Training Centre and is based in the centre of Southend. June teaches all aspects of the homeopathic training course and continues to carry on her practice at this centre."
3. The site makes a number of health claims for the efficacy of homeopathy. I'd like to challenge whether the advertiser can substantiate any of them.
http://www.sapphirecentre.co.uk/index.php?page=homeopathy
http://www.freezepage.com/1299676504DGJRTBSSCO
(i) Homeopathy "works" by "stimulating the body's natural defense [sic] system to promote health and well-being"
(ii) "Homeopathy is known to be able to treat many conditions"
(iii) The advertiser has "successfully helped", using her "homeopathic treatment", "A[ttention] D[eficit] H[yperactivity] D[isorder]... Allergies (food sensitivities)... Asthma... Acne... Eczema... Hay-fever and other seasonal allergies... Psoriasis... Female problems..."
(iv) "...homeopathy works by treating the patient, not the disease"
http://www.sapphirecentre.co.uk/index.php?page=june-blog
http://www.freezepage.com/1299676559STEBFUZLYK
(v) "June's enthusiasm and passion for homeopathy has given her the opportunity of treating a variety of people who have been suffering from a wide range of complaints both acute and chronic during the 18 years she has been in practice"
(vi) "Homeopathy... has been known to help where other treatments may not have"
(vii) Homeopathy can be "safely used at home in first-aid situations"
4. I'd also like to challenge whether the following claim misleadingly implies that homeopathy is safe or effective because it is "natural":
http://www.sapphirecentre.co.uk/index.php?page=homeopathy
http://www.freezepage.com/1299676504DGJRTBSSCO
() "...homeopathic remedies are natural, safe, non-toxic and non-addictive and can be used by anyone at any stage including by children, pregnant women and the elderly. We do however, recommend that a pregnant woman seeks the advice of a qualified practitioner to assist her in treatment."
5. I can confirm that I have no connections with the alternative medicine industry.
JUNE SAYER - ARH COMPLAINT
Dear Sir/Madam,
I write to lodge a formal complaint against June Sayer DHom(Med) HMD FBIH D.N.Th D.Iridol. MARH.
The matter concerns the contents of Ms Sayer's website
www.sapphirecentre.co.uk
I argue that Ms Sayer may be responsible for multiple breaches of the Alliance's "Code of Ethics and Practice", specifically Sections 31, 36 and 37.
INTRODUCTION
1. The Advertising Standards Authority (ASA) is the voluntary regulator for all marketing in the UK.
2. On 1st March 2011, the ASA's remit was extended to embrace online marketing activities, including "companies’ own marketing claims on their own websites and in other non-paid for space they control" (http://www.asa.org.uk/Media-Centre/2011/New-online-remit-enhances-consumer-protection.aspx)
3. For marketing communications promoting homeopathic products and services, the relevant sections of the British Code of Advertising Practice (CAP Code) include:
(i) Section 3.1 'Marketing communications must not materially mislead or be likely to do so.'
(ii) Section 3.7 'Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.'
(iii) Section 3.11 'Marketing communications must not mislead consumers by exaggerating the capability or performance of a product.'
(iv) Section 3.13 'Marketing communications must not suggest that their claims are universally accepted if a significant division of informed or scientific opinion exists.'
(v) Section 3.47 'Claims that are likely to be interpreted as factual and appear in a testimonial must not mislead or be likely to mislead the consumer.'
(vi) Section 12.1 'Objective [health] claims must be backed by evidence, if relevant consisting of trials conducted on people. If relevant, the rules in this section apply to claims for products for animals. Substantiation will be assessed on the basis of the available scientific knowledge...'
(vii) Section 12.2 'Marketers must not discourage essential treatment for conditions for which medical supervision should be sought.'
(viii) Section 12.5 'Marketers inviting consumers to diagnose their minor ailments must not make claims that might lead to a mistaken diagnosis.'
(ix) Section 12.6 'Marketers should not falsely claim that a product is able to cure illness, dysfunction or malformations.'
(x) Section 12.7 'References to the relief of symptoms or the superficial signs of ageing are acceptable if they can be substantiated.'
(xi) Section 12.10 'Marketing communications must not suggest that any product is safe or effective merely because it is “natural” or that it is generally safer because it omits an ingredient in common use.'
(xii) Section 12.14 'Marketers must not use fear or anxiety to promote a medicine or a recovery from illness and must not suggest that using or avoiding a product can affect normal health.'
