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<tr><td><b>Comment Number: </b></td><td>522418-13268</td></tr>

<tr><td><b>Received: </b></td><td>9/29/2006 8:02:13 PM</td></tr>

<tr><td><b>Organization: </b></td><td>CONSUMER AWARENESS INSTITUTE - and PYRAMID SCHEME ALERT</td></tr>

<tr><td><b>Commenter: </b></td><td>JON TAYLOR</td></tr>

<tr><td><b>State: </b></td><td>UT</td></tr>

<tr><td><b>Subject: </b></td><td>Business Opportunity Rule</td></tr>

<tr><td><b>Title: </b></td><td>Notice of Proposed Rulemaking</td></tr>

<tr><td><b>CFR Citation: </b></td><td>16 CFR Part 437</td></tr>

<tr><td><b>Attachment: </b></td><td><a href='522418-13268.pdf' target=_blank  title='Click to view attachment'>522418-13268.pdf</a>&nbsp<a href='http://www.adobe.com/products/acrobat/readstep2.html' target = _blank >Download Adobe Reader</a></td></tr></Table>

<hr><P><b>Comments:</b></p>ATTN: FTC Personnel - These comments constitute our rebuttal of the submission (tracking no. 522418-12039) by Joan (“Jodie”) Bernstein, with Bryan Cave LLP, on behalf of Quixtar, Inc., which is essentially Amway recycled to avoid the “Amway stigma”. What is incredible is the fact that the comment is introduced by Jodie Bernstein, the former Director of Consumer Protection for the FTC. Not only did Ms. Bernstein supply the same nickname she used at the FTC, but she addressed her cover letter to Donald S. Clark, the Secretary of the FTC – something the rest of us were firmly instructed not to do, but to send to the Commission without addressing it to a single person. So Ms. Bernstein used her “in” with the Commission to gain undue access. As a consumer advocate, I also find the fact that she is representing Amway/Quixtar absolutely stunning. It makes me wonder what she was doing while acting as Director of Consumer Protection at the FTC. Was she fully engaged or connected with what was going on; viz. the massive fraud committed daily by Amway/Quixtar worldwide? If I had been in her position and been actively involved in consumer protection, Amway/Quixtar could not pay me enough money to have my name associated in any way with Amway. After all, it was Amway that created the “800-pound gorilla in the Commission chambers” (quoting Bruce Craig, former Assist. AG for Wisconsin), when it outfoxed the FTC judge who ruled in 1979 that Amway was not a pyramid scheme, subject to the “Amway rules” – which Amway has thumbed its nose at ever since. And look-alike product-based pyramid schemes or chain sellers have been proliferating ever since, causing millions of consumers to be defrauded out of tens of billions of dollars every year worldwide. Of course, Amway/Quixtar is a member of the DSA, and their comments reflect those of the DSA and member firms. So I am attaching the latest revision of my comments to the DSA and member MLM firms. It is all relevant to this submission and clearly answers their objections to the proposed rule. Sincerely, Jon M. Taylor, Ph.D., President, Consumer Awareness Institute and Advisor, Pyramid Scheme Alert - E-mail: jonmtaylor@juno.com - Web site for MLM research and guides - www.mlm-thetruth.com

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