In addition to diet, there are many other things you can also do related to lifestyle, such as stress management through mindfulness (8) or gentle movement such as pre or post natal yoga (9), which have both shown to be incredibly helpful in encouraging mental wellbeing. If you feel you need extra support, personalised nutritional therapy can be very helpful as there can often be other drivers such as nutrient deficiencies and digestive complaints that can play a significant role in mental health and will need to be addressed in a way that is tailored to the individual. 
All of the coefficients are positive, as one would hope, and one specific factor (MR7) squeaks in at d=0.34 (p=0.05). The graph is much less impressive than the graph for just MP, suggesting that the correlation may be spread out over a lot of factors, the current dataset isn’t doing a good job of capturing the effect compared to the MP self-rating, or it really was a placebo effect:
The bitter reality of life is that there’s no organ of our body, which can defy the effects of aging with success. At least not entirely on its own. That’s why we need supplements in the first place. Remember? That’s only the beginning of the bad news for your brain. Certain sections of our brain, especially prefrontal cortex and hippocampus, can be seriously reduced in size as you are getting older. In addition, the number of capillaries in your head reduces, as well. Let’s not forget the arteries that become narrower and therefore limit the blood flow.
The truth is that, almost 20 years ago when my brain was failing and I was fat and tired, I did not know to follow this advice. I bought $1000 worth of smart drugs from Europe, took them all at once out of desperation, and got enough cognitive function to save my career and tackle my metabolic problems. With the information we have now, you don’t need to do that. Please learn from my mistakes!
I tried taking whole pills at 1 and 3 AM. I felt kind of bushed at 9 AM after all the reading, and the 50 minute nap didn’t help much - I was sleep only around 10 minutes and spent most of it thinking or meditation. Just as well the 3D driver is still broken; I doubt the scores would be reasonable. Began to perk up again past 10 AM, then felt more bushed at 1 PM, and so on throughout the day; kind of gave up and began watching & finishing anime (Amagami and Voices of a Distant Star) for the rest of the day with occasional reading breaks (eg. to start James C. Scotts Seeing Like A State, which is as described so far). As expected from the low quality of the day, the recovery sleep was bigger than before: a full 10 hours rather than 9:40; the next day, I slept a normal 8:50, and the following day ~8:20 (woken up early); 10:20 (slept in); 8:44; 8:18 (▁▇▁▁). It will be interesting to see whether my excess sleep remains in the hour range for ’good modafinil nights and two hours for bad modafinil nights.
I started with the 10g of Vitality Enhanced Blend, a sort of tan dust. Used 2 little-spoonfuls (dust tastes a fair bit like green/oolong tea dust) into the tea mug and then some boiling water. A minute of steeping and… bleh. Tastes sort of musty and sour. (I see why people recommended sweetening it with honey.) The effects? While I might’ve been more motivated - I hadn’t had caffeine that day and was a tad under the weather, a feeling which seemed to go away perhaps half an hour after starting - I can’t say I experienced any nausea or very noticeable effects. (At least the flavor is no longer quite so offensive.)
It all comes down to my personal investigation and exploration into how one can use a variety of compounds to enhance the mind, all while combining ancestral wisdom and herbs such as bacopa and gingko with modern science and tactics such as LSD and racetams. The fact is, I’ve taken a deep dive in the wonderful world of smart drugs, nootropics and psychedelics, and have had the opportunity to interview some of the brightest minds in this unique field of brain enhancement on my podcast. So in this article, I’ll spill the beans on it all, including how to navigate the oft-confusing world of smart drugs and nootropics, the best brain supplement stacks I’ve discovered and experimented with, how to procure and microdose psychedelics and much more.
at first impression it took a while to kick in... then a burst of creativity... after 15 days of taking it, I noticed a plateau affect... I kept taking it... took the two daily in one dose and I noticed I was very awake but lacked the initiative to do anything, I noticed an increase in libido which kind of sucked because I'm single but that boost of creativity that was experienced the firs couple of days was not there... I don't know if it has to do with the fact that I skipped a couple of days. I still have maybe like 10 doses left... I purchased a bottle of Accellerin and I noticed that it's the same bottle with the same lettering... is this a newer version of Addium? Anyway, I'm going to keep on taking the product to finish the bottle and I'll give a second review within the next 15 days.