(xiii) Section 12.15 'Illustrations of the effect or action of a product should be accurate.'
(xiv) Section 12.19 'Marketing communications for a medicine may not claim that its effects are as good as or better than those of another identifiable product.'
(xv) Section 12.20 'Homeopathic medicinal products must be registered in the UK. Any product information given in the marketing communication should be confined to what appears on the label. Marketing communications must include a warning to consult a doctor if symptoms persist. Marketing communications for an unlicensed product must not make a medicinal or therapeutic claim or refer to an ailment unless authorised by the MHRA to do so.'
4. Sections 36 and 37 of the Alliance's Code of Ethics state that all registrants are expected to observe the CAP Code in their marketing materials:
(i) '36. All advertising must be published in a way that conforms to the law and to the guidance issued in the British Code of Advertising Practice.'
(ii) '37. Professional advertising must be factual and not seek to mislead or deceive, or make unrealistic or extravagant claims...'
5. In addition, Section 31 states:
(i) '31. Registrants must observe and keep up to date with all legislation and regulations relating directly or indirectly to the practice of homeopathy.'
REGULATION
6. It is not in dispute that many of the Alliance's registrants hold the opinion that homeopathy is effective for a range of medical conditions; neither is it in dispute that these beliefs are held sincerely.
7. The only matter of importance is a registrant's compliance or non-compliance with the advertising regulations to which they are professionally bound.
8. At present, the Committee of Advertising Practice (CAP) do not accept that claims for the efficacy of homeopathy have been substantiated by rigorous clinical evidence:
(i) "Despite its popularity, CAP understands that no scientific rationale exists for assuming that remedies lacking in pharmacologically active molecules can produce clinical effects and is unaware of robust evidence that proves it does." (http://www.copyadvice.org.uk/Ad-Advice/Advice-Online-Database/Therapies-Homeopathy.aspx)
9. Section 12.1 of the CAP Code, quoted earlier, requires that all marketers hold substantiation, in the form of rigorous clinical evidence, before making health claims in their marketing materials.
COMPLAINT
10. I complain that Ms Sayer may have breached the Alliance's Code of Ethics in respect of the following marketing claims found on her website, on March 9th 2011. (I give the full URL of the page, and a mirrored copy of the page as it was on that date.)
http://www.sapphirecentre.co.uk/index.php?page=homeopathy
http://www.freezepage.com/1299676504DGJRTBSSCO
(i) Homeopathy "works" by "stimulating the body's natural defense [sic] system to promote health and well-being"
(ii) "Homeopathy is known to be able to treat many conditions"
(iii) The advertiser has "successfully helped", using her "homeopathic treatment", "A[ttention] D[eficit] H[yperactivity] D[isorder]... Allergies (food sensitivities)... Asthma... Acne... Eczema... Hay-fever and other seasonal allergies... Psoriasis... Female problems..."
(iv) "...homeopathy works by treating the patient, not the disease"
http://www.sapphirecentre.co.uk/index.php?page=june-blog
http://www.freezepage.com/1299676476PHNEYWQJSL
(v) "June's enthusiasm and passion for homeopathy has given her the opportunity of treating a variety of people who have been suffering from a wide range of complaints both acute and chronic during the 18 years she has been in practice"
(vi) "Homeopathy... has been known to help where other treatments may not have"
(vii) Homeopathy can be "safely used at home in first-aid situations"
11. I also complain that Ms Sayer may have breached the Alliance's Code of Ethics in respect of the following marketing claim, which would seem to be in breach of the CAP Code Section 12.10 (quoted above):
http://www.sapphirecentre.co.uk/index.php?page=homeopathy
http://www.freezepage.com/1299676504DGJRTBSSCO
(i) "...homeopathic remedies are natural, safe, non-toxic and non-addictive and can be used by anyone at any stage including by children, pregnant women and the elderly. We do however, recommend that a pregnant woman seeks the advice of a qualified practitioner to assist her in treatment."
RESOLUTION
12. I have never been a patient of Ms Sayer, nor do I have any connection with her, nor do I have any conflicts of interest to declare. I write in the capacity of a concerned member of the public.
13. Because I have no personal connections with Ms Sayer which might admit of an informal resolution, I have considered the Code's advice (Section 59) and opted not to implement "Stage One" of the complaints process (Section 60) but am instead making a written complaint to the PCO (Section 61).
