Exhibit 04
Multi-Level Marketing
FTC
Sued her former employer as a pyramid scheme.

Before civic leader, she was a senior director at a pyramid scheme.

Brooke spent years at Nerium International selling an “age-defying” cream made from a poisonous plant extract. The FTC later sued Nerium as an illegal pyramid scheme.

Before Lori Brooke became a neighborhood association president and District 2 candidate, she had a different career. From 2014 to at least 2017, Brooke worked as a sales representative and “Senior Director” at Nerium International, a multi-level marketing company that sold “age-defying” skin cream made from a poisonous plant extract. In 2019, the Federal Trade Commission sued the company, alleging it operated as an illegal pyramid scheme.

Brooke was not a casual customer who bought a few bottles of cream. She held the title of Senior Director — the fourth rank in Nerium’s multi-level compensation hierarchy, which required building at least three “legs” of recruited sellers beneath her. She gave product demonstrations on YouTube, spoke at recruiting events, and earned a car bonus from the company. This was a person deeply embedded in the business of selling an MLM dream to other women.

4.1

The Company

Nerium International launched in 2011 as a single-product MLM company built around a skin cream called Nerium AD. The company later rebranded as Neora. Like all MLMs, Nerium’s business model depended less on selling products to outside customers and more on recruiting new “brand partners” who paid to join, bought inventory, and then recruited others below them. The compensation plan had eight ranks, from Brand Partner at the bottom to Royal Black Diamond at the top. Brooke’s title of Senior Director sat at the fourth level — meaning she had successfully built a multi-tiered recruiting network beneath her.

A March 2017 Constant Contact email from a fellow Nerium seller named Clara Bellino invited San Francisco women to a “Real Results Market Party” featuring Brooke as the guest speaker:

Finding 4.1 · The Company

“I’m excited to share with you that we’re welcoming Special Guest Speaker, Senior Director with Nerium International Lori Brooke, to our monthly San Francisco Party! Lori is married, has two daughters ages 16 and 18.5, and lives in Cow Hollow. She’s been involved with Nerium International since 2014 and fell in love with the product after experiencing dramatic improvement on the skin of her neck. She’s grateful to Nerium, not only for the youthful boost, but for the amazing women who have come into her life — and the cool Lexus car!”

The “cool Lexus car” was not a gift. It was part of Nerium’s incentive structure. MLM companies routinely offer car bonuses to top recruiters — not as outright purchases, but as monthly lease payments that continue only as long as the seller maintains her recruiting volume. If the downline shrinks, the payments stop, and the seller is stuck with the lease. The car bonus exists for one reason: to create the appearance of wealth and success at recruiting events, encouraging new recruits to sign up.

Nerium Market Party flyer listing Lori Brooke as Senior Director

“Real Results Market Party” flyer listing Brooke as “Guest Speaker, Senior Director with Nerium International”

4.2

The Product

Nerium AD was marketed as an “age-defying” night cream with a single hero ingredient: an extract from the oleander plant. Oleander is one of the most toxic plants in North America. Every part of it — leaves, flowers, bark, sap — contains cardiac glycosides that can cause fatal poisoning in humans and animals. Nerium’s pitch was that this same toxic compound, applied topically, could reverse wrinkles and rejuvenate skin.

A CBS News investigation examined the claims. Dr. Vic Narurkar, head of Dermatology at California Pacific Medical Center in San Francisco, told CBS there was no “real science” behind the product. He reviewed the before-and-after photos on Nerium’s website and said the purported results were “impossible without Botox or a surgical brow lift.” The photos, presented as proof of the cream’s effectiveness, were staged to show results that a topical cream cannot produce.

Brooke was not a skeptic. She was a promoter. In January 2014, she posted a YouTube video demonstrating how to apply Nerium AD cream to her own face, walking viewers through the nightly routine the company taught its sellers to share:

Brooke’s own video demonstrating how to apply Nerium AD cream, January 2014

Source: YouTube

4.3

The Lawsuit

In November 2019, the Federal Trade Commission sued Nerium International in federal court, alleging the company operated as an illegal pyramid scheme. The FTC’s complaint stated that Nerium’s business model was structured so that most participants “end up making little or no money, and a substantial percentage lose money.” The agency alleged that Nerium used income claims to recruit new brand partners while concealing how few of them would ever earn anything.

The case had a mixed outcome. In September 2023, a federal court dismissed the FTC’s complaint. Nerium declared victory. But the story did not end there. In May 2024, the same court ruled that the FTC’s position had been “substantially justified” — meaning the agency had a reasonable basis for bringing the case — and denied Nerium’s request to recover its legal fees from the government. The court found the FTC’s pyramid scheme allegations serious enough that the lawsuit was warranted, even though the agency ultimately failed to prove its case at trial.

By the time the FTC filed suit, Brooke had already moved on. But she spent years building her network inside a company that the federal government later determined had sufficient hallmarks of a pyramid scheme to merit a federal lawsuit.

4.4

The Reinvention

After Nerium, Brooke reinvented herself. Her LinkedIn profile lists her as a “Partner” at “Women Venture Partners” from 2019 to 2022, described as a venture capital and private equity firm. The title suggests a serious career in finance. The record suggests something else entirely.

There is no registration for Women Venture Partners with the California Secretary of State. There is no record of it in the SEC’s EDGAR database, where any legitimate investment advisory firm would be registered. No fictitious business name filing exists. The company’s LinkedIn page lists Brooke’s own home address as its business address. Every public database that would confirm the existence of a real venture capital firm returns nothing.

Then, in October 2025, Brooke made a $500 contribution to her own supervisorial campaign. On the SF Ethics Commission disclosure form, she listed her occupation as “retired.”

Finding 4.4 · The Reinvention

Senior Director at a company the FTC sued as a pyramid scheme. Then “Partner” at a venture capital firm with no state registration, no SEC filing, and no address beyond her own house. Then “retired.” Now she wants to represent District 2.

Brooke’s professional history follows a pattern: grand titles attached to entities that do not hold up under scrutiny. At Nerium, she held a rank that sounded prestigious but meant she had recruited enough people into a company the federal government would later call a pyramid scheme. At Women Venture Partners, she claimed a partnership at a firm that appears to exist only on LinkedIn. The career she presents to voters is built on credentials that dissolve the moment anyone checks the public record.

Share this with your District 2 neighbors.

Election Day — June 2, 2026

Paid for by GrowSF Voter Guide. FPPC # 1433436. Committee major funding from: Nick Josefowitz. Not authorized by any candidate, candidate's committee, or committee controlled by a candidate. Financial disclosures are available at sfethics.org.