Dr Hart explained how communication between the gut and the brain is controlled via our immune system, our endocrine system (hormones) and our central nervous system, which are all under the influence of the bacteria in our gut. The types and amount of these bacteria, known as our gut microbiome, can be directly impacted by factors such as diet, stress, pollution and medications (2) and the composition of the microbiome is also understood to affect one’s susceptibility to food sensitivities and intolerances (3).  
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Over the years, science has looked into the validity of this date being the most blue of all dates, however there is little evidence to prove this. There is some research that suggests how weekends are a time when people generally feel happier and less anxious, mostly for those that work full-time Monday-Friday, however there is little difference with subjective mood for other days of the week. Some charities such as MIND, have even said that Blue Monday, which is used mainly as a marketing tool to sell products and stories, can also be dangerously misleading and have even set up the hashtag #BlueAnyDay to help dispel the myth of this date.The idea that as a population we are more likely to feel down on the third of fourth Monday of the year can not only trivialise depression as a medical illness that can be life threatening but can also affect those that live with depression and know too well that feelings associated to this illness are not dictated by a single date in the diary.
[…] The verdict is out on brain health and aging. Scientists now know that memory loss and cognitive decline are not an inevitable part of growing older. In fact, the research proves quite the contrary. You can keep your mind sharp well into old age with a strategy that combines a healthy, active lifestyle with a brain-protecting diet and brain-boosting supplements. […]
Our top recommendation for cognitive energy enhancement is Brainol. This product is formulated from all natural ingredients. Brainol is a product that works internally. This herbal blend contains 19 key ingredients such as Huperzine A, L-Tyrosine, L-Theanine, St. John’s Wort, Phosphatidylserine, Bacopa Monnieri and Guarana, to name but a few. There are no unwanted side effects from these all natural ingredients.

The chemicals he takes, dubbed nootropics from the Greek “noos” for “mind”, are intended to safely improve cognitive functioning. They must not be harmful, have significant side-effects or be addictive. That means well-known “smart drugs” such as the prescription-only stimulants Adderall and Ritalin, popular with swotting university students, are out. What’s left under the nootropic umbrella is a dizzying array of over-the-counter supplements, prescription drugs and unclassified research chemicals, some of which are being trialled in older people with fading cognition.


…Phenethylamine is intrinsically a stimulant, although it doesn’t last long enough to express this property. In other words, it is rapidly and completely destroyed in the human body. It is only when a number of substituent groups are placed here or there on the molecule that this metabolic fate is avoided and pharmacological activity becomes apparent.
Attention Deficit and Hyperactivity Disorder (ADHD) is a condition that relates to a collection of behavioural symptoms such as hyperactivity, impulsiveness and inattentiveness. It is most commonly diagnosed in childhood between the ages of 6 and 12 when disruptive behaviour begins to show, however, due to a growing awareness of the condition, it is also becoming common among adults. According to the thinktank Demos, the cost of undiagnosed ADHD in adults in the UK who are unable to work or hold down a full-time job are estimated to cost billions of pounds to the nation. They warn that too many may be going through life struggling, unable to access the support ot diagnosis they need, which means there could be a huge amount of wasted talent.

Factor analysis. The strategy: read in the data, drop unnecessary data, impute missing variables (data is too heterogeneous and collected starting at varying intervals to be clean), estimate how many factors would fit best, factor analyze, pick the ones which look like they match best my ideas of what productive is, extract per-day estimates, and finally regress LLLT usage on the selected factors to look for increases.
Ampakines bind to AMPARs to block uptake of glutamate, thereby increasing synaptic responses, and this has indeed been shown to minimize the effects of conditions such as Alzheimer’s. Ampakines are also being studied as possible treatments for schizophrenia, depression, ADHD and more. But there is a huge risk associated with ampakine consumption. They are now tightly regulated because if you exceed a safe dosage, you will begin to suffer neuronal damage from glutamate toxicity, which leads to some of the very conditions that ampakines are thought to attenuate. Ampakine consumption can also lead to a decrease in long-term synaptic depression (LTD), a process by which specific synapses (the space between neurons across which information is sent) are intentionally weakened in order to avoid a plateau in the efficiency of your synapses. In other words, it allows your neurons and their connections to continue growing in efficiency. LTD is believed to be necessary for healthy synaptic plasticity (the adaptability of synapses), memory function and motor skills. To be honest, there is debate over whether cognitive functions like motor learning are truly dependent upon LTD, but it is possible that if you were to take a higher-than-recommended dose of an ampakine, the overstimulation that would result may lead to suppressed LTD and consequently to poor memory and motor function.

