Deciphering IHRB’s unlawful ads

Deciphering IHRB’s unlawful ads

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The Complaints Resolution Panel had determined that Sam Cohen’s IHRB advertisements are ‘Unlawful, misleading, and unverified’. The Panel imposed Sanctions on IHRB. This was followed-up by the big-guns in Canberra at the Therapeutic Goods Administration (TGA), which is part of the Federal Department of Health. The TGA has Ordered IHRB to cease and desist, by banning IHRB from publishing its ads and by Ordering IHRB to withdraw its statements, its promises, its claims, and its misleading and down-right incorrect and illegal statements. You can read about the Sanctions here, and about the TGA Orders here, and about the HCCC Prohibition Orders here.

IHRB’s ads have been published in a range of foreign languages, in various publications and magazine, and on its own website. Below is one of the very many misleading and deceptive ads. This article hones in on some of the statements and explains how IHRB has been misleading the public via unlawful and unverified claims.

IHRB Ad analysed 660 px


In his sales pitch and in his ads, Sam Cohen says that he has invented the world’s first and the world’s best hair regrowth formula. Clients are led to believe that IHRB has a product to regrow hair that is the first in the world. When challenged about this ad, Mr Cohen says that he meant that he is the first in the world to offer a guarantee. In either case, he is wrong. He has no formula which can regrow hair, which is why the TGA has specifically banned him from making such a statement. The TGA Order specifically says (amongst many other things) that IHRB must stop saying that its herbal and natural products can regrow hair. And the TGA has Ordered IHRB to stop saying that it can grow hair in people for whom Minoxidil did not work (because he has, while under Oath at a Hearing, said that Minoxidil is a ‘flash in the pan’ and that his formula never fails). The TGA has also Ordered IHRB to stop saying that its products can aid in the regrowth of natural hair for those experiencing hair loss.


What is this formula? Any product that can regrow hair, is, by definition, a ‘therapeutic’ product. The TGA requires any therapeutic product to list its ingredients on the bottle, and the TGA requires that such a product be Registered with the TGA after scientific evidence of the efficacy and safety of such a product is furnished. IHRB has never had anything tested and has never labelled its products correctly. It has never registered its products with the TGA. All its pharmacists say that they have never known about any such therapeutic products and never injected anything into Minoxidil that was Sam Cohen’s, or was IHRB’s intellectual property, nor anything that had active ingredients or that had any therapeutic value. In other words, I allege that it’s all misleading and deceptive conduct designed to steal money from innocent clients who pay thousands of dollars for Minoxidil and such like, all being products they could have purchased at around $15 per bottle from their local pharmacist, without having Sam Cohen as the middle man (who sources medical products illegally and sells them illegally).

3 “AFTER 40 YEARS OF RESEARCH… there is nothing better than the best”

Sam Cohen’s company is called the ‘Institute of Hair Regrowth & Beauty’. The word ‘Institute’ is misleading. Sam Cohen speaks of 40 years of research. He has no such research. He tells his clients that he knows more about hair than doctors. In this ad, we read that he guarantees that there is nothing better than his products. Given that he is Prohibited from Supplying or Selling medications, and given that he has never proved that his concoction can regrow hair, then what is this advertisement saying? How can he claim that there is nothing better than his products? He has no efficacious products that can regrow hair. So how can it be the best? The best at doing what? His clients who have enjoy hair regrowth, have been enjoying the benefits of Minoxidil (some with Retin-A) and Finasteride and some have taken Loniten. It is these products that have helped some of his clients, and they could have purchased the products via any pharmacists (some with a doctor’s prescription). Every single client (including those who are thrilled to see hair regrowth) have been ripped off. They simply did not understand that they could purchase those products on their own, without stupid IHRB contracts and without risking their health in the hands of a man whom the Health Care Complaints Commission, after in-depth investigations, found to have risked the health and safety of his clients.


