Why would they be frightened by something as simple as filing a complaint with a consumer protection agency? Every state has one.
If you're asking why I haven't it's because my wife is an attorney who explained to me why it would be a waste of time. I explained it above but you choose to ignore it.
but as long as they stay away from making definitive statements of guaranteed success then they have CTA.
It's very hard to prove if it was easy as I said noone would need to wade through the homeopath meds in the drug store. Some of them have been sued and the homeopath drug makers win. Does that mean they work? It means it's almost impossible to prove intent which is required in civil lawsuits of fraudulent practices.