- Prevagen's active ingredient is apoaequorin, a protein originally discovered in jellyfish and now made synthetically.
- Its main human trial, the company-funded Madison Memory Study, showed no statistically significant benefit over placebo on any of its nine cognitive tasks, according to regulators; the positive claims came from after-the-fact subgroup analyses.
- The FTC and the New York Attorney General sued the maker, Quincy Bioscience, in 2017. In March 2024 a jury found none of eight challenged memory claims was backed by competent and reliable scientific evidence.
- In December 2024 the federal judge ordered Quincy to stop using all eight statements, including "clinically shown to improve memory," but denied the state's request for money penalties. Quincy appealed; the Second Circuit heard arguments in February 2026.
- If you want a memory supplement with real trials behind it, there are better-studied places to start — and memory changes deserve a medical workup first.
What Prevagen is — and what apoaequorin does
Prevagen is a memory supplement made by Quincy Bioscience of Madison, Wisconsin. Its signature ingredient is apoaequorin, a calcium-binding protein first found in the bioluminescent jellyfish Aequorea victoria. The version in the product is produced synthetically.
The marketing logic goes like this: calcium regulation inside neurons declines with age, apoaequorin binds calcium, therefore apoaequorin could protect aging brain cells. That is a plausible-sounding mechanism. The problem is the gap between mechanism and what happens when you swallow the protein.
Apoaequorin is a protein. Dietary proteins are normally broken down into amino acids and small peptides during digestion, so critics have long questioned whether an intact, functional protein reaches the brain after an oral dose. The early animal work often cited in its favor delivered apoaequorin directly into the brains of rats, which sidesteps that question entirely.[5] To our knowledge, there is no independent human evidence showing that oral apoaequorin reaches the brain in active form.
The Madison Memory Study: what it found
Prevagen's key human evidence is the company-sponsored Madison Memory Study, a randomized, double-blind, placebo-controlled trial in a little over 200 adults that tested participants on nine cognitive tasks.
According to the FTC and New York's complaint, the Prevagen group showed no statistically significant improvement over placebo on any of the nine tasks.[1] The complaint also alleged that the company then ran more than 30 post hoc analyses — slicing the data after the results were known — most of which were not statistically significant either; the few positive results involved isolated tasks in small subgroups.[2] Those subgroup findings are what later appeared in advertising.
When a trial runs many comparisons after the fact, some will look significant by chance. That's why researchers treat post hoc subgroup results as hypotheses to test in a new trial, not as evidence a product works. The way to confirm a subgroup finding is a fresh, pre-registered trial in that subgroup — which is exactly what the regulators said was missing.
The regulatory and legal history, in order
Prevagen is unusual among supplements because its claims have been tested in court, not just in the lab. The timeline below is drawn from the FTC, court records, and trade-press coverage of the case.
| Date | What happened |
|---|---|
| January 9, 2017 | The Federal Trade Commission and the New York Attorney General jointly sued Quincy Bioscience, alleging that Prevagen's memory-improvement claims were false and unsubstantiated.[1] |
| September 2017 | A federal district judge dismissed the case; the FTC appealed. |
| February 21, 2019 | The U.S. Court of Appeals for the Second Circuit vacated the dismissal and sent the case back to the district court.[2] |
| September 2021 | The FTC's claims for money relief were dismissed after the Supreme Court's 2021 AMG Capital Management decision limited the FTC's ability to seek monetary remedies in court; the case continued on other grounds.[3] |
| March 11, 2024 | A jury found that none of the eight challenged statements was supported by competent and reliable scientific evidence, and that all eight had the capacity or tendency to deceive under New York Executive Law. Under New York's consumer-protection statutes, it found two statements — that Prevagen reduces memory problems associated with aging, including a "clinically shown" version — materially misleading.[3][4] |
| December 2024 | Judge Louis L. Stanton ordered Quincy to stop using all eight challenged statements, including "Prevagen is clinically shown to improve memory," but denied New York's requests for civil penalties and disgorgement. Quincy said it would appeal.[4] |
| February 26, 2026 | The Second Circuit heard oral argument on Quincy's appeal of the liability findings and the scope of the injunction, and on New York's request to revisit monetary penalties.[5] |
As of the most recent coverage we could confirm, the Second Circuit had not yet issued its decision. Because appeals can change the outcome, check the court docket or the FTC's case page for the current status before relying on any single article — including this one.
