| Comment Number: | 522418-00774 |
| Received: | 6/4/2006 7:11:33 PM |
| Organization: | Independent Associate of Pre-Paid Legal Service |
| Commenter: | Dale Comyford |
| State: | CO |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear Sirs: I am an Independent Associate of Pre-Paid Legal Services Inc. I have only began marketing Pre-Paid Legal Services’s products for about a year ago, however, I have been a member and have used their attorneys at discount fees for over 10 years. I have been extremely pleased with both their attorney’s services and the services of Pre-Paid Legal Services. In the one case where I was not satisfied with the attorney assigned to me, PPL quickly assigned a different attorney to my issue. I have introduced several people to the business and am currently helping them to market the service. In addition to my help extensive get started assistance is available from PPL. If I were to die tonight I am confident that that assistance would be sufficient for them to succeed. I have invested in numerous “Business Opportunities” over the years. Three were scams by dishonest vendors (I got into them before the internet was invented), a bunch just were not my cup of tea and I either failed or quit, and four, including PPL were or are very successful. I oppose the implementing of the subject rule and ask you to act to prevent its implementation for the following reasons. 1. The rule is far to complex and difficult to understand. I tried to read the whole thing in the Fed. Regs. and fell a sleep 12 times before getting through the 44 pages. 2. The rule would require a 7 day waiting period to get started as business owners. Most of my associates read the material on the website and get started by signing up there. So far, all of them have gone to other websites, including ones that criticize PPL before signing up. The 7 day wait is unneeded and an undue burden on new business owners. They have done their research and want to get started. With todays Google searches it is possible to get tons of information in minutes on every business opportunity out there. In addition with all the great business opportunities out there, most venders would rather market them than waste time and money marketing something that does not work plus there is the risk of being sued in civil court with a class action suit. In the last few years I have gotten several calls from lawyers wanting to know if I could think of someone that they could sue for me. I bet you have gotten those kind of calls too. No, I did not give them any names. 3. Requiring me to provide names and phone numbers of the 10 nearest purchasers of the Business Opportunity to all who are interested would violate their privacy and open them up to identity theft. 4. The rule would require me to provide a list of lawsuits filed against not only PPL but also to list and provide information on all lawsuits against all the PPL lawyers and legal firms in every state of the US and Canada to all potential associates. Needless to say this is an undue and unnecessary burden. Please act to stop this rule. As business opportunity buyers, we don’t need it and we don’t want it. All we want is the opportunity to fail and succeed on our own merits. I have found that there are more dishonest lawyers out there than dishonest business opportunity sellers. As a marketing associate of a business opportunity seller (PPL) this rule would add unreasonable additional costs to the starting of the business and would make it more expensive and difficult for our average buyer to get started in an excellent money making business at a very reasonable cost. Thank you for your assistance in this matter.