| Comment Number: | 522418-13275 |
| Received: | 9/29/2006 11:27:48 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: | 522418-13275.pdf Download Adobe Reader |
Comments:
ATTN: FTC Personnel - These comments constitute our rebuttal of the submission on behalf of Herbalife Ltd.by Brett Chapman, Corporate General Counsel for Herbalife, regarding the proposed new business opportunity rule R511993 (Tracking No. 522418-11711). Herbalife is a member of the DSA, 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 highly relevant to this submission and clearly answers their objections to the proposed rule. I would add that the request to exempt publicly traded companies would not help because the SEC requires entirely different information than is needed for business opportunity seekers. 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