Connecticut Attorney General (AG) William Tong has taken legal action against two online distributors, Triggered Brand and Made In China, for allegedly selling research-grade GLP-1 weight loss drugs directly to Connecticut consumers without prescriptions or medical oversight. These drugs, marketed as research compounds, lack Food and Drug Administration (FDA) approval for human use. The lawsuit against Triggered Brand alleges violations of the Connecticut Unfair Trade Practices Act (CUTPA) and seeks civil penalties. Additionally, Tong has issued a civil investigative demand to Made In China to gather information regarding its marketing and sales practices.

The Details

The complaint against Triggered Brand and its owner, Samuel Stolt, alleges violations of the CUTPA because defendants are selling untested and unsafe “bootleg” GLP-1 weight loss drugs, exploiting regulatory loopholes by marketing these research compounds directly to consumers without proper FDA approval.

Pharmaceutical companies such as Eli Lilly and Novo Nordisk, manufacturers of FDA-approved, Wegovy and Zepbound, must adhere to FDA regulations ensuring their GLP-1 injections are sterile, pure, and traceable to patients for safety.

In contrast, the AG’s lawsuit alleges the companies are selling raw peptides for research purposes operate without similar standards, as these compounds are not FDA-approved for human or veterinary use.

The complaint against Triggered Brand also raises several concerns about the company’s operations and financial practices. It alleges that the business address provided by Triggered Brand is merely a mailbox rental service, suggesting an effort to conceal the company’s actual location and activities. Furthermore, the defendants are accused of employing a network of interconnected companies, purportedly under the control of Samuel Stolt, to deceive creditors. This network is allegedly designed to obscure financial dealings and mislead those seeking accountability. Additionally, the defendants reportedly limit payment methods to cryptocurrency or peer-to-peer apps, which may be an attempt to circumvent traditional financial scrutiny and oversight.

Furthermore, letters have been sent to Connecticut weight loss clinics, advising against the sale of compounded weight loss drugs not approved by the FDA. The AG emphasizes the importance of obtaining GLP-1 medications through legitimate pharmacies with proper prescriptions to ensure safety and compliance.

Established pharmaceutical companies invest significantly in meeting stringent FDA standards, which not only protect public health but also uphold their reputations. The rise of unregulated entities selling potentially dangerous compounds without oversight threatens to erode consumer trust in legitimate pharmaceutical products.

Why It Matters

The issue of counterfeit GLP-1 drugs has drawn significant attention from state AGs, underscoring its importance in consumer protection and pharmaceutical regulation.

In February, the National Association of Attorneys General, representing a bipartisan coalition of 38 state and territory AGs, urged the FDA to take decisive action against those endangering consumers with counterfeit versions of GLP-1 drugs, including Mounjaro, Zepbound, Ozempic, and Wegovy. These counterfeit drugs, driven by supply shortages and high costs, have infiltrated the U.S. market, posing significant health risks. Originating from countries such as China and India, these counterfeits may contain contaminants or incorrect dosages, leading to severe side effects.

The letter asserts that the FDA has the necessary expertise and resources to curb these deceptive practices and calls for increased enforcement against compounding pharmacies illegally involved in this market. It also encourages collaboration with state pharmacy boards to ensure that compounded GLP-1 drugs are produced safely and in sanitary conditions.

The states will certainly continue to monitor these products in the marketplace and pursue all available remedies for alleged harm to consumers.

