|Received:||7/14/2006 12:24:04 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:In Re: Business Opportunity Rule, R511993. My Personal Quixtar Experience: I have been a Quixtar IBO for about two years, within the Markiewicz International organization. The information which I received prior to registering was based upon the personal franchise focus of my Emerald upline. After I registered, I found that there were many more creative business opportunities, and I’ve spent the past year learning about and exploring those opportunities. I have been able to meet some personal and professional goals relative to learning about the e-commerce and i-commerce industries within an informal and relaxed business system approach which includes personal one-on-one training, as well as formal training via printed/audio materials and seminars. My next goal as an IBO is to put the training I’ve received into action via personal contacts and web marketing strategies, and to invest time and capital into more advance leadership development training. Both the unique Quixtar business system and the affiliated Britt Worldwide educational materials fit into my overall lifestyle, providing me with timeless principles in a culture-current, positive format. I’ve realized both tangible and intangible benefits other than income, such as learning about price structuring, private franchising, and relationship-building. It is my opinion that the prospects and IBOs who take advantage of the specialized education associated with Britt Worldwide, Winters Marketing, and Markiewicz International should be able to quickly understand that the Quixtar business opportunity is not a get-rich-quick plan, that hard work is required, and that there are no guarantees of success, due to the fact that the testimonies and training materials provided are proven, factual, and bona fide, based upon personal experiences of people from all walks of life. The proposed rule in its present form would create serious problems for every Quixtar IBO. For example, the compulsory 7-day waiting period is irrelevant to the culture-current global, web-based marketing of today's economy. This could be eliminated or revised to a 3-day waiting period, while still protecting the prospect’s need for more information and at the same time maintaining the marketing advantage for the private franchise sponsor as well as for the Quixtar Corporation. There is more than adequate information which any prospect can glean from the Quixtar website, and the sponsoring IBO has the unique ability to connect the prospect with successful long-term business owners who can answer any questions the prospect may have. Relative to certain financial investments, a prospect can receive money back if not satisfied. The requirement relative to providing prospects with personal information about local IBOs would infringe on the privacy of every IBO whose name, address, and phone number was provided to prospects. It would also penalize the sponsor, who would be required to give his prospect contact information for 10 other IBOs, any of whom might be happy to register the prospect themselves. An alternative would be to provide the prospect with selected Eagle level or above “Profiles of Success” as references, with such profiles containing limited information about the IBO's experience/testimony, and being more or less tailored to the prospect’s personal and/or professional current demographics/lifestyle/ interests/career. (The person(s) represented in the Profiles of Success should have already signed a release with Quixtar relative to use of certain information for purposes of validating the viability of the Quixtar opportunity.) I believe that providing every prospect with important information about prior experiences is good for Quixtar and the entire direct selling industry. However, there are less burdensome ways to accomplish that goal than the manner set forth in the proposed FTC rule.