Exposing the IHRB Contract

Exposing the IHRB Contract

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This article examines the IHRB Contract so that you can better understand how Mr Sam Cohen’s company has managed to use the English language to play a game of chess that puts the customer in a checkmate position before the customer has left the IHRB office. This IHRB contract is so entertaining and so pathetic, you will find it riveting. It is like an episode of your favourite TV soap. Clause ends on a cliff hanger, leaving you wanting to read more, just for the sheer joy of its trickery and mastery. In the end, it is a stupid contract that is misleading, unfair, and nothing at all like the dozens of ads and testimonials that Mr Cohen uses to lure his poor unsuspecting customers to hand over their money for absolutely nothing at all.

The green text is from the contact, verbatim. The other text highlights my experiences with the contract.
I have underlined the text about which I will be commenting.

IHRB’S ‘hair re-growth treatment program’ is a combination of Specially prescribed medical and pharmaceutical treatments, herbal preparations, organic products and natural extracts’, developed over many years and dispensed under medical prescription. It will mainly involve treatment in the privacy and comfort of your own home.


Mr Cohen sold me Schedule 2 and Schedule 4 medications without a doctor’s prescription. I just walked out with them. I had no idea at the time.

He never disclosed to me that I was using Retin-A which can only be obtained with a prescription and which (along with minoxidil) caused a painful rash on my scalp.

He never told me about the side-effects of Minoxidil which includes hair loss.


I checked with the Health Department, and I know that Mr Cohen and IHRB are NOT licensed to sell pharmaceutical products or any Scheduled products. Yet Mr Cohen even has a price-list that includes prescription-only Schedule 4 medications and pharmacy-only lotions and poisons.

Later in the treatment, Mr Cohen wanted me to obtain other medications, and he wanted me to give him the prescription to fill it for me. He is not authorised to do this.

Mr Cohen’s medications are not properly labelled.

The customer information sheet given to him by the first pharmacist was not passed on to me, so I never knew the ingredients and never knew the potential side effects until I had made enquiries at the conclusion of my treatment.

Mr Cohen changed the dosage which went against the advice and labelling of his pharmacist.

The products and labels all say ‘or use as directed’. Mr Cohen was directing the dosages. He has no authority to do this.


Mr Cohen told me that, apart from his treatment, not a single product in the world works for hair re-growth. Whereas he said that he has helped thousands of clients, because he uses special secret Indian Curries which are his own innovation which he places inside the topical solution. He said, ‘Without the Indian Curries, nothing works.’


Mr Cohen uses all these friendly terms like ‘organic’, ‘natural’ and ‘herbal’ to give the illusion that his treatment is safe, simply because in reality, his program is dangerous.

Mr Cohen also uses the organic/herbal angle in order to sell his branded shampoos and cleansers and Saw Palmetto tablets that are completely useless and exorbitantly priced.

My manufacturing contacts in Asia have advised me that the IHRB Organic Shampoo is not organic. And it is the cheapest shampoo with nothing special in it, yet IHRB sells at eight-times the market rate. Unfortunately, clients are locked into using his useless products at inflated prices.


Mr Cohen complicates his treatment so that it would enable him to place advertisements saying that he has a safe and simple product. In fact, his hair treatment uses non-approved and dangerous prescription medications.


Mr Cohen acts as a pharmacy dispenser in that, when he does manage to solicit prescriptions from clients, he takes the prescriptions and has them filled and then he dispenses, sells, and provides the medications to the client. This goes against the code of practice as stipulated for pharmacy professionals.

Mr Cohen showed me an inch-thick stack of prescriptions, trying to convince me that it was normal, and that I should hand-over my prescriptions (I had none to give him).


In my opinion, the biggest scam in this whole business is the alleged existence of the Indian Curries. And the biggest danger in this whole business is the use of non-approved dangerous medications.

When his topical solution was not helping to grow my hair, Mr Cohen sent me to my GP, armed with a letter from him, requesting a prescription for Proscar, Loniten, Minoxidil, and Retin-A.

My Doctor refused, and sent me to a Specialist. My Specialist also refused on the basis that the combination of products was dangerous and that Loniten and Proscar are not approved, and Loniten has severe adverse effects which include heart failure.

The entire IHRB business revolves around using non-approved medications. Yet, all the promotions speak about herbal/organic/natural extracts which is misleading.

