| Comment Number: | 522418-02555 |
| Received: | 6/16/2006 9:26:23 AM |
| Organization: | Cash Cow Enterprises, LLC |
| Commenter: | Atticus Killough |
| State: | SC |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Dear FTC Thank you for considering my comments on your proposed change to the Business Opportunity Rule. I am an independent distributor for XanGo, and we market a functional health beverage based on the mangosteen fruit. I have been involved in direct selling since 1997 and have managed to turn it into a full-time income since 2000. 2.5 years ago a friend of mine showed me what mangosteen juice did for a bad case of poison oak from which he was suffering. I was very intrigued and immediately wanted to try this product, so I ordered 2 cases and launched my XanGo business for about $270. A 7-day waiting period (reminiscent of the waiting period required for handgun purchases) may have caused me to think twice. As it was, my family and I noticed results almost immediately and we began sharing the story of this product with family and friends, and I began aggressively marketing the juice. In my 9 years of direct selling I have never seen anything grow so fast. My sales organization today produces over $700,000 a month in sales volume and for well over a year this has afforded me a multiple-six-figure income and a lifestyle approaching that of the "American Dream" Since the cost to get started in XanGo is $35, and given that they offer a 30-day unconditional money-back guarantee on up to 8 25-oz bottles consumed, and a buyback of all remainng usable product, I have seen great success in employing XanGo's liberal "no risk" policy. I attribute my rapid growth to this sense of security each new distributor and customer can feel. It allows for plenty of "exploratory volume," and it's often in testing the product that a customer then commits to purchasing long term. Having a 7-day waiting period would seriously hamper the speed with which my business can grow from month to month, and have a deleterious effect on my earnings potential and on the stability of my business. This, in turn, will reduce the amount of income tax I will be able contribute back to my state and federal government. Many new distributors are at their most excited the day they get started, which typically produces the highest level of activity. To implement the waiting period would potentially squelch initial momentum, so crucial for the growth of the company, the growth of my own organization and for each individual's personal business growth. I truly do appreciate the FTC's desire to protect consumers from unscrupulous practices, but I can assure you that XanGo has to date been the most ethical and straightforward company with which I have ever been associated. There is a saying that "abuse doesn't take away the use" and to force XanGo and other legitimate Network Marketing companies to submit to a law that in essence punishes them and their distributor force for the "sins" of a relatively small minority seems un-American. The waiting period issue is, of course, my gravest concern, but with respect to earnings claims, let me state that I could easily falsify my bank statements and airbrush a few extra zeros onto the end of my check. There will always be wolves out there, but don't punish the whole flock as a result. Also, I would feel very nervous about having my personal data made available to any and all who want to contact the 10 nearest existing sales people. In addition, most of our "sales reps" are "merely" customers. Many of our distributors are content simply to order product and refer a few people to essentially get a rebate on their product purchases, along with having some additional tax deductions. I don't want to expose my prospects to 10 people around me who may be my competitors. I also don't want my private information, nor that of my team members disclosed to potentially unscrupulous inquirers. Thank you for your time and consideration. I am grateful for a government that is willing to listen to my concerns. Let freedom ring! Sincerely, Atticus Killough XanGo Indpendent Distributor Greenville, South Carolina