Comment Number: 522418-10266
Received: 7/16/2006 1:06:46 AM
Organization: CONSUMER AWARENESS INSTITUTE - AND PYRAMID SCHEME ALERT
Commenter: JON TAYLOR
State: UT
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
Attachment: 522418-10266.pdf Download Adobe Reader

Comments:

ATTN: FTC officials considering the proposed Business Opportunity Disclosure Rule R511993 – Quoting a letter I sent earlier, “This submission has direct relevance to the proposed Business Opportunity Disclosure Rule R511993, as it furnishes a case study in compliance (or lack thereof) with past FTC efforts by FTC officials to enforce disclosure requirements for a “business opportunity” that falls in the category of a pyramid marketing (or chain selling) scheme.” Attached is the full “REPORT OF VIOLATIONS” regarding Nu Skin’s resistance to fully complying with the FTC’s order for the company and its representatives to cease and desist misrepresenting earnings of distributors. This complete version includes a simplified version of Appendix G, Part 2. (I mistakenly referred to it as Exhibit G in the last letter.) There are many lessons to be learned about disclosure and the resistance of pyramid marketing scheme promoters to accept true and meaningful disclosure – for good reason. Who would join if they knew their odds of success are far greater at the gaming tables in Vegas? - Jon M. Taylor, Ph.D., President, Consumer Awareness Institute, and Advisor, Pyramid Scheme Alert E-mail:  Web site for MLM research and guides – www.mlm-thetruth.com