The IHRB contract says, we will…

The green text is from the contact, verbatim. The other text highlights my experiences with the contract.
I have underlined the text about which I will be commenting.

A) We Will Conduct a detailed assessment and/or examination of the current condition of your hair and scalp during your initial visit.

While in reception, Mr Cohen receptionist gave me a form to fill in. It did not contain a single question relevant to any information about my hair.


Mr Cohen simply looked at my head and touched my hair. That took two seconds. There was nothing detailed about his inspection.


Mr Cohen simply told me about hair being thin and thinning. I did not see him assessing anything.


There was no examination of any kind. No discussion about my blood pressure, no questions about my family history pertinent to his medications (which I later found out could cause heart conditions, water retention, erctile dysfunction, and rashes).

There were no tests of any kind. No blood test. No detailed medical history.

The whole emphasis was on herbal Indian Curries which Mr Cohen said were safe and had been used by thousands of his clients including men, women, and children, and that he has never failed and that he achieved a 130% success rate.

B) We will refer you to yours or any other registered medical practitioner to initially examine and confirm your suitability to undertake the treatment program and complete the prescription order for the required pharmaceutical formula preparations. We will then order and supply the formulations prepared for you.


Mr Cohen knows that most GPs refuse to act as his puppet because his mix of medications are not approved and dangerous. This is why Mr Cohen has a few doctor-friends who will comply with his demands, and he therefore is happy to ask people to go to his doctor-friends instead. He had asked me to ‘ditch’ my doctors, saying that all doctors are stupid and know nothing about hair. He said my doctors don’t know what they are talking about when they refused to prescribe Loniten and Proscar.


I walked into his office, paid $3,700 and walked out with the medications. I did not have a prescription. I was not sent for an initial examination. I did not think anything of it because Mr Cohen had said that his treatment was all herbal and organic. Therefore, no examination was done to confirm my suitability.

Complete the prescription

The contract is cleverly worked and superbly crafted. This ambiguous phraseology means that Mr Cohen wants to complete the prescription. He wants the prescription in his hands. He is not authorised to do this. He has no right to interfere with the client/pharmacist relationship. I suspect that must be making extra profits from this process. He is not qualified to be doing this.

Mr Cohen cannot be trusted because he removes labels from medications (in order to keep the client in the dark) and he does not pass on the medication information sheets which include the ingredients and risks, and he alters the dosages to suit him which puts the clients at risk). In my case, he was guilty of all the above.


Mr Cohen likes the idea of compounding medications so that he can charge whatever he likes. In the end, we do not know what he is doing. For example, he might ask a client to obtain a prescription for products that he stashes away to use them to concoct more of his own mixtures to sell to people like me who walked-in and walk-out with products whose ingredients include Schedule 4 medications which were not disclosed.


Mr Cohen wants to supply. This is the role of a pharmacist. There are certain laws in relation to pharmacy dispensaries and pharmacy sales. His topical solution is compounding in Melbourne. Mr Cohen has no licence to be operating a pharmacy in Sydney to sell products. Note that the supply of said medications is at the customer’s additional expense. Mr Cohen’s price list was exorbitant.

C) We will prepare reports, diagrams, and photographically record the hair coverage of your scalp prior to the commencement of your treatment program.


I saw no reports. Mr Cohen just looked at my head and touched my hair. He had a small patient-card on which he would note when I visited him.


I saw no diagrams. I do not know if these were prepared.


Photos were taken. Mr Cohen cleverly lifted my hair to photograph the obviously thinning scalp.

At the end of the program, he used fuzzy out-of-focus photos, and held my hair down flat to give the illusion that my scalp had better coverage.

D) We will supply the initial batch of the hygiene products and herbal tablets to cleanse and prepare the scalp for treatment (replacements at your own cost).


The shampoos are basic cheap detergents which are sold at eight-times the market rate for comparable shampoos, yet Mr Cohen locks clients into his branded products so as to make huge profits for no reason at all. The other cleansing agent is very expensive. It is used because the topical solution is sticky and tacky and needs this harsher cleanser. It smells like paint-stripper. It is used to remove the glue-like residue that stiffens the hair to look like a wig and feel like a dirty dry mop.


The tablets are Saw Palmetto which do nothing for hair re-growth. These are sold at double the market rate. They are badly labelled. Their origin and contents is unknown. We do not know if they are manufactured under strict manufacturing conditions. Mildew and bacteria can infect factories that are not world-class. These tablets are useless and look like home made. Why must such simple tablets be IHRB branded? This is another way to lock clients into useless profitable products. IHRB has no clinical trials for any of its products.


