Healthcare Solutions Mgmt. Group Inc. (HSMD)

[sunspotter]

"Maybe it could be marketed as a dietary supplement until clinical trials and therefore meet FDA requirements. It is ingested since it is water."

As long as it didn't make any medical claims of the following sort, it could be, yes:

"intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease"

But as soon as they make medical claims, it's a drug. That's why your breakfast cereal or any other food can't claim to lower the incidence of heart disease. If they did, they'd be drugs.