| Comment Number: | 522418-00188 |
| Received: | 6/1/2006 8:59:47 AM |
| Organization: | Shaklee |
| Commenter: | Ginger Derkatch |
| State: | OK |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| Attachment: | 522418-00188.pdf Download Adobe Reader |
Comments:
Re: Business Opportunity Rule, R511993 Dear Sir or Madam: We are writing this letter to express our strong opposition to the proposed Business Opportunity Rule R511993. We understand that it is the responsibility of the Federal Trade Commission to protect the public from "unfair and deceptive acts or practices," but the rule as proposed would make it very difficult for us to operate our business as Shaklee Independent Distributors. A fifty-year old companies such as Shaklee Corporation and their distributors would be placed at a disadvantage compared to start-up direct selling companies which may not yet have experienced litigation but which are far more likely to have legal issues surrounding their opportunities. We have noticed over the years in this industry that it is the start-ups and younger companies that are often the source of problems due to misrepresentation, buy-in fees that don't reflect the cost of products etc. These are harmful practices which should be addressed but not by punishing companies that have been operating by ethical and legal standards and have followed the "golden rule" in their overall business practices. Our detailed response is attached. Thank you for your time in considering our comments. Sincerely, Ginger & Earl Derkatch