|Received:||7/16/2006 5:36:35 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Federal Trade Commission Office of the Secretary Room H-135 (Annex W) 600 Pennsylvania Avenue, NW Washington, DC 20580 RE: Business Opportunity Rule, R511993 Jim & Dian Fawver 10255 Dear Sir or Madam: We are writing this letter because we are concerned that the FTC's proposed Business Opportunity Rule (R511993) as currently drafted could destroy the successful small business that we have spent years building. We do understand and appreciate the FTC's responsibility to protect the public from "unfair and deceptive acts or practices," but we feel the rule goes to far in trying to protect the public by proposing burdensome requirements and business activities that would imply to anybody that this is the kind of business to totally avoid. We are distributors for USANA Health Sciences, a publicly traded company that has ethics equal to or better than my former employer, the IBM Corporation. I can't imagine asking an IBM client to wait 7 days before we accept their decision, or before we hire them. But that's what you are asking us to do with the proposed "seven day waiting period." And then can you imagine asking any potential client for IBM to review the IBM lawsuits before selecting an IBM product or accepting a hiring offer? And how about giving the client or potential hire the names and phone numbers of the 10 clients or hires that proceeded them? I have spent the last 30 years of my career in a "Corporate America" culture, mostly in an executive management position. For the last 5 years I have been a distributor for USANA. I can assure you that USANA has the highest of quality in their products, and the highest of ethics in their management philosophy. To impose rules upon an industry that is different than "mainstream America" in not right. Granted, many years ago there were some practices that may have warranted such regulation. The network marketing industry is now very legitimate, and I have found that when an exception to that legitimacy comes along, the state attorney generals are dealing with it very aggressively. Thank you for the work you do, and also for providing a forum for input to you to help you do the right thing. Jim and Dian Fawver Independent Distributors, USANA Health Sciences, Inc.