| Comment Number: | 522418-10423 |
| Received: | 7/16/2006 1:11:58 PM |
| Organization: | Infinity Health, LLC |
| Commenter: | Conrad Bell |
| State: | OR |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
July 16, 2006 Marika and Conrad Bell Infinity Health, LLC. Federal Trade Commission/Office of the Secretary, Room H-135 (Annex W) Re: Business Opportunity Rule, R511993 600 Pennsylvania Avenue, NW Washington, DC 20580 RE: Business Opportunity Rule, R511993 Dear Sir or Madam: We are writing this letter because we are concerned about the proposed Business Opportunity Rule R511993. We believe that in its present form, it could prevent us from continuing as Take Shape for Life Health Advisors. I understand that part of the FTC’s responsibilities is to protect the public from “unfair and deceptive acts or practices,” but some of the sections in the proposed rule will make it very difficult if not impossible for us to sell Take Shape for Life products. The proposed rule calls for the release of any information regarding lawsuits involving misrepresentation, or unfair or deceptive practices. It does not matter if the company was found innocent. Today, anyone or any company can be sued for almost anything. It does not make sense to us that we would have to disclose these lawsuits unless Take Shape for Life is found guilty. Otherwise, Take Shape for Life and ourselves are put at an unfair advantage even though Take Shape for Life has done nothing wrong. Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. We are glad to provide references, but in this day of identity theft, we are very uncomfortable giving out the personal information of individuals (without their approval) to strangers. Also, giving away this information could damage the business relationship of the references who may be involved in other companies or businesses including those of competitors. In order to get the list of the 10 prior purchasers, we would need to send the address of the prospective purchaser to Take Shape for Life headquarters and then wait for the list. We also think the following sentence required by the proposed rule will prevent many people from wanting to sign up as a salesperson “If you buy a business opportunity from the seller, your contact information can be disclosed in the future to other buyers.” People are very concerned about their privacy and identity theft. They will be reluctant to share their personal information with individuals they may have never met. We have been Take Shape for Life Health Advisors for 4 years now. Originally, we became Take Shape for Life Health Advisors because we needed the products to get healthy and wanted to earn some additional money. Now we depend on this business as our only means of income. We appreciate the work of the FTC to protect consumers, but we believe this proposed new rule has many unintended consequences and that there are less burdensome alternatives available in achieving its goals. Thank you for your time in considering my comments. Sincerely, Marika and Conrad Bell