| Comment Number: | 522418-13259 |
| Received: | 9/29/2006 4:53:25 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: | 522418-13259.pdf Download Adobe Reader |
Comments:
IMPORTANT ADDITIONS IN REVISED REBUTTAL OF DSA COMMENTS (522418-12055 through 12096) REGARDING FTC BUSINESS OPPORTUNITY RULE After much additional work on this important rebuttal, I have attached my latest revision of comments submitted August 7 and 8 (tracking nos. 522418-13112 to –13113 and the Aug. 8 revision – before I found out about the extension for rebuttals), which rebutted the comments by the Direct Selling Assn (DSA) in 11 parts by Joseph Mariano, et al (tracking #522418-12055 through 522418-12096). Since this is all based on 12 years of research and prepared in consultation with other top experts on the subject, I earnestly hope FTC personnel read this rebuttal carefully. Included in this submission is some important statistics (including Exhibit A on breakdown of a sampling of comments), terminology, and proposed disclosure forms which should resolve the impasse over the issue of requiring meaningful and honest disclosure vs. invasion of privacy and overly burdensome reporting by individuals. The form in Exhibit B should satisfy the consumer’s need for genuinely helpful information and the MLM’s desire for simplicity and protection of individual privacy. And the conclusions capsulize the fundamental issue before the FTC in this rulemaking endeavor. 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