|Received:||7/6/2006 3:20:16 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have reviewed comments from other members of Quixtar and concur that the bill needs to consider how we have been successfully operating our network businesses, and in all fairness to us make some necessary changes. My wife and I have been in the Amway and Quixtar business for over 16 years. The changes that must be considered include creating a 7 day delay in registering clients which would absolutely kill any further business for us. The registration part of our business is very delicate and people usually give up and don't register when offered. This doesn't in any way suggest we are taking advantage of people and cheating them by urging them to register now. Also, the reference list requirement would be very impractical. First of all, when someone is starting out, he doesn't have any personal references. And second of all, references given may be called and offered an opportunity to join the references’ organization and not ours. We have always provided a list of references in our total organization across many professions mainly to impress on the quality of our leadership. Also, I don't understand that you want us to give a litigation list. Is that a requirement of any other kind of US business? In nearly 100 percent of the litigation I have studied against Amway or Quixtar was bogus, not warranted, and simply stupid. People looking at the litigation list would conclude that it is illegal without understanding anything behind the final ruling for any item listed. And finally, your suggested earnings disclosure would obviously say you can’t do this and why bother. (Actually we have always given a proper earnings disclosure to our prospects.) Don’t make it impossible for us to do business.