| Comment Number: | 522418-12492 |
| Received: | 7/17/2006 10:15:10 PM |
| Organization: | Shaklee distributor |
| Commenter: | Joan Lubar-Alvarez |
| State: | OR |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
The suggested changes in Business Opportunity Rule R511993 will seriously hamper our business. We run a very respectable small business, talking with people around the country and in the area, promoting both our Shaklee products and business opportunity. What you are asking us to do is next to impossible, especially the giving of a list of people who began their businesses in the last 3 years. That is a true invasion of privacy and so unnecessary! In addition, our distributor cost is as low as $19.95, hardly anything to worry about in terms of fraud. Our products are 100% guaranteed, so no one loses anything on buying them. The proposed rule calls for the release of any information regarding lawsuits that allege misrepresentation, or unfair or deceptive practices over a 10-year period. It does not matter if the company was found innocent or not liable. It does not make sense to me that I would have to disclose these lawsuits unless Shaklee Corporation, or its officers, directors or sales department employees, had been found guilty or liable. Fifty-year old companies such as Shaklee would be at a disadvantage compared to start-up companies, which may not yet have experienced litigation but are far more likely to have legal issues surrounding their opportunities. I have been a Shaklee distributor for over 22 years. I joined because I loved the products and decided later to share them with others as a distributor. These rules make no sense to me and are placing an undue burden upon me and others like me. Please rethink this, as our personal income relies upon this business. Thank you for your time, Joan Lubar-Alvarez