Comment Number: 522418-04713
Received: 6/28/2006 1:35:51 AM
Organization:
Commenter: Sherry Rink
State: KS
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

Dear FTC Commissioners, I am writing concerning the proposed Business Opportunity Rule, R511993. The responsibility you hold in your position on this commission for protecting the welfare of consumers and businesses alike nationwide is an awesome task. May God be with you as you make difficult decisions. I thought of addressing directly the different emphases of the above stated rule. However, I decided on taking a more personal approach. I am a homemaker who has been out of the business world for 30 years. Being a wife, mother, and homemaker is a full-time job in itself, one I have been very happy and content to pursue. At the end of March this year, a friend of mine, also a homemaker, introduced me to XanGo, the product and the business opportunity. As I read and listened to the information that she shared with me, I made the choice to become a XanGo independent distributor, a cost to me of $35.00. Not only do I want the product for my own health benefits, but I desire to share what I am learning with the people in my life whom I care about and who are suffering physically, perhaps needlessly. So, now I am learning how to embark on a new business venture as well as manage my home and family relationships. I conduct my business while on the phone from my kitchen and living room, and from our computer downstairs. All I want to do is offer others the opportunity to try XanGo's mangosteen juice to see what benefits they may receive. All I do is share sources of information they can choose to pursue, and in some cases, a sample taste of our product. The rest is up to them. If I would need to abide by the stipulations, guidelines, and criteria of the proposed Business Opportunity Rule, my business opportunity would end before it really gets started. The record keeping, paperwork, delays, and disclosures would require more time and expertise than I could give, and would also take valuable time away from any income I would try to generate. My primary motivation is to help those I know and care about, but earning an income in the process is also an honorable goal, for me as well as them, if they so choose. All of that will be jeopardized, if not destroyed, under R511993. I am an individual, not a corporation. Reputable network marketing companies like XanGo, AIM, Shaklee, Nu Skin, HerbaLife, Juice Plus, etc. who work hard to keep their commendable reputations in tact would have no choice but to strive to comply with the far reaching burden of this rule. However, the people/companies with ill intent and ill repute would only keep up their schemes and deceptions and circumvent the rules of this Rule. I fail to understand how what is proposed will catch the thief. I would be interested to hear how you think this will work. Instead, would it be feasible to have strict and punitive measures in place that could be applied on a case by case basis when one is proven guilty of criminal acts? The principle is basic-punishment and restrictions are reserved for the one who is convicted of being guilty, be it a misbehaving child in the home, not all of his siblings, or a criminal sentenced in a court of law, not everyone at the scene of the crime. The proposed rule would jeopardize the good and allow the bad to keep on keeping on, because if they are deceiving others now, they will keep on deceiving, even the FTC. I guess I am asking the Commission to rethink this rule, not its intent, but how it could be better applied, and the mechanics of its application more fine tuned. The wellbeing and even existence of many reputable and well intentioned companies and individuals is at stake here. I am inquiring so as to save the life of my own new business opportunity. My business future is in your hands. Please treat it with regard and respect. I know you will find the appropriate and equitable answer. Thank you for taking on such a formidable task. My prayers are with you. Sincerely, Mrs. Sherry Rink