Submission Number: 00007 

Received: 1/12/2011 7:14:13 AM
Commenter: Jon Taylor
Organization: Consumer Awareness Institute
State: Utah
Agency: Federal Trade Commission
Initiative: Trade Regulation Rule on Disclosure Requirements and Prohibitions Concerning Business Opportunities - FTC File No. R511993
Attachments:
00007-57279.pdf Size = 127 KB
00007-57280.pdf Size = 106 KB
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Submission Text
(This comment replaces my last one, which was incomplete). RE: Serious problems with the latest staff report – especially in the light of new information – and a #10,000 challenge, Part 1 Please find attached Part 1 of my comments on behalf of consumers who are scammed by some of the most unfair and deceptive practices in the field of business opportunities. The Business Opportunity Rule could help protect consumers, but only if it is handled honestly and effectively by the FTC staff. Unfortunately, the latest staff report on the Rule has some serious flaws in it that need to be corrected. The first attachment is my full comment letter: “BOR-FTC-Comment1-Jan2011.” This refers to my ebook just completed which incorporates the most extensive research ever done on “entrepreneurial chains” with an average loss rate of 99.6% - and which provides incontrovertible evidence to disprove claims in the staff report that “the IPBOR would have unintentionally swept in numerous commercial arrangements where there is little or no evidence that fraud is occurring” – which of course includes the MLM industry. The next attachment is Appendix 7e from Ch. 7 of my new e-book “The Case for and against Multi-level Marketing,” which graphically compares income options. I am sufficiently certain of my research conclusions that I am offering $10,000 to any law enforcement official that can identify any business model that is more unfair and deceptive, and more viral and predatory, than MLM. This $10,000 challenge is spelled out in the Appendix at the end of the attached letter. To download the whole e-book free of charge, go to my researched-based web site at – www.mlm-thetruth.com Jon M. Taylor, MBA, Ph.D.