| Comment Number: | 522418-13263 |
| Received: | 9/29/2006 7:07:30 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: | 522418-13263.pdf Download Adobe Reader |
Comments:
ATTN: FTC Personnel - These comments constitute our rebuttal of the submission on behalf of CTFA (Tracking No. 522418-70012) in a letter by Elizabeth H. Anderson, Exec. VP, Legal and General Counsel. This organization has many members who are also members of the DSA and supports many of the DSA’s recommendations, and the 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 responds to their suggestions regarding the proposed rule. I would specifically strongly object to the CTFA’s proposed definition of “business opportunity.” Having worked in the field of business opportunities for over 35 years< I can sat that their proposed definition serves the interests of chain selling operations, but not legitimate business opportunities. 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