| Comment Number: | 522418-13252 |
| Received: | 9/29/2006 3:54:59 PM |
| Organization: | CONSUMER AWARENESS INSTITUTE - and PYRAMID SCHEME ALERT |
| Commenter: | JON TAYLOR |
| State: | UT |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| Attachment: | 522418-13252.pdf Download Adobe Reader |
Comments:
ATTN: FTC Personnel - These comments constitute our rebuttal of the submission by Avon, Inc. (Tracking No. 522418-11543). Avon has historically been a leader in the direct selling industry. However, it has recently adopted a limited multi-level model, and feedback we are receiving is that they are making it more and more difficult for participants to make a profit after buying all the product samples, etc. the companies urges them to buy. So I believe the rule would apply to them and be a protection for prospective recruits. Avon is a member of the DSA, and their comments reflect those of the DSA and member firms. So I am attaching the latest revision of my comments to the DSA and member MLM firms. It is all relevant to this submission and clearly answers their objections to the proposed rule. Sincerely, Jon M. Taylor, Ph.D., President, Consumer Awareness Institute and Advisor, Pyramid Scheme Alert - E-mail: jonmtaylor@juno.com - Web site for MLM research and guides - www.mlm-thetruth.com