14. There are two possible routes which might lead to a speedy resolution of the complaint:
(i) Ms Sayer might produce new clinical evidence, not yet considered by CAP and of sufficient quality to substantiate all the marketing claims she makes in her website
(ii) Ms Sayer might accept the PCO's advice that her claims are not substantiated, are not "factual", are "unrealistic" or "extravagant", contain improper claims that her treatments are effective and safe because they are "natural", and undertake to remove the claims from her websites and all future marketing materials
15. I will readily agree to any resolution proposed by the PCO or Ms Sayer that achieves either of these two objectives.
NIGEL BIRD - ASA COMPLAINT
I'm writing to complain about the marketing claims I read today (9th March 2011, at 1pm) on the websites www.homoeopathymanchester.co.uk, www.marklandtherapycentre.co.uk and www.stress-solutions.info
All three sites promote the services of Nigel Bird, a homeopath. Since broadly the same promotional text is used on each site, I've combined them into a single complaint.
The pages in question are too big for a screenshot, so I've used a mirroring website. The ASA online complaints form doesn't accept HTML files yet, but I have saved a copy and can send them to you, if necessary.
1. On both sites the advertiser makes a number of health claims in order to promote his homeopathy services. I'd like to challenge whether any of the claims can be substantiated, and whether they are misleading. In particular, I'd like to challenge whether the repeated use of the word 'prove' - a corruption of the German word 'Preufung' which means 'testing' (but not 'proving') is misleading, when presented out of its proper context. I'd also like to challenge whether the claim that homeopathy has been 'proved' to treat malaria is irresponsible.
http://www.homoeopathymanchester.co.uk/index.html
http://www.freezepage.com/1299676106PKFNFXTGPR
(i) "Ever thought about trying alternative medicines? - Complementary healing, treating like with like [with Homoeopathy] can help you where traditional drugs or treatment wouldn't be as effective..."
http://www.homoeopathymanchester.co.uk/homoeopathy.html
http://www.freezepage.com/1299676134DGDRXJRFLP
http://www.marklandtherapycentre.co.uk/homoeopathy.html
http://www.freezepage.com/1299676163INEZQGYDIL
http://www.stress-solutions.info/homeopathy.html
http://www.freezepage.com/1299676184JHBCJEKDMG
(ii) Samuel Hahnemann, the inventor of homeopathy, "prove[d]" that homeopathy could treat malaria
(iii) Hahnemann's "methods of treatment" are "known to be safe, effective and non-topic [sic]" (n.b. The Stress Solutions site renders this as known to be SAFE, EFFECTIVE and NON-TOXIC")
(iv) Many homeopathic remedies have been "proved" on "healthy human volunteers"
(v) There are now "over 4,500 remedies available tro [sic] treat all disease from babies and children to adults of any age"
(vi) Homeopathic remedies "assist the patient to regain health by stimulating Nature's 'vital force' of recovery"
(vii) Homeopathic "medicines" are "effective"
(viii) Conventional medicines can only "suppress" symptoms of disease, in contrast to homeopathy which "use[s]" them
(ix) "...there is almost a 200 year history of well-proven documentary evidence of the efficacy of Homoeopathic remedies"
2. I'd like to challenge whether the following claim can be substantiated, whether it is misleading, whether it is irresponsible, and whether it could discourage consumers from seeking essential treatment:
http://www.homoeopathymanchester.co.uk/pracitioner.html
http://www.freezepage.com/1299676249NJRAOUMYNC
http://www.marklandtherapycentre.co.uk/nbird.html
http://www.freezepage.com/1299676276VXUSKOVSIV
http://www.stress-solutions.info/homeopathy.html
http://www.freezepage.com/1299676184JHBCJEKDMG
(i) "...conventional medicine only suppressed symptoms, they did not get to the cause of the disease and the drugs used could be dangerous, toxic and their side-effects outweigh their possible benefits."
3. I can confirm that I have no connections with the alternative medicine industry.
NIGEL BIRD - ARH COMPLAINT
Dear Sir/Madam,
I write to lodge a formal complaint against Nigel Bird, MARH.
The matter concerns the contents of three of Mr Bird's websites which he uses to promote his services as a homeopath. They are:
www.homoeopathymanchester.co.uk
www.marklandtherapycentre.co.uk
www.stress-solutions.info
Each of the websites uses broadly the same promotional text, so I have included references to each in this complaint.
