Monetizing the COVID-19 Backlash

Trial Site News’ fair and balanced “deep dive” investigation into “The Wellness Company”.

This essay was originally published by Trial Site News, and is republished here with permission.

Author: stevenoconnor, Attorney at Non-profit

Jan. 4, 2024, 9:30 p.m.

We refuse to profit from your sickness. Join the fight for medical freedom by supporting TWC — a company focused on your Wellness with incredible doctors, treatments, and products.”

A quote from Dr. Peter A. McCullough of The Wellness Company, a startup seeking to build a parallel health system. But along the way, will the company start embracing attributes mastered by the existing healthcare corporate empire?

Founded in June 2022, the Wellness Company is a new company that offers supplements that purport to reverse damage from mRNA vaccines, along with COVID-19 treatments offered via telemedicine subscriptions.

Founded by Foster Coulson, the driving ethos was to build a company to support a patient-centric, parallel healthcare company.  Driving that vision was what Coulson saw as a system during the COVID-19 pandemic demonizing front line physicians and available, safe medicines that could have saved in his view millions of lives. 

A lead player is the high-profile Dr. Peter McCullough, quoted above. But of course, this firm focuses on profits if it is to grow, invest and truly offer an alternative system, friendly to patients. While the Wellness Company is a privately held, independent venture,  a review of Coulson’s investments reveals what looks to be a larger-scale entity designed to give mainstream healthcare systems competition.

A company Mission Statement, named “Warrior Initiative”, purports that TWC focuses on veterans and first responders.

This initiative statement indicates that:

“We believe a moral obligation exists to serve those who have fought a two-decade long war to ensure our security and safety—especially those who returned from combat with physical and/or mental scars.

We owe another debt to those on the home front who risk their lives every day as First Responders, putting their lives on the line to protect and save ours. The Wellness Company (TWC) is committed to serving our Veterans and First Responders whom we consider our nation’s warrior class.

TWC’s mission is to bring the most comprehensive wellness products and resources available to promote healthier and more holistic lifestyles for our warrior class.”

Despite this noble mission statement, TWC has earned an “F” from the Better Business Bureau. And oddly, an unrelated firm, with an identical “The Wellness Company” moniker, is a pro-vaccine medical services organization out of Rhode Island.

What follows is both a critical review of TWC plus the summary of a discussion with their Chief Executive Officer Peter Gillooly.

Who is behind the Wellness Company?

Foster Coulson is Founder and Chairman of TWC. According to the left-leaning magazine Mother Jones, Coulson’s family “made its fortune manufacturing firefighting planes.” In fact, the family company, Coulson Aviation positions itself as a leader in aerial firefighting and is actually part of Coulson Aircane Ltd, which in turn, is all part of the privately held Coulson Group.

Clearly, Foster Coulson has been influenced a great deal from his family’s private conglomerate, one that appears to have maintained its control by keeping private equity investors out. The only financing appears to be a few million in debt in 2018, at least according to Pitchbook.

The young Mr. Coulson certainly benefited from that valuable experience with the family venture to launch TWC, which is also part of a complex group of companies, all somehow seemingly related to Integro Capital LLC, (IC LLC) which Coulson founded back in October 2021, (during the apex of the pandemic) as a vehicle to invest and profit, and maybe even change the U.S. healthcare system.

In terms of overall corporate structure, IC LLC has been formed as a holding company designed to monetize the dynamics arising out of the COVID-19 pandemic, with one of the investor’s companies (TWC) being focused on building a parallel health system.

After all, establishment health systems and government health agencies such as the Centers for Disease Control and Prevention and the Food and Drug Administration took a big credibility hit during the pandemic.

A large segment of the health market, already skeptical about conventional health systems, pharmaceuticals and the like before the pandemic became even more wary as perverse financial incentives, “public health” and acute care mismanagement were revealed to wary consumers.

During the pandemic, the state (government) overreach, and the usurpation of front-line care due to the national public health emergency triggered top-down realities profoundly impacted Coulson, who, during his travels in South America, encountered primary care physician Dr. Vladimir Zelenko, known well in medical freedom movement circles for his influence (via hydroxychloroquine) on former president Donald Trump.

It was Zelenko’s popularizing a three-drug combination of hydroxychloroquine, zinc and azithromycin as an intervention for mild-to-moderate COVID-19 (Zelenko protocol- derived from the prior work of Dr. Dieter Raoult, which was co-marketed with Coulson as “Z-stack” supplements) that inspired Coulson to think of bigger business opportunities.

