Sharon Blinkoff

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On September 7, 2012, the FDA issued a Warning Letter to Lancȏme USA, a subsidiary of L’Oreal, advising that claims made on Lancȏme’s website for a series of products sold under names containing “Youth Activating” and “Regenerating and Reconstructing” caused the products to be drugs under the Food, Drug, and Cosmetic Act. (the FDA sometimes considers websites to be “labeling” or, alternatively, evidence of intended use)  In its letter the FDA stated that the listed…