|Received:||7/16/2006 11:42:46 AM|
|Organization:||Independent Shaklee Distributor|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been a Shaklee Distributor for 31 years. It would be a great injustice if the suggested rules are imposed on as wonderful a company as Shaklee, and many other fine MLM companies as well. I have read the recommendations put forth by Robert L. FitzPatrick, Pres. Pyramid Scheme Alert. He claims to be an authority on distinguishing a legitimate Multi-Level-Marketing opportunity, a Pyramid Scheme, or Illegal Pyramid Scheme. He does nothing of the sort. He consistently blurs the lines between legitimate MLM and Pyramid Schemes, or even illegal pyramid schemes. He is extraordinarily reckless with his home-made definitions. His solution to reducing harm to the public is to impose ridiculous and very harmful rules on the law-abiding, productive U.S. MLM participants, such as we Shaklee Distributors, for instance. We do not systemically cause harm. Illegal, harmful pyramid schemes cause harm. It would be very harmful to impose these rules on us! Mr. FitzPatrick's "expertise" is very misinformed.