| Comment Number: | 522418-12748 |
| Received: | 7/17/2006 11:55:16 PM |
| 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: | 522418-12748.pdf Download Adobe Reader |
Comments:
ATTN: FTC personnel – Regarding the Business Opportunity Disclosure Rule R511993, the “Network Marketing Payout Distribution Study” has much relevance to the issue of earnings disclosure that is addressed in the proposal. It was mailed earlier, but since no confirmation of your receiving it in your office could be obtained, I am attaching it now. This study consisted of a challenge issued to presidents of 6o of the most prominent MLM companies to voluntarily disclose data regarding earnings of distributors that would help consumers make informed decisions. Personnel from six companies promised to respond with data, but none were able or willing to do so. I suspect upper management realized that the data was too damning. But the FTC could – and should require such information. More details on recommended disclosure, based on extensive research, is found in my earlier submissions (tracking number 522418-12262, et al) I also formally request a hearing or forum pursuant to Secti0n 18[c] of the Federal Trade Commission Act and Section F of the April 12, 2006, Notice of Proposed Rulemaking. I would be prepared to testify regarding the matters discussed in the tax report, as well as the submittal I sent earlier (tracking number 522418-12262). Others with significant information to report relevant to the new rule include, Bruce Craig, former Assistant AG of Wisconsin, Robert Fitzpatrick of Pyramid Scheme Alert, Eric Schiebeler, Doug Brooks, an attorney specializing in this area who has worked on numerous similar cases, and Dr. Stephen Barrett, owner of the web site MLMwatch and numerous others, mostly related health quackery, which is common in MLM schemes.. - Jon M. Taylor, Ph.D., President, Consumer Awareness Institute and Advisor, Pyramid Scheme Alert E-mail: jonmtaylor@juno.com Web site for MLM research and guides – www.mlm-thetruth.com