Now, in the warning letter, the agency said that apoaequorin did not meet its definition for a dietary ingredient. Since Quincy was also still making therapeutic claims in its marketing materials, and had conducted clinical investigations with the ingredient—two things only drug manufacturers are allowed to do—the agency stated that it considered Prevagen not to be a supplement at all, but an unauthorized drug. In letters that followed, Quincy disagreed with this assessment vigorously.

Top seller

At the time, Prevagen’s popularity was soaring.

From the beginning, Mark Underwood had been a tireless advocate for the supplement. Before it was picked up by national retail chains, Prevagen was sold directly to consumers, and Underwood would sometimes appear on local radio shows in Wisconsin, speaking enthusiastically on the air about what the product could do for the brain.

“If you don’t have the type of protein that’s contained in Prevagen, your brain is susceptible to death or injury,” Underwood said on one radio show in 2008. “Quite frankly, we’ve raised the bar towards a lot of thinking where some people were pretty satisfied saying well, you know you’re just old, you have dementia, you have this issue, there’s not much you can do.”

Back at Quincy Bioscience’s corporate office, the sales team would be waiting to field calls from listeners concerned about losing their memories, said former employees.

In those early days, management was “basically hiring anyone with a pulse to join,” recalls Jovan Chavez, who worked for Quincy’s sales team for almost 10 years before he was let go in 2018. Another former Prevagen salesman, Shawn Andrus, said that he joined Quincy in 2012 with little sales experience. “Most of us were in our early twenties and all we cared about was paying our bills,” he said.

The money was good, Andrus said, as long as you made a lot of calls. The team worked on commission, with employees receiving a cut of every successful sale. The system, as Andrus described it, could encourage aggressive product promotion. The more Prevagen someone sold, the more money they made, and Andrus said he was good at selling customers on the company’s bigger packages. “A lot of my sales would be the 6-12 bottles at a time,” Andrus said. “There wasn’t any free time whatsoever. You were just dialing until basically your fingers bled.”

A spokesperson for Quincy said that the company never encouraged its sales team to pressure customers to purchase as many bottles of Prevagen as they could. “Customers often purchased multiple bottles at a time in order to reduce the cost of shipping or to ensure that they had an adequate supply of Prevagen on hand,” the spokesperson added.

Despite what he remembers as a sometimes stressful working environment, Andrus said he enjoyed his time at Quincy. He was sorry to be let go in 2015, along with his other colleagues on the sales team. Chavez said something similar. He believed that Underwood “had good intentions” with Prevagen.

That belief was bolstered by the studies the company had started conducting on the ingredient in Prevagen. Quincy used the results of one study, called the Madison Memory Study, in advertisements and packaging to claim that Prevagen was clinically shown to improve memory within 90 days. Chavez capitalized on that information in some of his pitches, too, to persuade people to purchase more product, he said. “Ten milligrams shows improvement after, you know, 30 days, but even more after 90 days, so that’s why you need a three months’ supply,” Chavez remembers telling potential customers on the line. “If you buy the extra strength, that’s just going to help you even faster.”