Monetizing the COVID-19 Backlash—Big Vision, Palpable Demand, But Can They Pull it Off?

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% 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% 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.

For example, remember the ICAM protocol TrialSite reported on? Early on in the pandemic, a pharmacist at a southern U.S. health system came up with a cocktail of repurposed drugs including blood thinners and steroids which saved many lives during the summer of 2020.  What did this African American pharmacist get for improvising, innovating and ultimately saving lives before any vaccine was available? Termination. As TrialSite reported, the health system’s contract with Pfizer to test the vaccine forbade it from such real-world endeavors.

Coulson, like many of us during the pandemic, witnessed what certainly looked like a captured health system—one controlled by money and power, and importantly, a particular ideology driven industry. Politics and information warfare emerged alongside conflicting interpretations of the science. Social media became battlegrounds.

His chance encounter with Zelenko in South America, the unfolding battles for medical freedom during COVID-19, including the emergence of front line physicians such as McCullough or the Front Line COVID-19 Critical Care Alliance all were inspirational, and pointed to a large nascent market, informing a business plan that would help these doctors via a parallel business to offer up alternative pathways for health., including the use of repurposed drugs, such as hydroxychloroquine, zinc, azithromycin, ivermectin and other supplements and antibiotics.

“De-prescribe from Big Pharma”

TrialSite believes Coulson’s entry into alternative health supplements was authentically driven by a certain level of disgust in how the health system and government responded to the pandemic. Coulson, then joined by colleague Lopez, sought to establish a business model that would help individuals also fed up “de-prescribe from Big Pharma once and for all.”

Front line physicians from Dr. Peter McCullough and several others were identified as a medical board for this alternative healthcare company.  At least two of the original founding physicians have recently departed TWC on short notice. Today, the TWC medical board today consists of:

The group has a Canadian board as well including a Dr. William Makis, M.D., Chief of Nuclear Medicine and Oncology who uses Substack and X in daily laments regarding deaths linked to the COVID-19 vaccines, as well as to claim that the incidence of turbo cancer is on the rise. The turbo cancers linked to COVID-19 vaccines is by no means proven, although folks have hypotheses. 

What’s a role of a Chief Medical Board?

Just how active members of a chief medical board should be on social media raises some profound questions for TMC.  On the one hand, Coulson’s vision is one of a parallel health system, or at least a company not tethered to the current rules, meaning independence to remain both responsive to patients and supportive of doctors.

And while generating lots of chatter and buzz on social media may be linked to supplement sales, credibility comes mostly with quality and patient centricity, and most importantly over time measurable patient outcomes.

Consequently, TrialSite’s Daniel O’Connor mentioned to CEO Gillooly that TWC may consider establishing some policies and procedures governing how its promoters operate online, what’s acceptable language or verbiage for promotions, and the like. The TWC CEO completely understood, explaining, “We are growing so fast so it’s hard to keep up. But we are cognizant of the need to strike a balance and ensure any messaging is appropriate.”

In the interaction between TrialSite’s Daniel O’Connor and TWC’s Peter Gillooly, the two discussed questions centering on quality systems, independent certifications of potency, purity and lack of adulteration, TWC’s supply chain, labeling compliance and financial disclosures, especially now that Coulson bought into a media venture that’s already advertising for TWC in critical purportedly unbiased articles.

On the social media advocacy and promotion, TWC’s CEO confided their interest in monitoring carefully for inappropriate activity. For example, some websites border on extreme fringe as the Mother Jones piece pointed out, such as controversial live-streamers Stew Peters, producer of “Died Suddenly” given he in the past offered a discount code for TWC, as do many of the alternative anti-COVID narrative podcasters and Substack blogs.

A challenge TWC faces is that at least some aspects of the market they must tap into could ultimately undo all that they hope to build.  For example, some of the more extreme and politically controversial alternative media channels which TWC has chosen to tap into and monetize could compromise the broader TWC brand.   