Sam Cohen tries to position himself as a hair expert. He uses medical and surgical terminology, while telling his clients that he invented the secret formula for hair growth, and that he has a Bachelor of Science. What proof does he have to back-up his extreme claims that enable him to use words like ‘INNOVATED’ or that he has improved hair implantation PROCEDURES (which is a medical procedure). As a man with no qualifications, how can he possibly ADVISE and CONSULT on ALL types of hair transplants?

5 “NO ‘IFs’ AND ‘BUTs’”

This site has published the woes of some IHRB clients who had nothing but trouble in trying to invoke the guarantee. Some filed an Application with CTTT (Consumer Tribunal) and found that Sam Cohen lied about every aspect of the transaction, including fabricating evidence. The IHRB contract is a farce, and is in no way a fair contract. In fact, through a sneaky trick, Sam Cohen voids the contract within seconds of it being signed, and thereby ensnares his clients. Sadly, CTTT Members are unable to fathom the process, resulting in injustice.


In this and every other piece of literature, and even in his older ads and currently on his website and on the front of his sales folder, Sam Cohen speaks about being the only one who can block the balding gene. The only product that can affect DHT is Finasteride. This is a Schedule 4 medication that requires a doctor’s prescription, and it comes with grave warnings. Finasteride has an unfortunate side-effect of unintended hair regrowth, which Sam Cohen uses as part of his medications. However, considering the HCCC Prohibition Orders, how can Sam Cohen be promoting any such product? It would be illegal for him to supply or sell such a product. The definitions of SUPPLY and SELL are featured at the bottom of this link.


Sam Cohen is admitting that he uses Minoxidil (sometimes with Retin-A). Minoxidil is a pharmacy-only medication/poison, classed as Schedule 2. The Health Care Complaints Commission has Prohibited Sam Cohen and IHRB from Supplying or Selling any pharmacy-only (Schedule 2) product. The definitions of Supply and Sell are featured at the bottom of this link. The definitions mean that IHRB cannot, in any way, shape, or form, have anything at all to do with these products, no matter how Mr Cohen might justify the supply-chain. Furthermore, Sam Cohen is mentioning that some bottles might contain Retin-A. This requires a doctor’s prescription, and would also make it illegal for Sam Cohen to have anything whatsoever to do with its sale or supply.


Click on this thumbnail to see a very large version of this ad in PDF.

Click on this thumbnail to see a very large version of this ad in PDF.

Sam Cohen is admitting (as he has admitted while under Oath at CTTT) that he adds his secret extracts. He says that they are exclusively his own formula. His own pharmacists have signed Affidavits that no such secret natural extracts exist. The first pharmacist was a pharmacist in Melbourne. He supplied IHRB for over 8 years. He signed an Affidavit to say that he never added anything whatsoever to the Minoxidil topical solutions, despite agreeing to do so. He was never satisfied that Sam Cohen’s concoction was of any use, or safe, or anything of significance. So for 8 years, no IHRB client was receiving or benefitting from Sam Cohen’s concoction. From my investigations, I allege that Mr Cohen was (and still is) illegally selling Minoxidil. The second pharmacist was Jonathan Fryar (of Hunter Pharmacy) who has since been De-Registered by the Pharmacy Tribunal for his part in supplying medications to Sam Cohen. Mr Fryar signed an Affidavit that the concoction (that Mr Cohen had supplied to him) was neither exclusive nor secret, nor was it the intellectual property of Mr Cohen. Mr Fryar also swore that the dubious formulation had no therapeutic effect (meaning it could not have grown hair) and had no active ingredients. The third pharmacist was Elias Pharmacy. In a Return-on-Summons for a CTTT hearing, Elias Pharmacy signed a letter to the Registrar that it never added any formulation, and knows of no secret natural extracts. It is alleged that Elias Pharmacy is still (to this day) illegally supplying IHRB with Minoxidil. When cornered with these revelations, Mr Cohen told CTTT that he does not use medications at all. Instead, he claimed he used Activance, to which he adds his secret extracts. Activance has nothing to do with hair regrowth. It is not a therapeutic product. Its ads have been Sanctioned after being found to be misleading. Therefore, Activance is an ineffective product. So how can Sam Cohen sell an ineffective product, while claiming to add his unproven extracts, and charging exorbitant fees for products that are supposed to regrow hair. My investigations have shown (and hence I allege) that IHRB is illegally selling Minoxidil, as was discovered when I sent bottles to be tested by a TGA-Accredited Laboratory.


