| Comment Number: | 522418-01145 |
| Received: | 6/6/2006 4:00:35 PM |
| Organization: | Arbonne |
| Commenter: | Paul Palmer |
| State: | TX |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
I support the proposed FTC rules to help consumers evaluate the business opportunities claims made by Business Opportunity Sellers. The FTC 'works for the Consumers to protect them from fraud and deceptive practices in the marketplace'. I believe Consumers are hurt by these MLM salespeople who are not simply selling a product, but a business opportunity that in fact statistically fails 99% of the time. This is often not disclosed, or is deceptively hidden in confusing messaging of easy money part-time and get rich slow. This was my encounter with Arbonne International. The rules you suggest will help the Consumer see this activity as fraud and deceptive business practices. The Consumer will have the information needed to evaluate the business opportunity from the person selling the opportunity. If they like the product only and the price they will continue to buy it. If they like the products simply for the opportunity of riches by deceptively selling business opportunities that fail more often than gamblers in Las Vegas, they both should be prosecuted as a shill. I like Goggle.com definition of a Shill as 'A player employed by the house (or by the gang), whose job it is to bet in order to keep the game going and to warm up potential players (or victims)'. I believe it is very deceptive for anyone to encourage Consumers to buy product for their own use at a discount only if they will sign up as a Distributor, then, (the switch) make outrageous claims of riches and ask them to buy more sample products to get rich. Sample products are needed to encourage others to be Distributors that sign up more and more Distributors who buy samples, and so the pain-chain continues. The honest Consumer will save money (and heartache!) by not being defrauded into buying sample products that they never make a profit with, unless they get other Consumers to gamble at a loosing game. This money spent on samples and building a business is hard earned money that is wasted on a business opportunity that was deceptively sold to the Consumer. Distributors are motivated to sign up Down-line Distributors which defrauds many-many Consumers into a chain of shills who typically are not disclosing the difficult odds of being a profitable business. This down-line is also encouraged to attend sales events (pep rallies), and host expensive parties, unpaid at the Consumers expense. My conclusion was the only way to make money was to sign up lots of people who buy samples and encourage others to buy samples. In my opinion Arbonne, and any other MLM as defined on the FTC web site, is like a gambling house using excited employees (Distributors) who pretend to have won big money at card game to get unassuming Consumers to gamble at that card game at which they will most likely loose. If each loose around $1,000 and 100 are signed up, and 99% fail then $99,000 was conned away from 100 Consumers. Amazingly these excited fools become zealous unpaid shills, working hard at winning at a game odds say they can not win at and they get their friends/family to play. This becomes criminal (in my opinion) when an unpaid shill figures out the only way to win is to deceive others to sign up as unpaid shills. Thus the path to becoming paid is victimizing Consumers into an endless chain of signing up Distributors who do not sell products, but sell “opportunities”. I believe it is the successful Distributors/Shills’ who are the worst criminals, and should be prosecuted. I support legislation to make it illegal to sell an “easy, exciting, profitable, opportunity” that the seller knows is contrary to their claims. This $29 Billion MLM Industry will be commenting on how wonderful MLM, or “Direct Selling” is to the economy. In my opinion, gambling is a better bet to the economy and Consumer. In Vegas it is obvious that the consumer will likely loose at gambling, and when I encourage others to go to Vegas for the fun, I am not paid to do so.