I argue that Mr Bird may be responsible for multiple breaches of the Alliance's "Code of Ethics and Practice", specifically Sections 31, 36 and 37.
INTRODUCTION
1. The Advertising Standards Authority (ASA) is the voluntary regulator for all marketing in the UK.
2. On 1st March 2011, the ASA's remit was extended to embrace online marketing activities, including "companies’ own marketing claims on their own websites and in other non-paid for space they control" (http://www.asa.org.uk/Media-Centre/2011/New-online-remit-enhances-consumer-protection.aspx)
3. For marketing communications promoting homeopathic products and services, the relevant sections of the British Code of Advertising Practice (CAP Code) include:
(i) Section 3.1 'Marketing communications must not materially mislead or be likely to do so.'
(ii) Section 3.7 'Before distributing or submitting a marketing communication for publication, marketers must hold documentary evidence to prove claims that consumers are likely to regard as objective and that are capable of objective substantiation. The ASA may regard claims as misleading in the absence of adequate substantiation.'
(iii) Section 3.11 'Marketing communications must not mislead consumers by exaggerating the capability or performance of a product.'
(iv) Section 3.13 'Marketing communications must not suggest that their claims are universally accepted if a significant division of informed or scientific opinion exists.'
(v) Section 3.47 'Claims that are likely to be interpreted as factual and appear in a testimonial must not mislead or be likely to mislead the consumer.'
(vi) Section 12.1 'Objective [health] claims must be backed by evidence, if relevant consisting of trials conducted on people. If relevant, the rules in this section apply to claims for products for animals. Substantiation will be assessed on the basis of the available scientific knowledge...'
(vii) Section 12.2 'Marketers must not discourage essential treatment for conditions for which medical supervision should be sought.'
(viii) Section 12.5 'Marketers inviting consumers to diagnose their minor ailments must not make claims that might lead to a mistaken diagnosis.'
(ix) Section 12.6 'Marketers should not falsely claim that a product is able to cure illness, dysfunction or malformations.'
(x) Section 12.7 'References to the relief of symptoms or the superficial signs of ageing are acceptable if they can be substantiated.'
(xi) Section 12.10 'Marketing communications must not suggest that any product is safe or effective merely because it is “natural” or that it is generally safer because it omits an ingredient in common use.'
(xii) Section 12.14 'Marketers must not use fear or anxiety to promote a medicine or a recovery from illness and must not suggest that using or avoiding a product can affect normal health.'
(xiii) Section 12.15 'Illustrations of the effect or action of a product should be accurate.'
(xiv) Section 12.19 'Marketing communications for a medicine may not claim that its effects are as good as or better than those of another identifiable product.'
(xv) Section 12.20 'Homeopathic medicinal products must be registered in the UK. Any product information given in the marketing communication should be confined to what appears on the label. Marketing communications must include a warning to consult a doctor if symptoms persist. Marketing communications for an unlicensed product must not make a medicinal or therapeutic claim or refer to an ailment unless authorised by the MHRA to do so.'
4. Sections 36 and 37 of the Alliance's Code of Ethics state that all registrants are expected to observe the CAP Code in their marketing materials:
(i) '36. All advertising must be published in a way that conforms to the law and to the guidance issued in the British Code of Advertising Practice.'
(ii) '37. Professional advertising must be factual and not seek to mislead or deceive, or make unrealistic or extravagant claims...'
5. In addition, Section 31 states:
(i) '31. Registrants must observe and keep up to date with all legislation and regulations relating directly or indirectly to the practice of homeopathy.'
REGULATION
6. It is not in dispute that many of the Alliance's registrants hold the opinion that homeopathy is effective for a range of medical conditions; neither is it in dispute that these beliefs are held sincerely.
7. The only matter of importance is a registrant's compliance or non-compliance with the advertising regulations to which they are professionally bound.
8. At present, the Committee of Advertising Practice (CAP) do not accept that claims for the efficacy of homeopathy have been substantiated by rigorous clinical evidence:
(i) "Despite its popularity, CAP understands that no scientific rationale exists for assuming that remedies lacking in pharmacologically active molecules can produce clinical effects and is unaware of robust evidence that proves it does." (http://www.copyadvice.org.uk/Ad-Advice/Advice-Online-Database/Therapies-Homeopathy.aspx)
9. Section 12.1 of the CAP Code, quoted earlier, requires that all marketers hold substantiation, in the form of rigorous clinical evidence, before making health claims in their marketing materials.
