| Comment Number: | 535221-00093 |
| Received: | 6/30/2008 4:26:47 PM |
| Organization: | CONSUMER AWARENESS INSTITUTE - and JON TAYLOR & CO. - and advisor, Pyramid Scheme Alert |
| Commenter: | Jon Taylor |
| State: | UT |
| Agency: | Federal Trade Commission |
| Rule: | Business Opportunity Rule |
| Attachments: | 535221-00093.pdf Download Adobe Reader |
Comments:
Howard N. Holwill, Vice President of Alticore, parent company of Amway and Quixtar, is merely parroting the approval of the DSA in exempting “legitimate MLMs” from RPBOR. It is quite obvious that he is on weak ground in his assumptions of what makes an MLM legitimate, or in how Amway/Quixtar is not a product-based pyramid scheme – with horrendous loss rates and with Amway/Quixtar promoters utilizing the typical deceptions used in MLM recruitment. For the facts and a correct and consumer-oriented rebuttal of the points they make, see attached rebuttal of DSA comments by Consumer Awareness Institute (Comment #535221-00091)