|Received:||7/12/2006 11:33:23 AM|
|Organization:||Lia Sophia Jewelry|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I urge the FTC to take more time to investigate the potential harm this ruling will do to legitimate direct sellers and their businesses. While I appreciate their concerns about fradulent practices and agree that strong measures need to be taken to protect consumers and potential victims, the rule as it is written will do more harm than good. I have been in business as a Lia Sophia Advisor and Unit Manager for 4 years and my company has been in business for over 30 years. I voluntarily provide a record of my personal earnings from my business, broken down by month, for the previous year to every individual who expresses an interest in my business opportunity. My company, led by Tory Kiam, Peter McBride, and Rick Schwartz, is very committed to doing business in an ethical and honest way. Our compensation program and management program are based on the product we offer, not on simply recruiting people into the business. Many years ago, my husband and I were recruited into a company we thought provided a legitimate business opportunity for us. I had lost my job and we were hoping to start a family and the picture that was painted for us was just what we were looking for...or so we thought. It didn't take long to find out that the focus of the company was simply to recruit new people and selling a product was secondary to that effort. We severed our relationship with the company and were saddened that by doing so we also were cut off by the "friends" who recruited us in the first place. Because of that experience I was leery of direct sales and asked detailed questions of my contact with Lia Sophia, then Lady Remington Jewelry. I knew I didn't want to become involved with another company that painted a pretty picture, but had no substance or plan to make that picture a reality. In every dealing I have had with Lia Sophia, I have found both the home office and my manager to be forthright and honest about both the potential and the pitfalls of our company and direct sales in general. I conduct all of my business dealings in the same manner. I respectfully ask that the FTC seriously reconsider enacting the proposed ruling as it is currently written. Please take the time to address the differences between legitimate direct sales companies and the type of multi-level or network marketing that is built solely on "pie-in-the-sky" and false earnings claims.