# FDA WARNING_LETTER - Sugoi LLC - Unknown Date

Source: https://www.globalkeysolutions.net/records/warning_letter/sugoi-llc/7587f904-1bb8-4629-addc-0234a01fdacd

> FDA WARNING_LETTER for Sugoi LLC on Unknown Date. Product: Tobacco. Access full analysis and detailed observations.

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## Details

- Record Type: WARNING_LETTER
- Company Name: Sugoi LLC
- Product Type: Tobacco
- Office Name: Center for Tobacco Products
- Summary: The FDA and FTC issued a Warning Letter to Albert Shu regarding Pink Sticks e-liquid products sold on sugoivapor.com. The FDA determined these are tobacco products under the FD&C Act.

Two FD&C Act violations were identified:
1.  **False or Misleading Labeling/Advertising:** Pink Sticks e-liquid is misbranded under sections 903(a)(1) and/or 903(a)(7)(A) of the FD&C Act. Its labeling and advertising imitate Pocky Strawberry biscuit sticks, a product appealing to children, through similar packaging, imagery, color scheme, and description ("a delicious flavor of ripe strawberries blended into a sweet pink cream that covers a crispy cookie biscuit"). The product also has a strong, detectable scent similar to the biscuit sticks. This imitation is misleading and poses a risk of accidental ingestion by children, with potential for acute nicotine toxicity, seizures, coma, respiratory arrest, and death.
2.  **Sales to Minors:** Pink Sticks e-liquid is misbranded under section 903(a)(7)(B) of the FD&C Act because it was sold to a person younger than 18 years of age, violating 21 C.F.R. § 1140.14(b).

The FTC also reviewed the marketing under Section 5 of the FTC Act, stating that packaging Pink Sticks e-liquid in

## Related Officers

- [Director](https://www.globalkeysolutions.net/people/ann-simoneau/155ef03c-6b60-4063-b35d-75522fa67d2b)
- [Associate Director](https://www.globalkeysolutions.net/people/mary-k-engle/9426dfba-028c-4d3a-bb62-7bdea653e6bc)

Company: https://www.globalkeysolutions.net/companies/sugoi-llc/27b07d19-7242-4ad5-bd1e-7b12bda6910c

Office: https://www.globalkeysolutions.net/offices/center-for-tobacco-products/65f73cae-ef6f-4e9f-a311-a111daa67374