But Gillooly was responsive and transparent on the topic.  He mentioned for example, that TWC cut ties with Stew Peters due to his increasing pattern of way far out their fringe and antisemitic rants. Peters and his ilk will only become more radicalized, not a great brand look for any aspiring startup, let alone one trying to build an alternative health system.  And the TWC made it clear to TrialSite that they won’t tolerate fringe or hate speech in any way connected to their brand.

Better Safe than Sorry

The supplements business is a tough one, with substantial costs, supply chain and quality concerns, continuous need for investment in quality management and traditionally slim margins. Moreover, already copy cats are targeting TWC such as Wellness Warriors LLC which offer, not surprisingly, yet another “Spike Protein Detox System.” 

Undoubtedly, more will seek to enter the market, as the barriers to competition which TWC has erected aren’t that high other than the marketing channel Coulson has developed and the scientific/medical board backing him.

Enter their latest and what we hear about their fastest growing product line. With a tag line of “Don’t wait for the next emergency,” Med Kits come to the rescue. The TWC med kits are marketed online via sources like LinkedIn, the professional network as “Critical, Life-Saving Medications Every American Should Have on Hand (And the Foolproof Way to Get them Prescribed.”

In prompting their potential consumers to “Prepare for the unexpected with these life-saving medications,” TWC conjures up emergency disasters, from hurricanes to pandemics to with the aim of prompting activity leading to new customers.

O’Connor and Gillooly discussed possible labeling and legality issues associated with the TWC Prescription Medical Emergency Kit model. Touting eight critical medications every American should have on hand, while concurrently reminding the audience of the importance of TWC’s commitment to “medical freedom”, the “Prescription only Medical Emergency Kit “provides you with a carefully selected assortment of vital medications, preparing you for those unpredictable moments in life. Our kit ensures access to proven treatments, including Ivermectin, arming you with confidence in the face of unforeseen medical emergencies and resource shortages. Our kit also comes with the Medical Emergency Guidebook as an educational resource for safety.”

Ivermectin becomes an enticing word given the difficulty many have in accessing this prescription medicine off label. To enable access to pharmaceutical grade ivermectin for human use, TWC employs licensed physicians to prescribe via a telehealth platform. Gillooly shared with TrialSite that the company has invested in all of the necessary infrastructure, electronic medical record and documentation capability to ensure compliance with the various state licensing boards.

Importantly, designing real-world research would be a next level feature, one that could be transformative.

Regulatory Gray Area

TWC’s entry into the business of prescribing medicines opens up numerous challenges for a new, immature startup from a compliance standpoint.  Pharmaceutical companies employ great measures to ensure they do not run afoul of regulatory and/or legal requirements.  For example, the Medical Affairs division of a company exists to communicate scientific and clinical information to the medical community. Additional rules and workflows exist for any communication to patients. 

Now selling supplements direct to consumers falls under the exceptions to FDA regulation, but employing or contracting with prescribing physicians, marketing pharmaceuticals such as ivermectin likely subjects the company to direct FDA oversight if any claims are violative.

According to TrialSite’s O'Connor, when a company’s business model becomes ever more dependent on business involving prescribing FDA regulated medicines for future indications, TWC physicians will be prescribing medicines for an indication that doesn’t yet exist.

With growth comes increased costs and pressure to sell, and this model [anticipatory prescriptions] could evolve into one involving perverse incentives—to promulgate fear of emerging infectious diseases, which would then increase the probability of  consumers opting to pay for a prescription.” TrialSite’ O’Connor asked TWC CEO about company culture, and how they would avoid this sort of capitalist creep, the type that so many in the medical freedom movement are critical of big pharma for doing.

Gillooly became passionate at this point, explaining that they are building the company to empower patients, to offer a new model, one that honors their right to health care, to key medicines lie amoxicillin. That if guided correctly by a licensed prescribing physician following a Hippocratic oath that this culture will prevail as the company grows.