Troutman Pepper Locke State Attorneys General Team

	Ashley Taylor – Co-leader and Firm Vice Chair Ashley is co-leader of the firm’s nationally ranked State Attorneys General practice, vice chair of the firm, and a partner in its Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group. He helps his clients navigate the complexities involved with multistate attorneys general investigations and enforcement actions, federal agency actions, and accompanying litigation.
	Clay Friedman – Co-leader Clay co-leads the firm’s State Attorneys General practice and is nationally ranked by Chambers USA for AG Government Relations and in Best Lawyers for Advertising Law. He has dedicated his entire career to state attorney general and federal work, serving for nearly a decade in a senior role and more than 25+ years in private practice. Clay focuses his practice on helping industry-leading companies mitigate the risks associated with state and federal regulatory investigations and associated litigation.
	Chris Carlson Chris advises clients on regulatory, civil, and criminal investigations and litigation. With a background as an assistant attorney general, he provides practical guidance to clients with matters involving state attorneys general and federal regulatory agencies.
	Lauren Fincher Lauren has vast experience handling state attorneys general investigations, navigating complex regulatory compliance matters, and providing strategic counsel in enforcement actions across various industries. She helps clients manage high-stakes regulatory matters and guides them through complex legal landscapes.
	Stephen Piepgrass Stephen leads the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group, representing clients in single and multistate enforcement actions, including inquiries and investigations, as well as litigation involving state attorneys general and other state and federal governmental enforcement bodies. He has significant experience handling actions with federal agencies, including the CFPB and FTC, as well as single plaintiff and class action litigation for clients in highly regulated sectors such as financial services, health care, pharmaceutical, and education.
	Michael Yaghi Mike handles high-profile state attorneys general, FTC, and CFPB investigations by advising clients through these complex government inquiries. He assists clients through the entire life cycle of investigations, from regulatory enforcement through formal litigation.
	Samuel E. “Gene” Fishel Gene is a former regulator with two decades of experience who has overseen state privacy and cybersecurity regulation enforcement, led national, multistate attorneys general privacy investigations, and prosecuted computer crimes at the state and federal levels. He has served at the forefront of state attorney general and federal enforcement, and utilizes this experience to proficiently represent client interests.
	Jay Myers Jay assists clients in heavily regulated industries, including health care, energy, insurance, emerging industries, and data privacy. He provides both regulatory legal advice and government relations strategies. Jay’s past and current clients include Fortune 10 companies, startups, nonprofits, industry associations, and advocacy groups. Recognizing that state government matters are often complex and multifaceted, he utilizes regulatory guidance, government advocacy, or both in tandem to deliver tailored solutions for each client’s unique needs.
	Jessica Birdsong Jessica is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement Practice Group. She received her J.D. from the University of Richmond School of Law, magna cum laude, where she served as associate articles editor of the Journal of Law & Technology.
	Blake R. Christopher Blake collaborates with clients on matters related to government contracting, investigations, and disputes. His senior-level government experience generates valuable insights and strategies for clients across a variety of industries.
	Nick Gouverneur Nick is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement Practice Group. He received his J.D. from the University of Illinois College of Law, where he served as a member of the Journal of Law, Technology & Policy.
	Troy Homesley Troy is an accomplished litigator who has represented and defended clients across a wide range of complex, high-stakes disputes at both the trial and appellate levels. He has represented technology companies, business executives, law firms, investment funds, high-ranking federal officials, international non-profits, and asylum seekers. Troy draws on his broad litigation experience to advise clients before litigation arises, while claims are pending or threatened, and leading up to and through trial and appeals.
	Natalia Jacobo Natalia is an associate in the firm’s Regulatory Investigations, Strategy and Enforcement (RISE) practice, based on the West Coast. She routinely counsels clients on a variety of state and federal regulatory matters, with a particular emphasis on consumer protection and data privacy matters.
	Namrata Kang Namrata (Nam) is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group, based in the Washington, D.C. office. She routinely advises clients on a wide variety of state and federal regulatory matters, with a particular emphasis on state consumer protection laws relating to consumer financial services and marketing and advertising. Nam’s experience transcends multiple industries, including financial services, telecommunications, media, and sports betting.
	Michael Lafleur Michael is an associate in the firm’s Regulatory Investigations, Strategy, and Enforcement Practice Group. Based out of the firm’s Boston office, Mike has deep experience in litigation, investigations, and other regulatory matters involving state-level regulators and state attorneys general.
	Lane Page Lane specializes in federal and state regulatory investigations and complex civil litigation. He focuses on representing financial institutions and other businesses, with a particular emphasis on consumer protection and fair lending issues.
	Dascher Pasco Dascher is an attorney within the Regulatory Investigations, Strategy, and Enforcement practice, based in the Richmond office. She joined our firm after working in personal injury and medical malpractice for a Virginia trial law firm. Dascher brings varied legal experience to the firm with strong litigation and regulatory strategy capabilities.
	Kyara Rivera Rivera Kyara is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement Practice Group. She received her J.D. from the University of Richmond School of Law, cum laude, where she served as publications and online editor of the Public Interest Law Review.
	Trey Smith Trey focuses his practice on representing and advising regulated utilities before state public utility commissions. He routinely helps clients obtain certificates of public convenience and necessity for transmission infrastructure. In this role, Trey works with his clients’ subject-matter experts to manage administrative proceedings, including by preparing initial filings; responding to discovery requests; drafting rebuttal testimony; and litigating any disputed issues.
	Daniel Waltz Dan helps clients navigate all aspects highly regulated relationships between industry participants and federal, state and local governments. Whether engaging with regulators, negotiating transactions or representing clients in the courtroom, he delivers solutions that help his clients achieve their strategic goals.
	Cole White Cole is a member of the firm’s Regulatory Investigations, Strategy and Enforcement (RISE) group. He has a decade of experience working in the attorney general community, having joined the firm from the Wyoming Office of the Attorney General, where he was assistant attorney general.
	Stephanie Kozol Stephanie is Troutman Pepper Locke’s senior government relations manager in the state attorneys general department.