From: Duvall, Gary R. <GD1!SEATTLE!GRD@grmdunn.attmail.com>

To: HQ.HQ02(franpr)

Date: 5/16/97 10:22am

Subject: RE: Comment on FTC Franchise Rule Revisi

I have a supplemental comment, on Item 1, below. These have to do with the importance of improving the UFOC format before adopting it as a federal standard.

In Item 3, the required disclosure of confidential settlements discourages settlement of disputes, and thereby encourages prolonging of litigation and arbitration. This should be reconsidered in my opinion.

In Item 17, last paragraph, there are two errors in the statutory references. The reference to Delaware should be to [Code Tit. 6, Ch 25, Sections 2551-1226], and the reference to Illinois should be to:

[85 ILCS 705/19 and 705/20].