TrialSite has been told through the network that Coulson did quite well with the Z-stack during the pandemic.

Of course, any mainstream interpretation insists on the conspiracy theorist tag for Dr. Zelenko, but TrialSite chronicled many well-meaning, objective and competent front-line physicians whose character was attacked during the pandemic merely for standing up and offering other ways to help deal with the crisis.

And our network assures us Coulson’s moral outrage was high watching the treatment of both doctors and patients during the pandemic.

Passing in 2022 due to cancer, Dr. Zelenko’s mission and their commercial success with the “Z-stack” product inspired Coulson’s bigger vision for a series of corporations that would take on various aspects of offering a parallel health service.

It was a “de-prescribing from Big Pharma once and for all,” as conveyed by Kiera Butler in the Mother Jones piece.

Part of Bigger Aspirations

Perhaps, following in the footsteps of the preceding larger Coulson Groups’ numerous interrelated subsidiaries, Foster Coulson sought to structure something similar, in a different industry, yet he has far bigger aspirations than aviation concerns.

The younger Coulson seeks to creating a parallel health system in places like the United States, where annual health expenditures currently top $4.5 trillion, approaching 20% of Gross Domestic Product.

And make no mistake, supplements are big business. Not pharma level, but big.

According to analysts such as Precedence Research, the U.S. dietary supplement market was valued at $50.91 billion in 2022 and will grow at a healthy rate (CAGR) of 57 percent from 2023 to 2030, unless big pharmaceutical companies can tap into and own some of that growth with more regulation, a market strategy another influential COVID-19 response critic recently highlighted.

In the United States, this supplement industry growth rate is largely powered by the Dietary Supplement Health and Education Act of 1994  (“DSHEA), which carved out a regulatory exception for dietary supplement such as vitamins and minerals.

Consequent to this bill, the health and wellness industry supplement sector products are not subjected to the same regulatory requirements as pharmaceuticals and other medical products, including conducting expensive time-consuming clinical trials or obtaining regulatory approval.

However, supplements and nutraceuticals are forbidden from making efficacy claims unless they are supported by substantial clinical data.  Dr. Robert Malone writes:

“Needless to say, the pharmaceutical industry has been working to amend the DSHEA act to make it more difficult for such products to make it to the market.”

And the supplement business is known for its bare knuckle, fierce competition. For some perspective on the leading players in this growing space—one that will likely grow further due to COVID-19 backlash:

Enter Coulson’s International Health Brands (IHB), created along with ex-Navy Seal with supposed defense ties, Dave Lopez. IC LLC, IHB, and TWC (at least during the startup phase) appear to all share the same address in Boca Raton, Florida.

These related firms are each designed to support or monetize (depending on one’s perspective), particular areas of health.  But we emphasize that according to CEO Peter Gillooly, any of Coulson’s investments are completely separated, firewalled and not influencing each other.

IHB has several companies (and separate brands) under its umbrella, including the following:

Note that TWC CEO could not or was not at liberty to explain IHB and its legal relationship to TWC, although O’Connor mentioned to him that TWC is listed on IHB as one of its companies.

Again, Gillooly denied any ties, emphasizing, “TWC is 100 percent a separate self-contained company.”

Coulson’s Integro Capital, or Coulson operating under a different investor umbrella, also has some level of investment in the other ventures. The following is a list of Integro and/or Coulson direct investments.

Most of the medical freedom world knows of Coulson for his founding TWC. In fact, a handful of TrialSite subscribers requested that we do an objective write up on the TWC and Coulson. In this activity, TrialSite, independent itself, seeks to be as objective and unbiased as possible.

Like most others active in this sector, TrialSite had no idea TWC appeared to be part of a startup-to-conglomerate aspiration, one seeking to power and monetize a parallel health economy. For example, while TWC and Elite might be different companies, they both sell supplements, and both have Coulson as likely majority shareholder.

Coulson’s certainly thinking big, and in healthcare and pharmaceuticals this comes with high risk and the need for large amounts of capital. But we have a level of appreciation for Coulson’s big vision.

TWC’s most well-known product is a supplement based on Nattokinase, an enzyme produced by natt?, a traditional Japanese food produced from soybeans fermented with the bacterium, Bacillus subtilis.

Marketed as “Spike Support Formula” and purported to undo damage caused by COVID-19 vaccines, it’s this sort of business line that can draw the attention of regulators.