But how to blind myself? I used my pill maker to make 9 OO pills of piracetam mix, and then 9 OO pills of piracetam mix+the Adderall, then I put them in a baggy. The idea is that I can blind myself as to what pill I am taking that day since at the end of the day, I can just look in the baggy and see whether a placebo or Adderall pill is missing: the big capsules are transparent so I can see whether there is a crushed-up blue Adderall in the end or not. If there are fewer Adderall than placebo, I took an Adderall, and vice-versa. Now, since I am checking at the end of each day, I also need to remove or add the opposite pill to maintain the ratio and make it easy to check the next day; more importantly I need to replace or remove a pill, because otherwise the odds will be skewed and I will know how they are skewed. (Imagine I started with 4 Adderalls and 4 placebos, and then 3 days in a row I draw placebos but I don’t add or remove any pills; the next day, because most of the placebos have been used up, there’s only a small chance I will get a placebo…)
She speaks from professional and personal experience. When she first moved to the United States from Italy at age 24 she was struck by how shifting from the Mediterranean-style diet she grew up on to a standard American diet negatively impacted her physical health and work performance. The experience led her to more closely study nutrition and the link between diet and brain health. In this excerpt from a longer interview, she discusses the brain foods you should be eating.
Our current natural brain health formula contains Cordyceps-Sinensis Extract as well as the complete balance of brain health supporting nutrients that work perfectly together to help your body elevate essential acetylcholine levels while increasing the neurological components (neurotransmitters) needed to help you stay alert, focused, mentally driven and calm.
2ml is supposed to translate to 24mg, which is a big dose. I do not believe any of the commercial patches go much past that. I asked Wedrifid, whose notes inspired my initial interest, and he was taking perhaps 2-4mg, and expressed astonishment that I might be taking 24mg. (2mg is in line with what I am told by another person - that 2mg was so much that they actually felt a little sick. On the other hand, in one study, the subjects could not reliably distinguish between 1mg and placebo25.) 24mg is particularly troubling in that I weigh ~68kg, and nicotine poisoning and the nicotine LD50 start, for me, at around 68mg of nicotine. (I reflected that the entire jar could be a useful murder weapon, although nicotine presumably would be caught in an autopsy’s toxicology screen; I later learned nicotine was an infamous weapon in the 1800s before any test was developed. It doesn’t seem used anymore, but there are still fatal accidents due to dissolved nicotine.) The upper end of the range, 10mg/kg or 680mg for me, is calculated based on experienced smokers. Something is wrong here - I can’t see why I would have nicotine tolerance comparable to a hardened smoker, inasmuch as my maximum prior exposure was second-hand smoke once in a blue moon. More likely is that either the syringe is misleading me or the seller NicVape sold me something more dilute than 12mg/ml. (I am sure that it’s not simply plain water; when I mix the drops with regular water, I can feel the propylene glycol burning as it goes down.) I would rather not accuse an established and apparently well-liked supplier of fraud, nor would I like to simply shrug and say I have a mysterious tolerance and must experiment with doses closer to the LD50, so the most likely problem is a problem with the syringe. The next day I altered the procedure to sucking up 8ml, squirting out enough fluid to move the meniscus down to 7ml, and then ejecting the rest back into the container. The result was another mild clean stimulation comparable to the previous 1ml days. The next step is to try a completely different measuring device, which doesn’t change either.
Cost-wise, the gum itself (~$5) is an irrelevant sunk cost and the DNB something I ought to be doing anyway. If the results are negative (which I’ll define as d<0.2), I may well drop nicotine entirely since I have no reason to expect other forms (patches) or higher doses (2mg+) to create new benefits. This would save me an annual expense of ~$40 with a net present value of <820 ($); even if we count the time-value of the 20 minutes for the 5 DNB rounds over 48 days (0.2 \times 48 \times 7.25 = 70), it’s still a clear profit to run a convincing experiment.

