[Jag]

Update: We ended up going to our hearing on the issues at hand. We drew up a great case, had everything we needed to fight this ruling and citation. Well, the mistake we made is having my wife (who is an Attorney) send in the documents for arguments on her letterhead. When we showed up the Licensing Division had an Attorney for the State of Utah there to handle their side. (When in all the cases before us the investigator handled there own)
We argued over an hour and had a good case, long story but the Investigator even lied and was caught by us 3 different times and was scolded by the Judge for not having the facts right, but bottom line we lost. In fact the Judge for this Division is a hired Judge this is also an Attorney in Private practice (moonlighter) so he is paid for the State. He says it does fall under the Esthetician Licensing and must have Master Estheticians performing the service. He then went on to fine us $400.00 first offense, next time it doubles to $800.00. And he continued on staying we are now on a fine line with the Medical Licensing side as we claim it helps with Back Pain, Arthritis, Blood Circulation, even Insomnia and that if we used or promoted a device to do this then if fall into a Medical Licensing to treat these type of conditions. The Inspector then told me they would be down to visit on that issues soon. (As of yet they have not)

After all this, we end up trying to hire Master Estheticians which is hard to find as none want to work in a Tanning Center, we have extra payroll because of the double coverage and have to pay them a lot more per hour. Now who knows, I may have to have a Doctor on Staff like a Medical Spa does if I claim the pain relief from the machines.

I have too much invested with two machines, advertising, build out of rooms etc. to go back now, so we are dealing with the restrictions that we have and the hard time finding any the Estheticians