|Received:||7/8/2006 11:45:09 AM|
|Organization:||JF. Zahn and Companies, Inc.|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Gentlemen… July 7th, 2006 In regards to “Business Opportunity Rule, R511993”, The proposed FTC change of rules would harm our business in several ways. Firstly, a seven-day waiting period would demise our ability to sell our XanGo product while we are on the road, family functions, and other courses of meeting people, in other than business surrounding and circumstances. As a standard we give an amount of information and literature, and also provide our contact information. This allows the prospective customer, consumer, and interested prospective distributors, to research information provided by web sites, other person in the up line of the organization, and other informational sources before the prospect decides to make a decision to join. A seven-day wait period would cause an amount of fear that the FTC requires this waiting period, and may cause all prospects to void any further communications. Second, a list of nearest references in the case of the XanGo business model is not a correct approach to this subject. The closest 10 purchasers, would cause a vast amount of wasted corporate time in compiling such lists, that would be a negative cost effect, and a negative force for the prospect, due to the fact that the prospector, may have no relationship what so ever with ten strangers in the area. XanGo prospects are informed of who is in their up-line, and also invited to attend informational meeting, where more than ten prospectors are available for inquiry and comments. Randomly give an uninterested prospect our personal information, could then be used for other purposes, fraud, and other personal information scams. Third, the earnings claims statement would be an unlawful insight to our personal business. We are not running for any kind or form of government office, and actually only provide this kind of information privately to the IRS, specific state, and specific county tax collectors. Which information is guarded, and protected by the governing laws of the United States of America. Fourth, legal actions occur in every part of the country, many do not even reference a specific companies product, but an individual person, or corporation that has not complied with the rules of the MLM or distributorship. This would ultimately be costly to the corporation, by listing legal action that may have no bearing on the parent corporation. Fifth, cancellation and refund request for the past two years would be a tragic use of company resources, that would need to be constantly revised and cause a enormous amount of revenue to perform this kind of function. Many prospects have dollar-based goals, and when the goal is reached or not reached, the performance level is evaluated, and then the decision to continue or discontinue participation is invoked. This may have no direct correlation to the subject, and construing incorrect information. We hope that this correspondence sheds some light to the bad and recurring damage this change of rules would cause to our business. Many of us have been involved in mlm types of businesses before, and have had our share of problems one way or another, in striving for success. XanGo is one of many that are truly above board, and upfront with all of its information. I propose that all mlm’s that have any question of deceptive practices, be eliminated and the parent corporation is shut down from further operation, and any holdings of the deceptive corporation be liquidated and returned to down-lines. We respectfully submit our comments for your review and publication if necessary. Best regards, JF. Zahn Chief Executive Officer JF. Zahn and Companies, Inc. Autumn L. Zahn Director of XanGo Operations JF. Zahn and Companies, Inc.