Between midnight and 1:36 AM, I do four rounds of n-back: 50/39/30/55%. I then take 1/4th of the pill and have some tea. At roughly 1:30 AM, AngryParsley linked a SF anthology/novel, Fine Structure, which sucked me in for the next 3-4 hours until I finally finished the whole thing. At 5:20 AM, circumstances forced me to go to bed, still having only taken 1/4th of the pill and that determines this particular experiment of sleep; I quickly do some n-back: 29/20/20/54/42. I fall asleep in 13 minutes and sleep for 2:48, for a ZQ of 28 (a full night being ~100). I did not notice anything from that possible modafinil+caffeine interaction. Subjectively upon awakening: I don’t feel great, but I don’t feel like 2-3 hours of sleep either. N-back at 10 AM after breakfast: 25/54/44/38/33. These are not very impressive, but seem normal despite taking the last armodafinil ~9 hours ago; perhaps the 3 hours were enough. Later that day, at 11:30 PM (just before bed): 26/56/47.


These are the most highly studied ingredients and must be combined together to achieve effective results. If any one ingredient is missing in the formula, you may not get the full cognitive benefits of the pill. It is important to go with a company that has these critical ingredients as well as a complete array of supporting ingredients to improve their absorption and effectiveness. Anything less than the correct mix will not work effectively.
Absorption of nicotine across biological membranes depends on pH. Nicotine is a weak base with a pKa of 8.0 (Fowler, 1954). In its ionized state, such as in acidic environments, nicotine does not rapidly cross membranes…About 80 to 90% of inhaled nicotine is absorbed during smoking as assessed using C14-nicotine (Armitage et al., 1975). The efficacy of absorption of nicotine from environmental smoke in nonsmoking women has been measured to be 60 to 80% (Iwase et al., 1991)…The various formulations of nicotine replacement therapy (NRT), such as nicotine gum, transdermal patch, nasal spray, inhaler, sublingual tablets, and lozenges, are buffered to alkaline pH to facilitate the absorption of nicotine through cell membranes. Absorption of nicotine from all NRTs is slower and the increase in nicotine blood levels more gradual than from smoking (Table 1). This slow increase in blood and especially brain levels results in low abuse liability of NRTs (Henningfield and Keenan, 1993; West et al., 2000). Only nasal spray provides a rapid delivery of nicotine that is closer to the rate of nicotine delivery achieved with smoking (Sutherland et al., 1992; Gourlay and Benowitz, 1997; Guthrie et al., 1999). The absolute dose of nicotine absorbed systemically from nicotine gum is much less than the nicotine content of the gum, in part, because considerable nicotine is swallowed with subsequent first-pass metabolism (Benowitz et al., 1987). Some nicotine is also retained in chewed gum. A portion of the nicotine dose is swallowed and subjected to first-pass metabolism when using other NRTs, inhaler, sublingual tablets, nasal spray, and lozenges (Johansson et al., 1991; Bergstrom et al., 1995; Lunell et al., 1996; Molander and Lunell, 2001; Choi et al., 2003). Bioavailability for these products with absorption mainly through the mucosa of the oral cavity and a considerable swallowed portion is about 50 to 80% (Table 1)…Nicotine is poorly absorbed from the stomach because it is protonated (ionized) in the acidic gastric fluid, but is well absorbed in the small intestine, which has a more alkaline pH and a large surface area. Following the administration of nicotine capsules or nicotine in solution, peak concentrations are reached in about 1 h (Benowitz et al., 1991; Zins et al., 1997; Dempsey et al., 2004). The oral bioavailability of nicotine is about 20 to 45% (Benowitz et al., 1991; Compton et al., 1997; Zins et al., 1997). Oral bioavailability is incomplete because of the hepatic first-pass metabolism. Also the bioavailability after colonic (enema) administration of nicotine (examined as a potential therapy for ulcerative colitis) is low, around 15 to 25%, presumably due to hepatic first-pass metabolism (Zins et al., 1997). Cotinine is much more polar than nicotine, is metabolized more slowly, and undergoes little, if any, first-pass metabolism after oral dosing (Benowitz et al., 1983b; De Schepper et al., 1987; Zevin et al., 1997).
Hunters will go to great lengths to gain an edge over their prey. You never know where the margin between success and failure may lie, so you wake up extra early, say a prayer, spray bottled deer piss on your boots, and do whatever else you think might increase your odds. My schedule recently got more demanding thanks to a new baby. With less time to kill and another mouth to feed, I've had to step up my game.
Does little alone, but absolutely necessary in conjunction with piracetam. (Bought from Smart Powders.) When turning my 3kg of piracetam into pills, I decided to avoid the fishy-smelling choline and go with 500g of DMAE (Examine.com); it seemed to work well when I used it before with oxiracetam & piracetam, since I had no piracetam headaches, and be considerably less bulky.

