| Comment Number: | 522418-10499 |
| Received: | 7/16/2006 3:46:01 PM |
| Organization: | PartyLite Gifts, Inc |
| Commenter: | Cathie Kummer |
| State: | FL |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| Attachment: | 522418-10499.pdf Download Adobe Reader |
Comments:
Cathie Kummer PARTYLITE INC. Federal Trade Commission Office of the Secretary Room H-135, Annex W 600 Pennsylvania Avenue, NW Washington, DC 20680 Dear Federal Trade Commission Member: I am writing to ask that you reconsider some of the requirements that the Commission is proposing to regulate the direct sales industry. I am an independent Consultant with PartyLite, Inc... I am proud to have been involved in this business for over four years, and I look forward to many more. I began my PartyLite business in a search for an alternative career, where I could work around my family obligations. After becoming a consultant, I fell in love with the opportunity it offers to so many different people. The PartyLite company has a great deal of integrity, which is something I especially appreciate. The income I earn has allowed me to pay off debt, live the lifestyle I have always wanted, and save for my children’s college education. The proposals presently being considered by the FTC would make my business much more difficult. They also would make it much more difficult for someone like me to join as a Consultant and start their own independent home-based business. With respect to the references requirement, I sometimes travel long distances throughout the State of Florida to present PartyLite to hosts and guests in their homes. Some of those hosts decide to become consultants after watching me present PartyLite. Requiring a seven-day waiting period would mean that the host cannot begin his or her business when s/he chooses (and for many of them, they are eager to begin immediately). It also means that I would need to make additional trips, sometimes hundreds of miles, in order to complete contracts and issue their starter kits after the expiration of the waiting period. This would be a significant, additional, and unnecessary expense to me. Additionally, it literally would be impossible for me to provide these potential consultants with the names of 10 consultants closest to them geographically, because I don’t personally know all the consultants in those areas. Since we all are independent business people, we don’t have the means to contact or keep lists of all the other PartyLite consultants who may be doing business in any particular region. Further, even if I had that contact information, I would not feel comfortable providing the personal contact information of other consultants to someone who is considering joining PartyLite. Nor would I want my own personal information given out freely by consultants that I do not know and who don’t know me, to people I don’t know. I feel good about sharing PartyLite’s very real business opportunity with others, and want to continue to easily introduce PartyLite to more people who could benefit as I have. The regulations you are proposing would hinder me from doing so – and would hinder others in starting their business in the time-frame they choose. Given the fact that these proposals are pending before the Commission, I have to assume that there are other multi-level marketing companies and consultants out there in the world who are operating without the ethics that I have seen demonstrated consistently throughout PartyLite. I would hope that the FTC could tailor its remedies in a manner that is designed to address those issues or those companies without adversely affecting PartyLite and other reputable direct-selling companies and their consultants. I’m grateful that we have the FTC working to protect average consumers like me, but in this case, you will be working against me, impacting my income, my future and my family’s future. Please reconsider the regulations you are proposing. Sincerely, Cathie Kummer Independent PartyLite Consultant