COMPLAINT
10. I complain that Mr Bird may have breached the Alliance's Code of Ethics in respect of the following marketing claims found on her website, on March 9th 2011. (I give the full URL of the page, and a mirrored copy of the page as it was on that date.)
http://www.homoeopathymanchester.co.uk/index.html
http://www.freezepage.com/1299676106PKFNFXTGPR
(i) "Ever thought about trying alternative medicines? - Complementary healing, treating like with like [with Homoeopathy] can help you where traditional drugs or treatment wouldn't be as effective..."
http://www.homoeopathymanchester.co.uk/homoeopathy.html
http://www.freezepage.com/1299676134DGDRXJRFLP
http://www.marklandtherapycentre.co.uk/homoeopathy.html
http://www.freezepage.com/1299676163INEZQGYDIL
http://www.stress-solutions.info/homeopathy.html
http://www.freezepage.com/1299676184JHBCJEKDMG
(ii) Samuel Hahnemann, the inventor of homeopathy, "prove[d]" that homeopathy could treat malaria
(iii) Hahnemann's "methods of treatment" are "known to be safe, effective and non-topic [sic]" (n.b. The Stress Solutions site renders this as known to be SAFE, EFFECTIVE and NON-TOXIC")
(iv) Many homeopathic remedies have been "proved" on "healthy human volunteers"
(v) There are now "over 4,500 remedies available tro [sic] treat all disease from babies and children to adults of any age"
(vi) Homeopathic remedies "assist the patient to regain health by stimulating Nature's 'vital force' of recovery"
(vii) Homeopathic "medicines" are "effective"
(viii) Conventional medicines can only "suppress" symptoms of disease, in contrast to homeopathy which "use[s]" them
(ix) "...there is almost a 200 year history of well-proven documentary evidence of the efficacy of Homoeopathic remedies"
ttp://www.homoeopathymanchester.co.uk/pracitioner.html
http://www.freezepage.com/1299676249NJRAOUMYNC
http://www.marklandtherapycentre.co.uk/nbird.html
http://www.freezepage.com/1299676276VXUSKOVSIV
http://www.stress-solutions.info/homeopathy.html
http://www.freezepage.com/1299676184JHBCJEKDMG
(x) "...conventional medicine only suppressed symptoms, they did not get to the cause of the disease and the drugs used could be dangerous, toxic and their side-effects outweigh their possible benefits."
RESOLUTION
11. I have never been a patient of Mr Bird, nor do I have any connection with him, nor do I have any conflicts of interest to declare. I write in the capacity of a concerned member of the public.
12. Because I have no personal connections with Mr Bird which might admit of an informal resolution, I have considered the Code's advice (Section 59) and opted not to implement "Stage One" of the complaints process (Section 60) but am instead making a written complaint to the PCO (Section 61).
13. There are two possible routes which might lead to a speedy resolution of the complaint:
(i) Mr Bird might produce new clinical evidence, not yet considered by CAP and of sufficient quality to substantiate all the marketing claims he makes in his websites
(ii) Mr Bird might accept the PCO's advice that his claims are not substantiated, are not "factual", are "unrealistic" or "extravagant", and undertake to remove the claims from his websites and all future marketing materials
14. I will readily agree to any resolution proposed by the PCO or Mr Bird that achieves either of these two objectives.
Monday, 7 March 2011
Honesty Is No Barr To Success
Author William Barr is the brother of Richard Barr, the scary-looking solicitor I've mentioned once or twice before.
I'm not sure which of them is older, so I'll just make a wild stab in the dark and offer the suggestion that Big Dick popped out before Little Willy.
The Brothers Barr are both frustrated authors. Big Dick laments:
"I am a reluctant solicitor. I still have not made up my mind what I really want to do when I grow up... back in the 1980s I hit on the idea that even life in a solicitor's office might be interesting to somebody, so I started to jot down my experiences. The outcome was a series of (mainly) lighthearted articles in Solicitors Journal [sic]..."
Little Willy is still struggling to match these lofty heights of literary achievement. His first book, Real Football Real Fans: A Journey to the Heart of Football, is languishing at number 938,440 in Amazon's bestseller rankings (as of today).