The TWC CEO understood explicitly that otherwise, and ironically the company could grow and morph into just another money-first hybrid healthcare and pharmaceutical operation. After all, did we not see during COVID how a confluence of state, industry and health systems sort of exploit and capitalize on fear?

O’Connor continued, “Should this prescription model become more central to TWC, their business will need to establish serious firewalls in their business activities involving supplements, FDA regulated pharmaceuticals (such as ivermectin), sales and marketing.” In the TWC’s defense, Gillooly totally got this point, emphasizing their rapid growth and their imminent hiring of the next wave of professionals to help them institute more refined, granular policies, procedures and the like.

Then there is the issue of quality. Today, TWC employs a repackaging and formulation model, then adding a premium on pricing, leveraging the demand drivers via the draw based on the top medical names backing the endeavor.

However, when the company also becomes a regulated healthcare company, and when a firm hires or contracts doctors to prescribe forward looking combination regimens in the form of commercial medical packages that includes prescription only drugs all under one roof, the game changes, and regulatory considerations become front and center.

TWC CEO emphasized that their outsourced manufacturing partners are U.S. based and presently ISO certified.

On the topic of quality, Gillooly told TrialSite’s Daniel O’Connor that they were working toward full Good Manufacturing Process (GmP), a very good move that will ensure they support compliance measures aligned with the FDA in production. The company’s CEO informed TrialSite that they should achieve GmP status by mid-2024. An important move, this demonstrates the executives at TWC are investing, planning to scale into a much bigger company—promising.  

“Touching more people’s lives…than any other firm….”

In his lengthy 2023 Annual Letter for TWC, Coulson offers that he reflects on 2023 “with pride” He notes his firms cover a spectrum of parallel economies and are “are touching more people’s lives in a tangible way than any other [firm] out there today.” A bold claim to say the least. But we can confirm TWC is the only one that we know of banking on a business model contrary to the current powers-that-be in U.S. healthcare. 

Coulson declares he does this by offering news, helping folks find connection, and finding “tomorrow’s cures” in a “fight for our freedoms and a better, brighter tomorrow.” He adds that, “TWC is also helping fuel the conservative freedom movement, a fact that I am EXTREMELY proud of.” He also crows that TWC is the biggest advertiser on “most conservative media outlets and news sites….” And there is evidence for some truth in this statement. One hears of TWC on many conservative podcasts such as the Rubin Report and many others from the mainstream to the fringe. Coulson says he is “a large shareholder in QU Biologics, which has pioneered and uncovered an immunological pathway, without Pharmaceuticals, to treat disease and cancers. It’s the future and it will change everything.” (Italics added.)  

As TrialSite shared previously, Coulson’s Integro Capital born during the pandemic represents his attempt to strike on his own and build a conglomerate of companies like his father did before him.

So, what are some of the other companies Foster made investments in?  We offer a brief overview next.

Site-Specific Immunomodulators

Coulson is certainly not an initial investor in QU Biologics. Since 2014, the self-described biotechnology company has raised tens of millions of dollars to help develop site-specific immunomodulators or SSIs. These are intended to restore the body's innate immune system to treat cancer. The idea here is the company mission purportedly is to transform the treatment and prevention of cancer and chronic inflammatory diseases by restoring normal immune function.

They are developing microbiome-like products such as QBECO SSI (derived from inactivated E coli targeting gastrointestinal tract and related origins) and other bacterial agents, pushing them through FDA-regulated clinical trials. QU Biologics has 6 studies registered in Clincialtials.gov with only one active but not recruiting. The study (NCT05421325) is attempting to get their QBKPN SSI experimental biochemistry through a Phase 2 clinical trial. Classification as a medication in, again, the class known as Site-Specific Immunomodulators or SSIs.

Nanobiosym

Coulson’s investment company also put money into Nanobiosym. It appears his partner, Dave Lopez assisted with the original relationship. A confusing company, Nanobiosym appears to be a sort of basic translational science research-based company focused on nanotechnology with testing services to augment their budget.

