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Medvi is an AI-powered telehealth startup with two employees. It did $401 million in business last year, generated $65 million in profit, and is projected to do $1.8 billion in sales this year, according to a recent profile in the New York Times.

A key factor in Medvi’s growth has been the use of affiliate marketers. Matthew Gallagher, Medvi’s founder, told Business Insider in an email that “maybe 30%” of its advertising was through affiliates.

A review of Meta’s ad library showed that some of these affiliates have run ads that feature what appeared to be AI-generated content, including people described as doctors. The supposed doctors’ pages include posts suggesting the pages were formerly run by other people or businesses, and some of their photos include telltale signs of AI use, like garbled text.

As of Monday, at least six purported doctor pages were marketing Medvi’s weight-loss drugs and a product that claims to increase men’s sexual performance. One profile, “Dr. Matthew Anderson MD,” lists an Angolan phone number and appears to have previously belonged to a gospel musician. Another, “Dr. Spencer Langford MD,” features older posts and contact information corresponding to a clothing store in the Republic of Congo.

One Medvi marketer, “Wade Frazer MD,” dropped the “MD” after Business Insider asked about it. The same profile photo was used by three other pages that advertised Medvi.

On Friday, more than 5,000 active ad campaigns that mentioned or linked to Medvi were live, according to Meta’s ad library. By Monday, after Business Insider drew Gallagher’s attention to profiles with signs of AI use, including Gemini watermarks on profile photos and implausible situations like a realtor advertising weight-loss drugs, the number of ads fell to roughly 2,800.

“In line with the FTC, we have a clear policy of providing disclosure on any actor or AI portrayal of a doctor or not using them at all,” Gallagher told Business Insider on Friday, using the initials of the Federal Trade Commission. “If we find an affiliate doing this we work to take these ads down.”

None of the pages mentioned in this article included prominent disclosures when BI reviewed them.

Medvi was one of six telehealth companies named in a request for an investigation sent to the FTC in September by the National Consumers League and other organizations, according to Nancy Glick, the NCL’s director of food, nutrition, and obesity.

In her view, Medvi’s use of terms on its website like “trusted by experts” and “doctor-approved” has confused consumers about the safety testing of the compounded drugs it sells.

“What Medvi is doing violates the FTC Act,” Glick told Business Insider. With so many companies selling compounded drugs online, she said, “it’s like playing a game of whack-a-mole.”

The FTC has said that advertisers must have “reasonable programs” in place to oversee their affiliates, and specifically flagged health-related marketing as an area that “may require more supervision” than lower-risk areas like fashion.

Gallagher didn’t respond to questions about whether and how his company monitored its affiliates.

The FDA sent a letter in February warning that representations at medvi.io were “false or misleading” because of comparisons to FDA-approved drugs like Wegovy and images suggesting that Medvi itself compounded the drugs it sells.

While the FDA letter was addressed to Gallagher’s company, he said the website mentioned in the letter, medvi.io, was operated by an affiliate marketer he declined to name. Medvi’s website is medvi.org. He said the marketer used his company name in the URL without permission, took the website down, and responded to the FDA.

Medvi has also been sued at least three times in the past 11 months by people who claim that the company and affiliate marketers it works with have violated spam laws by sending unsolicited texts and emails.

One of the suits was dropped, and two are pending.

“We have a strict ‘no spam’ policy and only text to opted-in recipients,” Gallagher said. “We investigate any claim of an affiliate not operating within this expectation and take action against it immediately.”

In a response to one of the lawsuits, Medvi said it “denies that it engaged in any illegal conduct in any jurisdiction.”

Medvi’s AI-powered marketing machine

The Times reported that Gallagher spent $20,000 on his first month of marketing and on AI software — including ChatGPT, Claude, and Grok — that he used to build the company, chat with customers, and populate its website with copy and images.

While Medvi now pays some human service providers for legal advice and accounting, the company’s website says that “certain materials” are AI-generated or enhanced, and Medvi disclaims any responsibility for the “accuracy, completeness, or reliability” of that content.

Medvi’s use of AI-generated marketing materials was previously written about in May by the news website Futurism.

Business Insider’s search of Meta’s Ad Library on Friday showed one ad that included videos of a woman injecting herself and tossing her hair in a mirror, with overlaid text saying a patient can get a prescription in five minutes.

“Just take the super quick quiz, they have like a 99% approval rate,” the video says.

One of the advertising accounts, “Dr. Amelia Rhodes,” included an image of the Johns Hopkins Hospital in Baltimore at the top of its page. No one by that name is listed in the Maryland Board of Physicians practitioner database or on the website of Johns Hopkins Medicine or Johns Hopkins University. Representatives for both institutions didn’t respond to comment requests.

The Rhodes ads were gone by Monday.

Telehealth in trouble

Since 2020, the telehealth industry has taken off, fueled by the COVID-19 pandemic and demand for GLP-1 weight-loss medications and ADHD treatments like Adderall.

As recently as 2024, the percentage of doctors seeing patients virtually was still nearly triple what it was before the pandemic, though growth in mail-order prescriptions has been stymied by skyrocketing costs.

Some telehealth companies have run into trouble. Mental health startup Cerebral paid millions of dollars to resolve a federal investigation into allegations of overprescribing in 2024. Years before, Business Insider reported on leaked documents and concerns by medical providers that Cerebral was pressuring them to prescribe medicines, including antipsychotics, that patients didn’t need.

The Federal Trade Commission also investigated Cerebral’s billing practices, and thousands of customers were eventually refunded.

The founder of Done, an Adderall-focused digital health company, was found guilty of health-care fraud conspiracy and distributing controlled substances last fall.

Many telehealth companies are marketing illegally, Glick believes.

“They really would need an army just to be able to find these offenders,” she said.