The IHRB treatment is $3,700 for nothing at all. Assuming Minoxidil has some value, and the rest are useless, then a year’s supply of Minoxidil is under $400. So why is Mr Cohen charging $4,900 (less $1,000 if paid up-front) and in my case a future discount to secure the sale? I was told that I was paying for the innovative Indian Curries, which I now know do not exist. On top of the $3,700, I am being contracted to pay for useless products.

E) We will provide the full hair regrowth treatment program for your when paid in full.


This is misleading. Mr Cohen supplied me with the topical solution and shampoo, cleanser, and Saw Palmetto tablets. Most of these are useless and pointless.

Later I found out that I am required to purchase other medications at my expense, and these are not mentioned as being refunded under his money-back guarantee.

Also, Mr Cohen did not pay for my other expenses which included:

Visits to Mr Cohen’s office for check-ups, eg travel, tolls, paring, petrol, etc
Visit to GP at his request to ask for prescription medications
Visit to Specialist after GP refused to prescribe non-approved products
Visit to GP to discuss the Specialist’s report
Visits back to Mr Cohen
Two visits to the GP regarding the rash on my scalp
Two courses of antibiotics at my expense.

The IHRB contract says, you must…

The green text is from the contact, verbatim. The other text highlights my experiences with the contract.
I have underlined the text about which I will be commenting.

F) You must closely follow and strictly adhere to all instructions given to you by the Company and by the medical practitioner, relating to your hair regrowth treatment program regime. Which incorporates the diligent use at your home of our hair hygiene products (Derma Clean, Shampoo and/or Conditioner) plus the prescribed topical pharmaceutical solution and the herbal product ‘Saw Palmetto Complex’ and any other products which may be recommended by a Doctor or your consultant.


This contract is asking me to strictly adhere to instruction given to me by the Company. This means that Mr Sam Cohen, who has not qualifications, is obliging me to following his instructions. This is dangerous when it comes to medication.

What happens in the case where the instructions given by IHRB contradict the instructions from my GP? I found myself in this predicament, and Mr Cohen kept admonishing my GP and Specialist, saying that I should use his products, or ditch my doctors in favour of one of his doctor-friends.


This contract commits the customer to purchase IHRB branded shampoos and cleansers and Saw Palmetto which are all useless and not essential to the treatment and which are sold at hugely inflated prices.


This is an open-ended commitment that seems unfair. How can a customer commit to other products which might be suitable or which might be expensive, or which might be useless or dangerous.

G) You must, after agreeing to proceed with your ‘hair re-growth treatment program’. You must pay in full as agreed.

I did pay in full. I was under the impression that we had agreed on a guarantee that I later found out was literally non-existent. After I signed and paid in full, Mr Cohen changed the contract.

H) You must truthfully and fully inform both the company (IHRB) and the doctor of any pre-existing medical or physical condition which may affect the satisfactory result of your treatment.

How is a client to know or understand what might affect the treatment? This onus cannot be placed on the consumer.

I) You must carefully read or have re-explained to you the conditions upon which the realgrowth treatment program is provided to you. We want you to fully understand the methodology of the program and what input is required by you.


I asked about the Indian Curries, but Mr Cohen said that they were company secrets and so he could not reveal the ingredients, but he emphasised that they were 100% safe. He said that without them, no treatment in the world will work, and this is why he is so confident to offer a money-back guarantee.

I asked Mr Cohen who would arbitrate in case of a dispute about whether or not hair had grown in accordance with his promise, and he said that I would be the judge, and in any case, we would have photos which a ‘blind man could see’.


The IHRB methodology is misleading and dishonest. At first, it was sold as an all natural product which Mr Cohen alleged to have discovered and innovated over 39 years, using Indian Curries.

Indeed, his material mentioned prescribed formulations. However, at no time does it outline that the medications used will be non-approved and dangerous medications.

The label on the topical solution had instructed me to use 1 mg twice per day. But Mr Cohen was upset by my following the label, and he wanted me to follow his instructions. Mr Cohen is neither qualified nor authorised to change the dosages.

The IHRB contract: Exclusions

The green text is from the contact, verbatim. The other text highlights my experiences with the contract.
I have underlined the text about which I will be commenting.

