| Comment Number: | 522418-13214 |
| Received: | 9/1/2006 11:35:33 AM |
| Organization: | |
| Commenter: | Steven Johnson |
| State: | OH |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| Attachment: | 522418-13214.pdf Download Adobe Reader |
Comments:
My family has been taken advantage of by a misleading business opportunity offered by the Shaklee Corporation of California. Shaklee repeatedly lied about the amount of income that distributors earn selling their products. In the public comments on the FTC's own website about the business opportunity rule, there is a blatant example of Shaklee's lies about distributor income. Comment number 3039 by Bill Vann (http://www.ftc.gov/os/comments/businessopprule/522418-00655.htm) contains an attached advertisement for the Shaklee "business opportunity" (http://www.ftc.gov/os/comments/businessopprule/522418-00655.pdf). In the lower right portion of the document under the heading "Average Income per Rank", the document states that distributors (abbreviated "Dist" in the document) is $5,798/year. That income is entirely false. Shaklee's own web site states that directors (abbreviated "DIR"), not distributors make $5,800/year (http://www.shaklee.com/main/compChart). In the Shaklee pyramid, a director is a higher and relatively rare salesperson compared to a distributor, which anyone can become by paying to join Shaklee. The Shaklee business opportunity advertisement contains an egregious lie. It claims that distributors, which anyone can become, will average $5,798/year in income. In fact, the $5,798/year income is earned only by directors. Nobody knows what Shaklee distributors average because Shaklee deliberately conceals that information. Income misrepresentation by MLMs such as Shaklee must stop. MLMs have become so brazen that they are making false income claims on the FTC's own web site. This sort of deception by Shaklee and other MLMs is exactly why the FTC needs to enact the new business opportunity rule and shut down companies like Shaklee that intentionally and repeatedly lie about the income potential of their salespeople.