| Comment Number: | 522418-03932 |
| Received: | 6/23/2006 12:15:59 PM |
| Organization: | Xango, LLC |
| Commenter: | Hamilton & Pamela Durow |
| State: | CO |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| Attachment: | 522418-03932.pdf Download Adobe Reader |
Comments:
June 23, 2006 Hamilton and Pamela Durow Federal Trade Commission/Office of the Secretary, Room H-135 (Annex W) Re: Business Opportunity Rule, R511993 600 Pennsylvania Avenue, NW Washington, DC 20580 RE: Business Opportunity Rule, R511993 Dear Sir or Madam: We are writing this letter because of concern over the proposed Business Opportunity Rule R511993. We believe that in its present form, it could prevent us from successfully continuing as independent distributorship for Xango, LLC. We became distributors for Xango, LLC in October 2005. Since joining, we have been able to build a small business, part time, that has the goal of supporting, more intensely, the seminary 2 of our sons have joined. They have both taken a vow of poverty, and they, along with their fellow seminarians depend totally on contributions and the good will of others. Our income at this point is still minimal, but we plan to continue this work and to increase it in order to give greater support. Originally, we became network marketers because we wanted to improve our health and earn some additional money. Our family has big plans for this extra income; to support those giving their whole lives to help others. Please help us preserve our small business. We need it! Some of the sections in the proposed rule would make it hard or almost impossible for us to sell Xango, mangosteen juice. People who are trying to find ways to feel better usually want to begin right away. The 7-day waiting period will delay the opportunity to try mangosteen juice to see if there is any benefit and give the public the idea that there is something wrong with our plan or us. Personally, with the addition of mangosteen juice, we no longer have symptoms of fibromyalgia, traumatic arthritis and have fewer allergy symptoms. These conditions are inflammatory ones, and for us, the mangosteen juice has relieved them. We do not want others to be deprived of the possibility of help, too. Xango, LLC already has a 100% buyback policy. A Xango independent distributorship only costs $35.00. We understand that you are trying to thwart the unprincipled, and we truly appreciate that, but in the process, the honest and legitimate folks will have a heavy burden placed on them that could hurt or destroy their businesses. Under this waiting period requirement, we will need to keep very detailed records when we share our product, and will then have to send in reports to our company. We are just a very small home business. Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. We would be happy to provide references, but in this day and age, we are very uncomfortable with the idea of giving out the personal information of individuals (without their approval) to strangers. This would make people in our organization, especially women, very vulnerable in numerous ways. Their safety could even be endangered. We fully understand this rule is aimed at the unlawful and unscrupulous - we are aware of many swindles on the Internet and have even been approached ourselves. However, this rule will do nothing to stop them. We believe it has the potential to hurt ours and many other honest hardworking small businesses. Nevertheless, our greatest fear is the detrimental effect this could have on our goal of supporting the seminary. Most likely, this rule will not stop lawbreakers – they violate the current rule, why would they comply with this one? Sincerely, Hamilton S. and Pamela M. Durow