1) The hair regrowth treatment program incorporates pharmaceutical preparations, which, where necessary must be prescribed, and therefore treatment is conditional upon a medical practitioner’s approval of the treatment pharmaceuticals for your specific usage. If a medical condition precludes you from undertaking treatment’ we will transfer you to another non-medical program. REMEMBER that, after the conclusion of the recommended period of your treatment program, you will require an ongoing maintenance usage of the hygiene products and pharmaceutical compound to maintain normal hair growth. It is normally impossible to reactivate hair growth from dead follicles and from follicles which have been dormant for more than 3 to 4 years. Please note that in some cases the commencement of regular hygiene usage and the application of the prescribed treatment can cause scalp irritation, scalp flaking or peeling, burning sensation and very rarely some excess hair growth on face, arms and body. If these symptoms occur please discontinue treatment and contact us promptly.


Mr Cohen sold me preparations that contained Schedule 4 medications without a prescription. If he says that he did not, then why must he compound his own products? He told me that it contained Indian Curries. These do not exist. Therefore, why is he compounding at all? Why not use a tried and tested reputable brand of Minoxidil from Johnson & Johnson?


I was told that I was using non-prescription Indian Curries. Yet my bottle contained a Schedule 4 medication which was not prescribed. This clause is designed as a plausible front to a dubious business. The contract says all the right things, but in practice, there are no justifications for any of the products, and no respect for the law.


Mr Cohen started me on a program, and only after a period of seven months did Mr Cohen send me to my GP who then did not approve the formulations. Subsequent investigations show that the President of the AMA and other doctors and trichologists also warn against the use of non-approved and dangerous products.


At no time does the contract explain what this means. What are these non-medical products? If they exist, why not use them at all times, or give the client a choice from the start? A woman wrote to tell me that when her doctor warned her that IHRB’s treatment can damage the foetus, Mr Cohen said that her switch to a new non-medical treatment will now take two years, and therefore void her warranty, and cost her more in compulsory products. I suspect that these products do not exist, and are a way of prolonging the client’s confusion so that Mr Cohen does not have to refund any money.


The term ‘require’ contradicts the term ‘suggested’ which is used at the end of the contract, and which is followed by the word ‘maybe’. It also clashes with the term ‘recommend’ that is used in Clause 3.


In all or Mr Cohen’s advertising, he criticises his competitors for not explaining the full-term costs of the program. Here he is asking a client to commit to on-going expenditure, without spelling it out like he says other companies should.

The clause mentions the word ‘maintenance’. This sounds like a scaled-down version or a simpler version. Mr Cohen has two priorities in this order: 1) Do whatever it takes to show immediate cosmetic improvement so that the client crosses the 12-month mark to nullify the guarantee, and 2) Lock the client into purchasing products that are useless and at exorbitant prices.

At no point does Mr Cohen tell the client that when a client stops taking the very dangerous medications that boosted the amazing cosmetic improvements, that their hair will fall out rapidly.


This part of the contract is a money-grabbing exercise. Why on earth does a client need these basic detergents and cleansers and pointless Saw Palmetto herbs? There is not a single clinical study that any of these IHRB branded products work. We can know by the ingredients listed that they are useless. Why is a client being told that a shampoo will help with the regrowth treatment when it is nothing more than detergent and sold at eight times the price of comparable shampoo from any supermarket? These products have nothing to do with the regrowth treatment.


If the Indian Curries do not exist, and if this is a maintenance program, why must a client purchase a compounded product at astronomical prices, when Johnson 7 Johnson sells a comprehensive range of Minoxidil products? Why is compounding required if the Retin-A will no longer be used and if the Indian Curries do not exist?


After using the non-approved Loniten and Proscar, there can be no normal growth without them. Once these products are suspended, the hair will fall out rapidly. Mr Cohen is not educating the clients, and he is misleading them about the future commitment.


If the contract is conservative and cautious, and if IHRB knows that it is impossible to reactivate dead follicles or dormant follicles that are older than four years, why is he showcasing incredible testimonials from clients who say that they had been bald or balding for over 12 years?

The testimonials on the website, in the sales kit, on the walls of the IHRB office, and in the dozens of full-page ads published in magazines, show people who have had an almost complete coverage of new hair growth, and for whom ‘miracles’ have happened within three, four, and seven months. How can IHRB promote these amazing testimonials, yet say that it is impossible? Why show one thing during the sales campaign, and then void it here in the fine print?

