| Comment Number: | 522418-01487 |
| Received: | 6/8/2006 8:55:27 PM |
| Organization: | Shaklee |
| Commenter: | John Woodman |
| State: | NY |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Re: Business Opportunity Rule, R511993 Dear Sir or Madam: I am writing this letter to express my strong opposition to the proposed Business Opportunity Rule R511993. I 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 me to develop my business as a Shaklee Independent Distributor. One of the most confusing and burdensome sections of the proposed rule is the seven-day waiting period to enroll new distributors. Many of the people who join Shaklee do so to purchase Shaklee products at a wholesale price, much as they would join a wholesale buyers club such as BJ’s, Costco or SAM’S Club. In other words, they are solely consumers of the products. If they should later decide to build a business, they only need to supply Shaklee Corporation with their Social Security Number or Tax Identification Number. There is no additional kit, fee or application required. A Shaklee Membership costs only $19.95. This is far less than the membership fee for the aforementioned “members only” clubs. Most major consumer purchases, from automobiles to household appliances, have no requirement for a seven-day waiting period. And in Shaklee’s case this waiting period is completely unnecessary since Shaklee Corporation already has a 90% buyback policy for products, including the Member Kit, purchased by a distributor within the last two years. This is above and beyond the 100% money back guarantee they offer on their products. The proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. There are numerous problems with this proposed requirement. In this day of identity theft, I am uncomfortable giving out the personal information of other Shaklee Distributors, without their knowledge or consent, to strangers. People today are understandably reluctant to share their personal information with individuals they may never have met. Additionally this will place a tremendous administrative burden on both Shaklee Corporation and its Distributors. I have been a Shaklee Distributor for nearly 25 years. I became a Shaklee Distributor because I was impressed with the exceptional quality of their products and the high degree of integrity by which they conduct business. There admittedly are many companies that set out to defraud consumers but Shaklee is NOT one of them! You don’t stay in business for fifty-years by defrauding people. While I appreciate the work of the FTC to protect consumers, I believe this proposed new rule has many adverse consequences for direct sellers and that there are less burdensome alternatives available to the agency to achieve its goals. Thank you for your time and consideration regarding this matter. Sincerely, John B. Woodman