According to their website they were funded to “create breakthrough scientific insights and transformational technologies that emerge from the convergence of physics, nanotechnology and biomedicine.” A reminder, Coulson has gone on record in Wellness Company statements his investments such QU Biologics don’t use any form of “pharmaceutical”. Anita Goel, MD Ph.D., founded Nanobiosym. In her own words on LinkedIn, she “is a world-renowned expert and pioneer in the emerging field of Nano biophysics - a new science at the convergence of physics, nanotechnology, and biomedicine.”  While Coulson denies any links to pharmaceuticals, he clearly has links to biotechnology and the movement toward nanotechnology and nanomedicine.

Product line

From a basic science perspective, Dr. Goel appears sage-like, seeking to “expand conventional theoretical and experimental physics frameworks and their mathematical machinery to describe non-equilibrium, open systems such as life and living systems that are strongly coupled with their environment.” But what is Nanobiosym doing for research and how do they make money? 

Their website is fairly confusing, but they offer two service lines including Nanobiosym Testing Services purported to be a superior (e.g., more sensitive and accurate) PCR test compared to most typical antigen tests, enabling earlier detection of SARS-CoV-2, for example. The testing market for COVID-19 is inundated and given the loss of interest it’s not clear how lucrative this type of product may be.

Other products in the pipeline include the following:

Lobbying trail

Interestingly, Nanobiosym is linked to $90,000 in lobbying payments. According COVID Truth Initiative, Nanobiosym paid $90,000 in 2020 to Ballard Partners' Brian Ballard and Dan McFaul, to lobby the White House, the United States Department of Health and Human Services, and the Overseas Private Investment Corporation on issues related to health and pharmaceuticals. TrialSite could confirm the $90,000 but could not confirm the targets of the money. Importantly Ballard Partners is a major lobbyist serving large pharmaceutical companies, defense contractors, social networks, and big tech such as Google and Bayer Pharmaceuticals, the German pharma that acquired Monsanto. See the link. Interestingly, the Overseas Private Investment Corporation is part of the U.S federal government, Office of Inspector General, U.S. Agency for International Development. Why would this startup Nanobiosym give money to this agency of the U.S. government?  See link. To Coulson and Lopez’ defense, if anyone jumps to conclusions this lobbying occurred a year prior to IC LLC formation.  Peter Gillooly mentioned he was not privy to Foster’s other investments but claimed that there was a lot of ludicrous chatter on the internet that was all gibberish.

Dating site

Other investments Coulson has disclosed include Unjected, “a community platform for like-minded people.” Unjected is a dating site for individuals that opted not to receive the mRNA COVID-19 vaccines, which means a minority of the U.S. population. According to the website, Unjected “Is the world’s first platform for the unvaccinated.” Shelby Thomson and Health Pyle founded the site, an inspiration for the photographer, who says politics doesn't play a big role in the company's mission (even though most people against getting the COVID vaccine tend be conservatives or fall in vulnerable categories such as residents of poor rural areas, urban inner cities, etc.). The dating site was recently kicked off the App store, evidencing clear censorship among Apple, for example.

Opening or Controlling the news

Coulson’s anti-establishment empire building block must also of course include a media site.  Afterall, the media is power, and control the media, control the narrative.

Coulson bought his way into the new conservative leaning, and at times, it would appear even more fringe Vigilant News Network. What’s described as a free and open network to bring people the latest unmanipulated stories, of course news today becomes incredibly difficult, as much of the market demands news that reaffirms its tribal-like value systems. The demise of mainstream media, the formation of the Trusted News Initiative, overt censorship and the like propels the media business into full disruption. Unfortunately, one of the negative externalities becomes audiences that seek out their own echo chambers and not necessarily objective, unbiased forums.  TrialSite has learned this painfully firsthand.