Mr Cohen’s website and sales kit is filled with clients who use extraordinary adjectives such as ‘miracle’ and ‘genius’. Mr Cohen sets the expectations of amazing results by the unbelievable photos in his advertising campaigns. This is a screen-grab from his previous iteration of his website. It is headed ‘Great success’ and it reads, ‘Even though, roots affected with ‘hereditary baldness gene will die around 4 years, the successful treatment of IHRB has re grown hair, in varying degrees, with practically every male patient. Women can and have shown outstanding results…’

This proves that even Mr Cohen makes wild promises and then expects clients to erase all these from their mind when they ready the cleverly-worded contract.

If IHRB places dozens of full page ads, why does it not mention these adverse effects in the ads? IHRB might argue that their ads do not sell a product per se. Indeed, this contract shows the 100% reliance and insistence on these products, which come with severe warnings.

The contract says that the products might cause these irritations. Unfortunately, IHRB is not outlining the full facts and explaining that a typical regime includes Finasteride, Retin-A, and Loniten for men (plus other similar dangerous ones for women) which can cause foetal abnormalities, erctile dysfunction, and heart failure.

Why are these conditions not mentioned in the contract? They are not mentioned because Mr Cohen will shift the blame onto the client’s GP, saying that the person who prescribed these products ought to be responsible for the patient. This is what he told the Office of Fair Trading when I complained about Mr Cohen’s refusal to honour his guarantee. Mr Cohen blamed my GP.

The case officer believed him. Yet, My GP did not prescribe anything whatsoever.

The IHRB contract: Variations

The green text is from the contact, verbatim. The other text highlights my experiences with the contract.

2) The paragraph headings do not comprise a part of the terms and conditions of providing the treatment program. They merely illustrate the descriptive text they contain.

Why on earth is this clauses needed? It is used in preparation to void Clause number 5 whose heading is ‘More Hair or Your Money Back’.

From this clause number 2, the deception about the non-existent warranty begins.

The IHRB contract: Continuing Service

The green text is from the contact, verbatim. The other text highlights my experiences with the contract.
I have underlined the text about which I will be commenting.

3) On completion of your treatment program you will be entitled to receive free ongoing hair and scalp examinations, consultations, advice and assistance every 3 months for 25 years. We do however recommend that you continue to purchase and regularly use our hygiene products and also continue the application of the prescribed topical solution as a maintenance program.


Such tactics should not be used within a contract. This is basically saying that IHRB will continue to use sales tactics to grab me as a client. Sales pitches of this kind should be free. Who would pay for any advice from Mr Cohen. He has no qualifications and no authority. His only claim is that he has been in the industry for 39 years. This does not automatically provide him with the skills to be treating patients and advising them to go against the advice of their GP, the Specialist, and the warnings from the TGA and the pharmaceutical companies.


IHRB has no capacity and no tools to conduct any examination whatsoever. In my case, the supposed detailed examination involved Mr Cohen looking at my head and touching my hair for two seconds.


Mr Cohen is in no position to be consulting on medical subjects. Mr Cohen blatantly lied to me about TGA approvals in an email and in person.


Mr Cohen’s advice to me was to ‘ditch’ my GP and my Specialist, and to go against the TGA drug warnings and to go against the warnings of the pharmaceutical companies.


When I developed a painful rash, Mr Cohen provided me with no assistance. He did not inform his compounding pharmacist. He refused to check if the newly-opened bottle was the cause of the irritation. Mr Cohen distances himself when clients need assistance. This is what I experienced, and what others who contacted me said they experienced.

25 years

Mr Cohen was born 7 July 1937. This means that he turns 74 next month. What plans does IHRB have to honour its commitments to a client, by offering a 25-year support structure? Mr Cohen told me that he is the only consultant and that he has no one to take over, and that he can’t even find a single staff member who can open his new York office. This means that making such a long-term claim in a contract, without a succession plan, is making false promises.


The term ‘recommend’ contradicts the term ‘required’ in Clause 1, and the term ‘suggested’ which is used at the end of the contract and followed by the word ‘maybe’.


The use of these products will not help if Loniten and Finasteride were used to turbo-boost the rapid cosmetic regrowth. There is no scientific reason why IHRB products need to be used? If Minoxodil is all that’s required, why obligate the client to purchase these at inflated prices?

