the bone piece (bottoms): the wax piece may be marketed as a growth tonic for children, the blood piece supposedly for joint and bone health, and the bone piece supposedly for calcium deficiency and geriatric needs. Early commercial activity in Russia between the 1930s and 1980s led to the production of an alcohol extract from deer antler velvet marketed under the Russian drug trade name Pantocrin (also pantocrine or pantokrin). In the West, velvet antler is dried, powdered, and consumed in encapsulated form or via aqueous alcohol extract as a dietary supplement, for which it is monitored for potential manufacturing and advertising violations by the US Food and Drug Administration and the Federal Trade Commission. A review published in 2012 summarized results from clinical research, including three studies on sports performance: "Claims that velvet antler supplements have beneficial effects for any human condition are not supported by sound clinical data from human trials." Marketing and FDA warning letters Companies attributing health claims from using dietary supplements of velvet antler have received warning letters from the US Food and Drug Administration (FDA) concerning the sale of encapsulated powders connected to their marketing claims. The claims were in violation of the United States Food, Drug and Cosmetic Act [21 USC/321 (g)(1)][36] because they "establish the product as a drug intended for use in the cure, mitigation, treatment, or prevention of disease" when velvet antler has no such scientific evaluation. Additionally stated by the FDA, velvet antler was "not generally recognized as safe and effective for the referenced conditions" and therefore must be treated as a "new drug" under Section 21(p) of the Act. New drugs may not be legally marketed in the United States without prior approval of the FDA. As of 2018, it is legal to sell velvet antler powder, extract or spray in the U.S. as a dietary supplement as long as no disease treatment claims are made and the label bears the FDA disclaimer: "This product has not been evaluated by the FDA. It is not intended to diagnose, treat, cure or prevent any disease." Deer antler spray Velvet antler in the form of deer antler spray has been at the center of multiple controversies with professional sports leagues and famous athletes allegedly using it for injury recovery and performance enhancement purposes. In mid-2011 a National Football League (NFL) player successfully sued a deer antler velvet spray manufacturer for