TrialSite joined Robert Kennedy Jr. to sue the Trusted News Initiative not on the basis of free speech but on anti-trust violations. The premise: big media are rapidly losing viewers and readers, and thus have banded together to establish what the truth actually is and punish those upstarts taking away their viewers and readers.  They do this by feeding the social media intelligence as to who or what to censor, or block.

Enter the Vigilant Network, another in a series of conservative leaning outlets.

The new media site also runs a Substack, with a range of articles from relatively hard-hitting seemingly truthful fare to more speculative content that Alex Jones would appreciate.

They recently partnered with The Gateway Pundit, classified by Wikipedia as a “Far right fake news site,” for example. But to be fair—we saw what we here at TrialSite suspected was evidence of corrupt practices at Wikipedia itself during the pandemic!

Coulson investing in controlling a political right media site has its benefits and drawbacks.  TrialSite founder Daniel O’Connor told this writer, “Coulson is smart, has the pedigree for business based on his upbringing and likely believes at the core in what he says publicly, but the pressures of costs, investors and the realities of capitalism will undoubtedly enforce the same discipline on this groups of ventures as any others.”

When confronted with this logic, TWC CEO Gillooly explained to O’Connor that they have established strict firewalls, and that while they will buy advertising in the news network it would be violative to unduly influence the content.

 The entrepreneur also says he founded Vigilant News Network “as a free and open network to bring people the latest unmanipulated stories….”  But regardless,  given the need for continual growth, rising costs associated with what in essence will be a regulated company,  the pressures to exploit the firewalls will be significant.  Only company culture of integrity and ethics can minimize such concerns. And of course, that starts at the top and Gillooly did assure TrialSite “we are building a serious big company and we will not compromise on our ethics, integrity or our mission.”

Concluding thoughts

Trust in the U.S. government, healthcare systems and the medical products industry sunk to what are likely all-time lows during the pandemic. Enter TWC and Foster Coulson’s mission to capitalize on those trends to build what he and Peter Gillooly emphasize will be a new kind of patient-centric company, dedicated to medical freedom.

But the uptick in TWC’s advertisements on conservative-leaning podcasts, Substack authors, and the like is palpable. Products that claim to “clean” the spike protein are not proven, and despite an esteemed Chief Medical Board seemingly validating the integrity and scientific veracity backing the products, they are dietary supplements that cannot be marketed for treating any form of disease, including SARS-CoV-2, the virus behind COVID-19, long COVID or long Vax, also known as COVID-19 vaccine injury.  Of course, a physician at their discretion and patient consent can try different approaches to solve a medical problem.  TrialSite stood up for that right of both patient and doctor during the pandemic. But that model doesn’t scale well enterprise wide.

Importantly, for this last point, the medical establishment, including regulators and public health agencies to the most elite academic medical centers, do not recognize the spike protein hypothesis, that this antigen residual from the mRNA vaccine is the actual cause of vaccine injuries. As big as Foster’s vision is, it will be difficult to supplant the U.S. health system. He’ll have to adjust to its rules, laws, social mores and the like, not the other way around.  But his mission along with Peter Gillooly and their team is an important one. They most certainly should be supported, given a chance to try to shake up U.S. healthcare, it’s needed.

To the defense of doctors like Peter McCullough, his TWC colleagues and others, numerous peer-reviewed journals now discuss disclosure of spike protein distribution for periods of up to or even over a year. Representing yet another example of how the chasm between the unfolding science and official medical establishment narratives diverge, leading to increasing polarization, mistrust and even radicalization of the population.

And it’s the later dynamics that Coulson and Lopez have seized upon. Yes, a growing number of people demand an alternative health system. But in a market economy Coulson will need to be ready to plow all of his profits, and then some, back into actually demonstrating defensible efficacy before making claims, the true standard of any health-related brand, plus seriously invest in adherence to the compliance and regulatory regimes that currently govern healthcare delivery. Because that’s the world that he must now abide by.

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