Ongoing products fromIHRB also means ongoing visits to the GP to obtain prescriptions for Retin-A which is all added costs. If Retin-A is not needed, then why not purchase commercially-available Minoxidil from reputable manufacturers?

Why is this not costed out for the client. Mr Cohen criticises his competitors for not doing this. And he does not doit himself.

The IHRB contract: Program Delivery

The green text is from the contact, verbatim. The other text highlights my experiences with the contract.
I have underlined the text about which I will be commenting.

4) REMEMBER we guarantee to provide and satisfactorily complete our side of the treatment program within an agreed time frame. Your failure to diligently follow or complete the program within that same agreed time period will probably result in a further deterioration of your condition, which will nullify our promise of satisfaction. You must give us the opportunity of reviewing or amending the program. If you do not follow the program recommendations fully and diligently within the stated time period it will not succeed and we will deny any liability for recompense of further treatment.


IHRB uses the term ‘guarantee’ in a sneaky way. In this context, in this Clause, it is used as it should be used, and that is, to positively assure that something WILL happen. Yet when it comes to growing hair, IHRB advertises guaranteed hair growth. IHRB is not saying that it guarantees more hair. It uses the looser term to mean that IHRB will try, but if it fails, the client can expect a refund. The guarantee in that context is a ‘backup’, not a ‘promise’.

I point this out to show that IHRB does play around with this word ‘guarantee’ to mean both expressions, and it is this sneaker use of the English language that it employs to confuse people into thinking that IHRB WILL regrow their hair.

Here is some text from an older version of the IHRB.com website that I saw some time ago. This type of expression seems definite and overly confident. Yet the contract show no such confidence. It reads: ‘IHRB can guarantee you a high level of satisfaction and produce far better results than you ever expected, because we know what causes baldness and what can be done about it. Most of our patients experience new hair regrowth within 3-6 months. IHRB will take the frustration out of your problem and solve it for you, giving you complete ‘peace of mind’.

IHRB’s contract keeps flipping from offering ‘satisfaction’ on the one hand, and ‘hair growth’ on the other. This means that a client’s opinion and satisfaction are irrelevant, because the promise is one of hair re-growth, and not one of satisfaction. Yet we see from the screen-grab shown above that the IHRB.com speaks a lot about satisfaction, as we will see below when we explore Clause 5.

By the way, on the question of hair re-growth, Mr Cohen told my case officer at the Office of Fair Trading that he never promised anything more than ‘some’ hair regrowth. In speaking with Sam, I formed the impression that his definition of ‘some’ could be as little as one strand. Yet we see his testimonial photos some remarkable transformations which give the impression to the average consumer that they can expect significant re-growth.


This is yet another unfair aspect of this contract. If IHRB simply does not perform, and if a client sees absolutely no improvement, this clause and others like it, mean that a consumer is unable to get out of this contract. There is no way to get out of the contract, no mater how abysmally IHRB performs.

Here, IHRB is saying that it reserves the right to switch and change anything and everything. If it fails, it will never admit defeat. It will entangle the client with endless trials and errors. IHRB wants the right to amend medications and treatments so that a client can never ask for a refund.


IHRB makes a sale, confirms a course of action, and then a client is bound to change course mid-stream, and this binds the client to follow IHRB’s instructions. Mr Cohen has no qualifications or authority to be directing an arbitrary new set of treatments. This merely torments the client who has to keep going back and forth, unable to cancel a treatment, no matter how bad it is. One former client of IHRB contacted me and told me that he had suffered severe pain as a direct result of the topical solution, yet Mr Cohen would not accept any responsibility and would not refund the money.


This is a lop-sided statement. Is IHRB saying that there is any other time when it would accept liability? No. Furthermore, that sentence is most ambiguous and it is badly written to the point of being nonsensical. IHRB does not recompense anyone for anything.

The IHRB contract: More Hair or Your Money Back

The green text is from the contact, verbatim. The other text highlights my experiences with the contract.

I have underlined the text about which I will be commenting.

5a) We are sincerely interested in your satisfaction.

If Clause 2 is invoked, we cannot link the heading of the section with the word ‘satisfaction’. This means that dissatisfaction does not warrant a refund. The section heading is ‘More hair or Your Money Back’. However, Clause 2 says, ‘The paragraph headings do not comprise a part of the terms and conditions of providing the treatment program. They merely illustrate the descriptive text they contain.’