Microdosing with Ketamine: Ketamine is a general anesthetic that is most commonly used on animals but ironically was originally devised for and tested on humans. Users of ketamine have claimed increased compassion and sensitivity to others, an increase in joy of life, and a reduced fear around death. Finding your ideal microdose of ketamine can be tricky, so it is important to start just a bit below the recommended doses. Taking ketamine sublingually (under the tongue) is the most effective and direct route of administration, and a sublingual microdose is about .75 milligrams per kilogram of body weight, although you can get a significant mood enhancement with as little as 0.2 milligrams per kilogram of body weight. I’d recommend that you never mix ketamine with any drugs that depress breathing such as alcohol, opioids, and tramadol, as it is an extremely calming agent that can produce a heavy sedative effect if you’re not careful or if you combine it with other sedative-like compounds. I’ve found a microdose of ketamine to be best combined with a trip to a float tank, or any other environment that involves sensory deprivation and introspection.
Adderall is composed of a mixture of amphetamine salts – chemical compounds that have numerous potentially positive effects, including increased concentration, awareness and alertness. Amphetamines work, in part, by causing the release of dopamine, a neurotransmitter associated with pleasurable activities like eating. However, an amphetamine-induced release of dopamine occurs automatically – no pleasurable activity needs to occur – but a come-down feeling will likely be experienced eventually, which is associated with feelings of lethargy and mental dullness. Due to this side effect, Adderall cannot be said to be a nootropic.[12]
Our #5 pick is BriteSmart which has a long list of ingredients, which look good on the bottle, but when we actually visited each one, we were left wondering about why some of them had been included. We did like the fact that it contained Vinpocetine and Huperzine A. We felt that this was a good product, but missing some key ingredients such as a supportive vitamin blend.

Since my experiment had a number of flaws (non-blind, varying doses at varying times of day), I wound up doing a second better experiment using blind standardized smaller doses in the morning. The negative effect was much smaller, but there was still no mood/productivity benefit. Having used up my first batch of potassium citrate in these 2 experiments, I will not be ordering again since it clearly doesn’t work for me.
Apart from the risks that accompany drugs with dopaminergic effects, amphetamines, even when used to treat neurological disorders like ADHD, have been known to frequently and predictably cause anorexia, weight loss and insomnia. High doses can cause psychotic behavior, and even normal doses have been known to produce psychosis that ranged from the loss of short-term memory to horrific visual and auditory hallucinations. Are you getting the impression that using synthetic stimulants to flood your brain short-term with excessive or unnaturally high levels of hormones and neurotransmitters may not be a good idea, especially when done frequently or in excess?
So with these 8 results in hand, what do I think? Roughly, I was right 5 of the days and wrong 3 of them. If not for the sleep effect on #4, which is - in a way - cheating (one hopes to detect modafinil due to good effects), the ratio would be 5:4 which is awfully close to a coin-flip. Indeed, a scoring rule ranks my performance at almost identical to a coin flip: -5.49 vs -5.5420. (The bright side is that I didn’t do worse than a coin flip: I was at least calibrated.)
Aside from the obvious pleasure some derive from this traditional combo, are there any actual benefits to simultaneously smoking and drinking coffee? One study in the Journal of Epidemiology and Community Health definitely concludes that the answer is yes. In the study, researchers analyzed 497 men and women with confirmed cases of papilloma, carcinoma and polyps of the bladder. All study participants, along with 1,113 control cases, were interviewed to determine the use of tobacco, exposure to secondhand smoke and coffee drinking.
For the moment, people looking for that particular quick fix have a limited choice of meds. But given the amount of money and research hours being spent on developing drugs to treat cognitive decline, Provigil and Adderall are likely to be joined by a bigger pharmacopoeia. Among the drugs in the pipeline are ampakines, which target a type of glutamate receptor in the brain; it is hoped that they may stem the memory loss associated with diseases like Alzheimer's. But ampakines may also give healthy people a palpable cognitive boost. A 2007 study of 16 healthy elderly volunteers found that 500mg of one particular ampakine "unequivocally" improved short-term memory, though it appeared to detract from episodic memory - the recall of past events. Another class of drugs, cholinesterase inhibitors, which are already being used with some success to treat Alzheimer's patients, have also shown promise as neuroenhancers. In one study the drug donepezil strengthened the performance of pilots on flight simulators; in another, of 30 healthy young male volunteers, it improved verbal and visual episodic memory. Several pharmaceutical companies are working on drugs that target nicotine receptors in the brain in the hope that they can replicate the cognitive uptick that smokers get from cigarettes.