Importantly, the spike protein hypothesis for vaccine injury has not been recognized by the FDA, or the National Institutes of Health or the Centers for Disease Control and Prevention (CDC).

However, TrialSite has reported on nearly a dozen peer-reviewed studies that point to the existence of a lingering, spike protein at least in some persons both vaccinated and/or with long COVID.

TrialSite’s founder Daniel O’Connor pointed out, “It is unfortunate that in times and situations such as this where trust in our health-related institutions weakens, and we seek to understand the emerging evidence, it cannot be discussed. Why?”

O’Connor continued, “And of course, antithetical to science itself would be the repression of emerging science for some other aim, be it politics, finance or religion and ideology.”

In evaluating TWC therapeutic claims or marketing messaging, a key question is whether Nattokinase-based supplements measurably improve clinical outcomes in patients that have some lingering injury associated with an mRNA vaccine or long COVID for that matter?

Are there credible clinical data supporting such a claim? TrialSite can only review the scientific literature, relevant and credible reports and tap into its network.

TrialSite journalists have reviewed multiple claims linked to TWC.  From a strictly medical evidence perspective, there are few, if any, data demonstrating clinical efficacy. However, that’s doesn’t mean that the substance cannot help.

It just means that it cannot be marketed to do so.  Rather the substance must be marketed for general health purposes.

Physicians such as Dr. McCullough treat hundreds, if not thousands of people, and based on consenting patients, they should be rigorously tracking (at least in observational studies) clinical findings with this product, publishing the results where other peers can review, learn, critique, and potentially accept.

Peter Gillooly informed TrialSite’s Daniel O’Connor that since day one, TWC established a 50 -state telehealth network. Of course, this means that the group would need all the bells and whistles for compliance to ensure adherence to state board level requirements.

Now, a next level vision would have included research designed right into the system. So, as patients were prescribed combinations of repurposed therapies and supplements TWC would have introduced the next level of real-world evidence putting the rest of the health system to shame.

But that sort of sophistication is certainly hard to come by.

TWC uses other advocates, some more opinionated than Dr. McCullough such as Paul Alexander, Ph.D. In one of his Substack entries, Dr. Alexander seems to link a TWC product incorporating a berberine-based supplement with the potential of metabolic benefit.

See “Selling Wellness Freedom Against Pharma Lies by Omission” for a critical assessment of any berberine-based claims. TrialSite offers a critical review of some of those claims.

Alexander has made quite a controversial name for himself of late on his Substack, continuously bashing Robert Malone publicly for his role as a young scientist researching mRNA and claiming that he has some vague association with pedophilia, as if Malone, two decades ago, schemed and dreamed of dangerous vaccines to give to the public.

We here at TrialSite are disgusted with the type or character assassination happening among people generally sharing the same cause: a more patient and provider-centric, dynamic, competitive and economical health care system empowering us to be healthier, not sicker.

Up until recently, the Nattokinase-based supplement which is claimed by TWC to target spike protein has been heavily promoted online in various conservative and libertarian leaning channels, again, mostly centered around its chief scientific proponent Dr. Peter McCullough, a contributor to TrialSite, and an internationally renowned figure at this point, especially for those that had real problems with the top-down, overbearing statist and globalist approach to COVID-19 response.

McCullough, a highly published cardiologist-epidemiologist, resisted the approved narratives which emerged during COVID-19, establishing protocols of repurposed drugs to help patients on the front lines during the onset of the pandemic.

McCullough was an early adopter in promulgating alternative treatment regimens in response to mild-to moderate COVID-19—the McCullough Protocol.

While becoming an activist for patients and physician autonomy, the former academic cardiologist paid a heavy price economically, with terminations and lawsuits—one big one in which he was victorious.

Other groups staking a claim to early adoption and promotion of front-line protocols would include the COVID-19 Front Line Critical Care Alliance (FLCCC), Zelenko himself, Dr. Sabine Hazan (who registered one of the first ivermectin-based studies with the U.S. government) and others.

TrialSite interacted with Robert Malone literally at the beginning of the pandemic when that physician-scientist was investigating the prospect of famotidine, the active compound for Pepcid, the over-the-counter heartburn drug Pepcid (which has been proven to have some efficacy for COVID disease and was used to treat Trump), as well as the combination of Famotidine plus Celecoxib.

In fact, hundreds of healthcare professionals behind the scenes with little to no media attention sought to care for patients first with a wide variety of early treatment protocols.

This is taken from a long document, read the rest here substack.com

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