This means that ‘satisfaction’ which sits under the ‘money back’ heading, has nothing to do with money or any refund or guarantee. So it is all a waste of time and an insult.

This statement is a complete red herring, and belongs in a sales brochure. It does not belong in a legally binding contract. This is because from experience, Mr Sam Cohen did not care about my satisfaction. He said that it was irrelevant. I told him that my hair-loss had become worse, and he said that I was wrong. So wrong in fact, that a blind man could see that I had improved.

Mr Cohen made it clear that my opinion or my assessment or my satisfaction did not matter and could not be taken into account.

Why or how this statement is in this contract is a complete mystery. It is used to trick people into thinking that they are in safe and reasonable hands. In fact, nothing could be further away. This line is part of a ploy and a plot to lull clients into a sense of ‘warm and fuzzy’ comfort.

5b) We say honestly “If you have diligently followed the hair regrowth treatment program, using the hair hygiene and supplementary products as recommended and faithfully applied the prescribed pharmaceutical solution, following each and every part of the program explained herein, but you have experienced no improvement in hair re-growth after 12 months (other than as a result of pre-existing medical or physical condition, which we did know of) we both agree that you will receive a refund of $3,700.


IHRB is declaring its honesty. Why does a contract need to emphasis that the seller is being honest? It is just fluffy language designed to disarm the reader. Mr Cohen was dishonest with me. Every part of my experience with him showed him and his company to be deceptive and dishonest.


This word is misleading. During the sales pitch, Mr Cohen speaks about supplements and herbs and Indian Curries. So with that flow of thinking, customers could assume that the word ‘supplementary’ products is referring to his herbal supplements. Indeed not. This tricky word is referring to ‘other’ products. The word supplement means ‘something that is added’. And so this refers to other medications that might be added and requested. Mr Cohen could request that clients go to their doctor and add some medications to the program. He might want clients to go and take other medications that their doctor would advise against. What if you a woman is pregnant or if a client suffers some other conditions, and their doctor says, no way, you can’t mix those medications, or you can’t take this product that Mr Cohen is recommending?


This sentence says that the client must follow the hair regrowth treatment. Why can’t the statement end there? Why must it continue to emphasis the other products? Are the products not part of the treatment? Indeed they are, except that IHRB knows that they are useless and superfluous and unnecessary. They are inefficacious products. However, they are highly profitable and extremely over priced. These are the profit spinners after the initial cash outlay which delivers absolutely nothing other than Minoxidil which is only worth under $400. So how can a $400 product sell at IHRb for $3,700 ($4,900 on the price list)? The justification is in the non-existent Indian Curries. Products are part of every clause and every mention because IHRb is trying to avoid the question: why on earth can’t we obtain these simple products from a pharmacy and a supermarket?


This is the icing on the cake. What is a pre-existing condition to someone who walks in and says my scalp is thinning? What is the pre-existing condition to a person who is balding or who is already bald? The pre-existing condition is hair loss. This is a pre-existing physical condition.

This is the cherry on the icing on the cake. It says that anyone who goes to IHRB for hair loss treatment, cannot expect a refund because of a pre-existing condition, being hair loss. So no refund. This augers well with the other absurdity that Minoxidil’s side effects include hair loss! A fact that was never mentioned to me, and which affected and accelerated my hair loss.

Both agree

When two parties sign a contract, it is given that both agree. Why do we see more warm-and-fuzzy language? What is there to agree? The contract ought to be clear. Both parties are signing it. There is no need to both agree. Of course we agree. It is superb copyrighting that pulls all the heart strings which weakens the reader, and no doubt stings the reader.

Mr Cohen told me that he had never had a dissatisfied client. This is a lie. Since completing my treatment, I have spoken with many clients who are livid and appalled by how they were treated by IHRB.

Agree to disagree. It does not matter because Mr Cohen has a different idea of business ethics. He told me that he has never refunded any money to anyone because I am the first case in his entire history of IHRB for whom the treatment did not work.

After the altercation that required police presence, Mr Cohen’s daughter told me that no-one has ever won. I told her that I will be taking the matter to the CTTT, and she said, people have tried, but they have never won.

The IHRB contract: What constitutes improvement?

The green text is from the contact, verbatim. The other text highlights my experiences with the contract.
I have underlined the text about which I will be commenting.