Thanks to its carefully-selected and totally harmless natural ingredients, you can deal with stressful situations more efficiently and overcome them easier. We are exposed to stress from diverse sources, such as family, school or work. If you feel that you constantly lack the energy to get your things done, then you can freely blame it on stress. Brain Pill helps you get rid of brain fog that limits your productivity and alertness levels.
Finally, it’s not clear that caffeine results in performance gains after long-term use; homeostasis/tolerance is a concern for all stimulants, but especially for caffeine. It is plausible that all caffeine consumption does for the long-term chronic user is restore performance to baseline. (Imagine someone waking up and drinking coffee, and their performance improves - well, so would the performance of a non-addict who is also slowly waking up!) See for example, James & Rogers 2005, Sigmon et al 2009, and Rogers et al 2010. A cross-section of thousands of participants in the Cambridge brain-training study found caffeine intake showed negligible effect sizes for mean and component scores (participants were not told to use caffeine, but the training was recreational & difficult, so one expects some difference).
Specifically, the film is completely unintelligible if you had not read the book. The best I can say for it is that it delivers the action and events one expects in the right order and with basic competence, but its artistic merits are few. It seems generally devoid of the imagination and visual flights of fancy that animated movies 1 and 3 especially (although Mike Darwin disagrees), copping out on standard imagery like a Star Wars-style force field over Hogwarts Castle, or luminescent white fog when Harry was dead and in his head; I was deeply disappointed to not see any sights that struck me as novel and new. (For example, the aforementioned dead scene could have been done in so many interesting ways, like why not show Harry & Dumbledore in a bustling King’s Cross shot in bright sharp detail, but with not a single person in sight and all the luggage and equipment animatedly moving purposefully on their own?) The ending in particular boggles me. I actually turned to the person next to me and asked them whether that really was the climax and Voldemort was dead, his death was so little dwelt upon or laden with significance (despite a musical score that beat you over the head about everything else). In the book, I remember it feeling like a climactic scene, with everyone watching and little speeches explaining why Voldemort was about to be defeated, and a suitable victory celebration; I read in the paper the next day a quote from the director or screenwriter who said one scene was cut because Voldemort would not talk but simply try to efficiently kill Harry. (This is presumably the explanation for the incredible anti-climax. Hopefully.) I was dumbfounded by the depths of dishonesty or delusion or disregard: Voldemort not only does that in Deathly Hallows multiple times, he does it every time he deals with Harry, exactly as the classic villains (he is numbered among) always do! How was it possible for this man to read the books many times, as he must have, and still say such a thing?↩
Discussions of PEA mention that it’s almost useless without a MAOI to pave the way; hence, when I decided to get deprenyl and noticed that deprenyl is a MAOI, I decided to also give PEA a second chance in conjunction with deprenyl. Unfortunately, in part due to my own shenanigans, Nubrain canceled the deprenyl order and so I have 20g of PEA sitting around. Well, it’ll keep until such time as I do get a MAOI.
Not all drug users are searching for a chemical escape hatch. A newer and increasingly normalized drug culture is all about heightening one’s current relationship to reality—whether at work or school—by boosting the brain’s ability to think under stress, stay alert and productive for long hours, and keep track of large amounts of information. In the name of becoming sharper traders, medical interns, or coders, people are taking pills typically prescribed for conditions including ADHD, narcolepsy, and Alzheimer’s. Others down “stacks” of special “nootropic” supplements.
According to the US Food and Drug Administration, "Piracetam is not a vitamin, mineral, amino acid, herb or other botanical, or dietary substance for use by man to supplement the diet by increasing the total dietary intake. Further, piracetam is not a concentrate, metabolite, constituent, extract or combination of any such dietary ingredient. [...] Accordingly, these products are drugs, under section 201(g)(1)(C) of the Act, 21 U.S.C. § 321(g)(1)(C), because they are not foods and they are intended to affect the structure or any function of the body. Moreover, these products are new drugs as defined by section 201(p) of the Act, 21 U.S.C. § 321(p), because they are not generally recognized as safe and effective for use under the conditions prescribed, recommended, or suggested in their labeling."[33]
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