|Received:||6/3/2006 2:21:10 AM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Dear FTC I am an Associate with Pre-Paid Legal Services Inc. a publicly traded company. I have been with this company for 6.5 years. I have been involved in the Direct Sales industry for 16 years. I am retired military and I have a Masters Degree in Management and a second Masters in Nuclear Science and Engineering. I believe your Propsed "Business Opportunity" Rule R511993 would have a negative impact on me and my business which I work on a full time bases. The proposed waiting period would cause record keeping and administrative problems and have a chilling impact on small business people. The disclosure of the the 10 nearest prior purchasers of the Business Opportunity to all potential associates would violate privacy rights of other purchasers, create opportunity for identity theft, and create an enormous administrative burden on me. Requiring that a list of lawsuites filed against the company going back 10 years be provided is unfair. It does not distinuish between winning and losing lawsuites, it does not distinguish between findings and allegations. Many lawsuites are found to have no bases or merit. By requiring this kind of disclosure going back 10 years the FTC would in effect allow meritless lawsuites to turn into winning lawsuites. I believe this propsed rule unfairly targets legitimate, publicly held, direct selling businesses like Pre-Paid Legal Services, Inc. I respectfully ask that you reconsder this rule. The direct selling "business opportunity" is a multi-billion dollar industry which meets the needs of millions of people and provides needed products and services for hundreds of major corporations. Unfortunately, we also have dishonest companies and people, but we should not unfairly punish the industry. There was a time when the government thought that franchises were bad and congress wanted to outlaw them. Imagine what the world and indeed this country would be like now without franchises. As jobs disappear and salaries are reduced people want and need an alternative to the traditional employer, employee relationship. I also believe this would have a negative impact on the country as a whole. Thank you in advance for your fair reconsideration and positive changes you all will make to this proposal. Please consult with industry leaders to draft a rule that would protect consumers from dishonest companies and individuals while allow legitimate companies and business people the opportunity to compete fairly in the market place.