5c) What constitutes improvement? Normal hair regrowth equals improvement. How will we tell? The photographic records before, (where possible) during and post treatment will amply illustrate the result.


What is normal? Normal means what is generally happening or what was most recently happening. So a person who has been balding for ten years, who have normal growth at a rate of x strands of hair per month. At the same time, that person might experience 2x strands of hair loss. So if the number is 50, we can say that a person has come to expect, as being normal, for that person within the recent past to gain 50 strands per month and lose 100 strands per months. So the hair is always growing, while hair is being lost at a faster rate.

If a person were to pay for an IHRB treatment, and that person used to, most recently, experience 50 strands of hair, then even tough one is losing 100 strands per month, Mr Cohen would say that his treatment has been successful.

All the testimonials show people who risked heart disease, to achieve a spectacular boost in cosmetic regrowth. These people attained a much higher than normal hair regrowth. Why does IHRB show these testimonials on the one hand, and then say that nothing like this, not even remotely like it, can be expected?


The photographic records taken of my head were manipulated in how Mr Cohen first lifts my hair to show the sparse hair at the scalp. Then as the months tick over, he starts to hold my hair down so as to trick the camera into seeing a wider, stronger, denser coverage. Also, out-of-focus shots are taken, along with a change in the zoom factor. All of these are manipulated.

Mr Cohen so loves this photographic-based evidence, that he over-sells the idea, saying that he is the only person in the industry, and in the world, to give clients photos to take home.

The reason he gives us photos to take home, is so that we can forget about taking our own photos. We feel that the task is being done, so he disarms us from having t take our own evidence. He also loves it because he can manipulate the light, the angle, and the way the camera is used and how his fingers are controlling our hair.

This all works in his favour most of the time (certain not in my case because I cottoned on to his manipulation, which was always supplemented by an emphatic ‘Your hair is improving’.

If Mr Cohen cares to be truthful, he should employ a more sophisticated method of counting hair and measuring thickness, roots, strength, rate of growth, blood readings etc.

Furthermore, all the cosmetic growth will fall out after people stop taking the dangerous medication, and he never cares about this. He just needs to get people over the argument about the guarantee period. After that, he is safe.

however, he really is safer than we know. Mr Cohen voids the guarantee before the client leaves the office. He had already voided it by saying that a pre-existing condition voids the guarantee. But to be extra certain, Mr Cohen performs the final act of humiliation by asking the client to void the guarantee. More on this below.


This word is too liberal. It is saying that the room for error or the room for argument has been more than eliminated because the photos will amply illustrate hair growth. In my case, the photos amply showed me that my hair did not regrow. The IHRB treatment did nothing for me. The reason? My two doctors refused to prescribe dangerous and non-approved medications. As a result, I did not fall into his dangerous trap. The outcome? My hair did not grow.

Mr Cohen understood that I would not be risking heart failure, yet he still told me that if I were to following his other treatment (which I did) everything would be fine. It was not fine. That was his way of buying time to think about the next way of conning me into another two-year commitment. Even while I was walking out of his office, after the police was called, he kept telling me that I need him for three years, or I will go bald. ‘Is that what you want?’ he kept on asking.

The IHRB contract: The Chicken or the Egg?

The green text is from the contact, verbatim. The other text highlights my experiences with the contract.
I have underlined the text about which I will be commenting.

5d) I have read and understand the terms and conditions set out above and agree to start the treatment program.

This is an illogical loop. A signature at Clause 5d says that the client is committed. Yet the second bullet point at the very top of the contract says that we must initially go to a medical practitioner to examine and confirm our suitability for the program.

If the doctor says that we are not suitable, there is no way out, because the contract gives IHRB the right to keep experimenting and wasting our time.

This contract is trying to do several things:

1) Show the authorities that IHRB respects the medical profession’s boundaries and rules in relation to the use of medications

2) Push the onus and responsibility for any issues to a GP so that IHRB can wash its hands of any adverse side effects

3) Lock the client into a hideously unfair program that is compete unnecessary.

4) Use friendly terminology to suggest to clients that this contract is warm and fair.

5) Confuse the issue sufficiently so that any argument about any one thing, will invoke an argument about another thing. It is a circular contract that is badly written and completely not in the spirit of the copious advertisements that promise the earth either directly via body-copy or indirectly via testimonials and dubious advertorials designed to plant the seeds of hope in the reader’s mind.

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