His second book, The Carp Club, is doing even worse at number 1,094,876.
What can possibly explain this disappointment?
It's not that the book is unpopular with his readers. The Carp Club has attracted gushing praise from its customer reviewers - of the eight reviews so far, six of them give the book 5 stars, and the other two give the book 4 stars.
What, then, is going on?
Of course, it would be both libelous and scandalous of anyone to claim that all but one of the reviews is an obvious fake, fraudulently planted on Amazon by either the author or his associates; and I for one would never dare to utter such a scurrilous slander.
Instead, I'll just invite my readers to examine the evidence for themselves; perhaps they can work out why, of the eight "reviewers", six have only ever "reviewed" one book (namely The Carp Club) and the seventh has only ever "reviewed" two books (namely The Carp Club and Real Football Real Fans).
Review #1 by "Jonathon Barclay" (click on the image to expand it)
"Mr Barr is an angry man, and rightly so. His first book, Real Football Real Fans is a response to the absurdities and excesses of the Premier League. This one is an attack on the failings, and failures, of our political class in the context of the Parliamentary expenses scandal and the financial crisis. Plenty of readers will have sympathy with his views, but few would have the imagination and wit to express anger in the form of an elegant fable based on carp fishing. Swift and Voltaire come to mind, with an underlying touch of Orwell (lolwut?!? SLW). Mr Barr's knowledge of fishing is as impressive as his humour; the book raises a number of important contemporary political and social issues in its 170 pages, but is so well written [sic] that it is easy to underestimate its importance (not that easy - SLW). Read and enjoy."
("Jonathon Barclay" has also reviewed two books not written by Little Willy, so no-one would imagine there to be any impropriety at play in this case.)
Review #2 by "George Clare" from the fictional town of "Welling Garden City" (lolwut?!?)
"I read this book with ever growing amazement as the scales fell from my eyes. Whether William Barr becomes the cult author of the election or just another minnow in the ocean remains to be seen. But Carp Club is a whopper of a story... Tristram Shandy meets Izaac Walton. Carpery rules." 
"George Clare" is the "reviewer" who has also "reviewed" Barr's first book, Real Football Real Fans. This is what he had to say:
"William Barr has given us back 3 o'clock on a Saturday afternoon football, the pools, Bob Danvers Walker and, above all pies and hot bovril. But this isn't a book of nostalgia, it's hard-nosed Division 2 where real football is alive and kicking. Take a break from the Premiership and the ghosted celebrity soccer biographies and read this lovely book. It's subtitled 'a journey to the heart of football' but it also takes you to the parts of England you may not visit every weekend - Grimsby, Mansfield, Accrington and Barnet. You'll find them full of surprises, scandals and humour. And you'll never pass Dagenham and Redbridge again with stopping for a pie or three."
Review #3 by "Maglia Rosa"
"Whether you are casting your bread upon the water or fly-fising [sic] in the Yemen this is a book for all those who take an interest in the state of the nation and its woeful lack of political leadership. Mr Barr perfectly satirises the current political debate and its dreary lack of meaningful content by setting the action in the small world of fishing clubs he knows so well." Review #4 by "R J Winstanley"
"This timely book will tick all the boxes for those who relish sticking a knife in the fishy side of politics, but won't make casting a vote any easier. It should be compulsory reading for all MPs and barristers." Review #5 by "A. Tagg"
"This is a book of fishes, politicians, banksters (good name for them), wretched carp poetry, and lots of jokes. It is also a serious and sometimes angry exploration of the shortcomings of our political system. The allegory of the carp club and its forthcoming election allows an entertaining story to explore serious questions in a way that might seem too heavy without the humour. What does a voter do who dislikes all of the major parties? Can John Fisher's ban the ballot campaign restore power to the voters or will the career carpist/politicians forever pursue their increasingly irrelevent [sic] quarrels without noticing that the carp have all died and the banksters have paid themselves all of the club's money? A thoughtful book and a really good read."Review #6 by "Christopher Davy"
"This is a witty, clever and thought provoking [sic] read - and directs savage satire at our politicians and electoral system. Deeply cynical and very funny, it also raises some serious issues. It should be read by all mps and lawyers to let than know they've been busted! William Barr eloquently expresses our justifiable anger at political sleaze whilst wrapping it up in a really good read. (His blog with the short stories is also very entertaining)."