Two points are easy to lose in the headlines. First, the jury did not find that every claim was materially misleading under New York's consumer statutes — only two were. Second, it did find that none of the eight claims had competent and reliable scientific support. For a reader trying to decide whether to buy the product, the second point is the one that matters.
Why heavy advertising isn't evidence
Prevagen's national TV presence and pharmacy shelf placement make it feel established. But in the US, dietary supplements do not need FDA approval for effectiveness before they are sold. "Clinically studied" can mean one company-funded trial. Bestseller rankings measure marketing, not memory.
That is not unique to Prevagen. It is why we rank ingredients by independent trial quality on our best brain supplements page and why our piece on blends vs single ingredients argues for products whose dose and evidence you can trace.
Better-supported places to start
No supplement has been shown to prevent dementia. But several ingredients have more independent, better-designed human research than apoaequorin:
- Omega-3 DHA — studied in older adults with age-related cognitive decline (the MIDAS trial used algal DHA). NIH notes that trials in cognitively healthy older adults show no significant effect, while some findings in mild cognitive impairment are more encouraging but need confirmation. See how DHA relates to age-related cognitive decline.
- Citicoline — a choline donor with randomized trials in older adults with memory complaints. Our review of citicoline research covers what was and wasn't shown.
- Correcting a deficiency — low B12 or vitamin D, untreated sleep apnea, depression, hearing loss, and medication side effects can all show up as "memory problems." Fixing a real deficit tends to beat adding a novel ingredient.
Be wary of the reverse trap, too: just because these options have better evidence doesn't make them proven treatments. Expect modest effects at best, and judge them over months, not days.
What to actually buy
We don't link Prevagen. If you want a supplement with an independent trial base instead, these are the products the site already covers in depth.
Nordic Naturals Algae DHA
Algal DHA — the source type used in the MIDAS trial discussed in our DHA coverage. Compare DHA per serving on the label.
Nootropics Depot Citicoline (Cognizin)
The citicoline product featured across our citicoline coverage. Talk to your doctor first if you take a dementia medication.
Frequently asked questions
Does Prevagen work?
According to the FTC's complaint, its main company-funded trial showed no statistically significant benefit over placebo on any of nine cognitive tasks. In 2024 a jury found that none of eight challenged memory claims was supported by competent and reliable scientific evidence.
What is apoaequorin?
A calcium-binding protein first identified in a jellyfish. Prevagen uses a synthetic version. Whether an oral protein reaches the brain intact has not been demonstrated in independent human research.
Was Prevagen banned?
No. It remains on sale. In December 2024 a federal court ordered the maker to stop using eight specific memory claims; the company appealed, and the Second Circuit heard arguments in February 2026.
Is Prevagen safe?
Safety is a separate question from effectiveness, and this review focuses on the evidence for its memory claims. Anyone with health conditions or on medications should check any supplement with a pharmacist or doctor.
What should I take instead?
Start by ruling out treatable causes of memory change with a clinician. If you want a supplement, ingredients such as DHA and citicoline have more independent trial data, though benefits are modest and not guaranteed.
Citations
- Fair L. Prevagen complaint suggests mindfulness about memory claims. FTC Business Blog, January 9, 2017. https://www.ftc.gov/business-guidance/blog/2017/01/prevagen-complaint-suggests-mindfulness-about-memory-claims
- U.S. Court of Appeals for the Second Circuit. FTC and People of the State of New York v. Quincy Bioscience Holding Co. Summary order, February 21, 2019. https://www.ftc.gov/system/files/documents/cases/quincy_bioscience_2019.02.20_dkt_50_opinion_of_2nd_circuit.pdf
- Truth in Advertising. Jury hands down verdict in Prevagen deceptive marketing case. 2024. https://truthinadvertising.org/articles/jury-hands-down-a-verdict-in-prevagen-deceptive-marketing-case/
- Long J. Prevagen's claims curbed, but New York attorney general's monetary demands denied. SupplySide Supplement Journal, December 17, 2024. https://www.supplysidesj.com/supplement-regulations/prevagen-s-claims-curbed-but-new-york-attorney-general-s-monetary-demands-denied
- MedShadow Foundation. The regulatory loopholes behind Prevagen's rise. Published May 2026. https://medshadow.org/integrative-health/non-drug-supplements/prevagen-memory-claims-explained/