Sam Cohen is saying that the success of his clients (some of whom do regrow their hair) is due to his exclusive, secret formula. He is saying that besides the Minoxidil, he adds his secret formula, hence the success and hence the confidence he has to provide a guarantee. I have audio files from a CTTT hearing whereby, while under Oath, Sam Cohen says that despite his clients taking a wide range of medications, that it is his secret extracts that contributed to his clients’ success. Any such extracts must be Registered with the TGA, and scientific proof must exist, and the ingredients must be listed on the labels. Sam Cohen meets none of these requirements, which is why he now has a TGA Regulation-9 Order against IHRB.


The Complaints Resolution Panel has deemed IHRB’s testimonials to be unverified. Indeed, these clients have enjoyed hair regrowth. However, some have told me, and Mr Cohen himself has admitted during a CTTT hearing, that the clients have taken a wide range of medications including Loniten, Finasteride, Minoxidil, and Retin-A. This dangerous combination does have a high probability of success (while for some clients, it can be deadly). One of the women featured in this ad is Maree Azzopardi. She told me that she took Finasteride and Minoxidil, and that she receives a 50% discount for allowing Sam Cohen to feature her story. Indeed, her hair grew back. However, she had paid IHRB $3,000 for the first year, and then $200 per bottle per month, for a few years thereafter (now she receives a discount), all while believing that Sam Cohen has a secret formula. Like other clients, she believed that she was receiving something that Sam Cohen had invented. All along, she was using a product that she could have purchased from any pharmacist for $15. I allege that she was scammed, but she was so happy to see her hair grow, that she did not care to query Sam Cohen. She said that she had contemplated suicide, and that she was devastated at losing her hair. When the medications worked, she was very happy, and felt that Sam Cohen’s formulation/bottles were doing a great job. She did not understand that she was:

a) being scammed;
b) lured by an advertisement that should never have been published, because it was sanctioned by the Complaints Resolution Panel;
c) illegally supplied Minoxidil because IHRB was under an HCCC Prohibition Order;
d) receiving medications from a pharmacist who was breaking all the rules by not owning the direct relationship with the end-user;
e) being conned about a secret formulation that does not exist;
f) able to purchase those products from any pharmacist at $15;
g) misleading the public by endorsing IHRB via ads that should not be published because they were Sanctioned;
h) misleading the public by not telling the public what medications she took, because she is inadvertently endorsing the secret formula, for which she neither has proof of its existence nor its efficacy;
i) using bottles that were not labelled and did not feature the ingredients, as is required by law;
j) not open and honest about receiving a 50% discount in exchange for her blind support and inadvertent collusion.

Another person who had supplied unverified and misleading testimonials is Sam Badawi who claims that he is a hairdresser. Sadly, reports and investigations show that he is NOT a hairdresser, despite owning a salon of sorts.


The HCCC requires IHRB to publish this statement. Unfortunately, the average consumer would not have a clue as to what this means. It warns the public that there is an Order in place. However, it does not outline what that Order means. Therefore, this is a useless statement that Sam Cohen has told Members at the Tribunal (assisted by his Solicitor) that the Order simply requires him to ensure that all medications are supplied via his pharmacist. If that is what Sam Cohen tells a Tribunal Member, you can imagine what he tells clients. Sam Cohen does not seem to admit that the Order renders his business closed. His business is a legal impossibility, as outlined in another article you can read if you click here.

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