Review #7 by "Tom Hoolahan"
"I came across this book having had the author's excellent bantheballot website and blog recommended to me. It's a kind of fishy Animal Farm dealing with such well-versed themes as avaricious bankers and self-serving, ineffectual politicians but in an original, engaging and witty way. It's amusing and has an enjoyable storyline but is also pretty hard-hitting and devasting [sic] in its critique of the powers that be. The Carp Club really appealed to me because I, like many others, am feeling utterly depressed about the forthcoming election - Labour have got to go, even if the Conservatives committed themselves to any policies I wouldn't want them in charge and the Lib Dems have failed to seize the initiative in what should have been their golden opportunity to take politics in a different direction. That only leaves a protest vote for the Greens or someone as a viable option for me but there's no point really. One or the other bunch of R.S. Holes will get into power but not voting for any of them is not going to feel much better because it won't change anything. However, the book is more than the rant of an aging, disenfranchised, fishing-mad eccentric. It contains cogent and balanced arguments looking at why the current system doesn't work and is full of references to polictical [sic] history, both old and recent. Best of all, Barr actually proposes a practical, workable solution to the current morass which would divest us of our feeling of powerlessness. I won't give it away here but it does make a lot of sense. To be honest, I can't think why his proposal has not been thought of by more mainstream commentators. Of course, the policiticians would not countenance it because it is not in their interests - but then nor was reforming the expenses system until public opinion made it untenable. You never know, the Carp Club may be the seed that leads to the fundamental reform the British political system to make politics fairier [sic] and politicians more accountable. The current crop of politicians have failed to suggest any real improvement to the system - make sure you read it here first before any of them claim the credit for it! Then spread the word." Review #8 by "Helena Bottlethwaite"
"To be honest I embarked on reading this book with a bit of trepidation, knowing little of carp fishing and politics. However, I was very soon gripped by the wonderfully strong characters, the countdown to election night and a burning curiosity to see just how the tale would unfold. Brilliantly written, Barr writes with an engaging style, brimming over with wit, intellect and punnery!! Love it. I would recommend this to anyone and everyone: it is a well written [sic] and well timed [sic] release - somebody needs to be expressing and communicating these views [but hopefully not these punctuation errors - SLW]"P.S. If your interest has been stirred, I'd invite you all to read the first three chapters of The Carp Club, available for free on Little Willy's website. If you think you could withstand 172 more pages of his bludgeoning prose, the book is a snip at just £5.50.
Richard Barr's Recurrent Memory Problems
It seems that Richard Barr - the strikingly photogenic solicitor pictured below - has a recurrent problem with forgetting to disclose things.
Of the commercial websites he controls, how many do you think are incorrectly registered as belonging to a "non-trading individual"?
The answer - it goes without saying - is all of them*!
http://richardbarrlaw.co.uk/ (Nominet WHOIS - "The registrant is a non-trading individual who has opted to have their address omitted from the WHOIS service.")
http://www.norfolkbaytreecottage.co.uk/ (Nominet WHOIS - "The registrant is a non-trading individual who has opted to have their address omitted from the WHOIS service.")
http://theapplehousenorfolk.co.uk/ (Nominet WHOIS - "The registrant is a non-trading individual who has opted to have their address omitted from the WHOIS service.")
Richard Barr's brother also runs a website. He uses it to flog copies of his latest best-selling** novel, The Carp Club - The Election That Never Was.
Can you see where I'm going with this...?
http://bantheballot.co.uk/ (Nominet WHOIS - "The registrant is a non-trading individual who has opted to have their address omitted from the WHOIS service.")
Forgetfulness often runs in the family, or at least in the blood family. Richard Barr's stepson somehow managed to remember to comply with his responsibilities.
Barr's fellow Director of the Society of Homeopaths, Mike Andrews, runs a site that's also in full compliance with Nominet's disclosure rules.
One of the reasons for Mike's admirable honesty, of course, is that he had already been caught out eleven months ago - along with ninety-nine of his colleagues!
* The words "all of them" carry the meaning "all of the commercial websites controlled by Richard Barr, which have come to my attention". If anyone knows of any besides the three mentioned above, I would be glad to hear about them.
**Contrary to appearances, the word 'best-selling' is not intended to be satirical. As of the time of writing, The Carp Club is flying off the shelves, and has already reached 1,094,582th place in Amazon's bestseller ranks.
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