| Comment Number: | 522418-13262 |
| Received: | 9/29/2006 6:51:44 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 |
| No Attachments |
Comments:
ATTN: FTC Personnel - These comments constitute our rebuttal of the submission by Dana Fix of Chadbourne & Parke LLP (Tracking No. 522418-11898). The claim that the proposed rule uses a definition of “Business Opportunity” that is overbroad and vague has merit and should be given serious consideration. The submitter’s concern was that the publication and sale of bona fide educational materials and course work is not a good application for the proposed rule. As the volume and intensity of comments from almost exclusively MLM companies makes clear, this is primarily an MLM or chain selling issue, not an issue with legitimate business opportunities. Having worked in the field of business opportunities for over 35 years, I can tell you that MLM is a horse of another color from legitimate business opportunities. MLM’s thrive on misrepresentations, at least 30 of which are explained by going to our web site at – http://www.mlm-thetruth.com/Misrepresentations-RecruitingMLMs.pdf MLM’s or “entrepreneurial chains” are rarely if ever legitimate sales or business opportunities, as explained in report rebutting DSA comments (tracking no. 522418-13259). 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