To: FTC <FRANPR@ftc.gov>
Date: 2/26/97 11:23am
Subject: 16 CFR Part 436
Dear Federal Trade Commission,
I am informed that you took 10 years to study the abuses and problems in franchising. Your franchise Rule is supposed to PROTECT PEOPLE who are victims of franchise abuse and misrepresentation.
Don't you think it would be a good idea to give PEOPLE who are injured by violations of the franchise Rule the right to sue under the Rule, i.e. a private cause of action. Isn't that what laws are for?
And while you're at it, could you also add that persons injured by violations of your franchise Rule are entitled to collect reasonable attorneys' fees. That way victims will be able to find an attorney or law firm willing to duke it out with the more heavily capitalized franchise companies who would otherwise grind meritorious victims into the ground as they have and continue to do.
Thank you for your consideration.
KEVIN BRENDAN MURPHY