There is some data bearing this out
How does tracking affect monitoring progress
Pediatric Use Intake in children should be in the amount (0.5 to 3 mcg daily) recommended by the Food and Nutrition Board, National Academy of Science-National Research Council
This results in increased concentrations of the melanogenic enzymes within the melanocyte
"Intelligent testing Page 220 and 221: Ikegawa S, Hasegawa M, Okihara R, S Page 222 and 223: Page 224 and 225: Iversen A, Kuhn I, Franklin A, and Page 226 and 227: Jang Y-C, Lee C, Yoon O-S, and Kim Page 228 and 229: Chemosphere 2003, 50(3):437-443
The filing relies heavily on prior regulatory action against Empower, including an FDA warning letter issued after inspectors found that drugs were not stored under sterile conditions