Rebuttal Comments Comment 535221-00038 submitted by Alticor - Used the words in reference to the proposed rule being used 'against MLMs that engage in deceptive or unfair practices' and 'significant concern that some pyramid schemes masquerade as legitimate MLMs' applies to the Alticor/Amway/Quixtar (A/A/Q) family of companies. As you know from my previous posts, this business masquerades as a legitimate business, but in reality they have allowed the 'kingpin' IBO's to rip off their downline groups via the tool scam to the point you have to have over 100 other IBO's in your group (getting similarly ripped off by the tool scam) prior to breaking even, thus creating 100 new financial victims. The UK has stopped this madness, it is time the FTC does the same for U.S. IBO's. A/A/Q's silence on this key issue is unconscionable, which is the same word several U.S. Federal judges have used to describe the A/A/Q ADR (arbitration dispute resolution) process, which is required to be followed, thus IBO's having no meaningful recourse, as the same 'kingpins noted above also control this process. I have been invited by Quixtar to enter the ADR process in this and other matters, and I informed them verbally and in writing I consider the ADR process to be similar to being invited to a Dracula convention with an open wound. In other words, it's fixed and would be a bloodbath, my blood. As I have already shown A/A/Q NOT to be an MLM because of the tool scam, I agree with A/A/Q's statement to "strongly support the FTC's efforts to protect consumers and prospective purchasers of business opportunities from pyramid schemes and other deceptive practices.", as A/A/Q with the tool scams clearly are both pyramid schemes and other deceptive practices." I consider A/A/Q with the tool scams so bad I would gladly join A/A/Q as desiring "to continue to work with the FTC in deveioping rules that strengthen the FTC's ability to catch nefarious actors.", and A/A/Q needs to look into a mirror to fix their own house prior to considering other such companies. Comment 535221-00063 submitted by Stephen Barrett, comments 535221-00006/57 submitted by Jon Taylor, 535221-00064 by Justin Durand, 535221-00001/79 by Reid Parrington, comment 535221-00040 submitted by Robert FitzPatrick, and comment 535221-00080 submitted by Tom Summerhays, I find to be a crackpots who do not understand MLM, and probably business in general. I don't know much about other MLM's, but A/A/Q is a solid business model, made bad by the tool scammers mentioned above and in previous comments. 535221-00050 by the DSA - The DSA has been non-responsive to me, indicating they are examining "lessons learned" regarding the UK shutdown of the tool scam. I reminded them the lesson was taught in 1983 by Rich DeVos' "Directly Speaking" tapes, referenced in previous comments, so it's quite late to be learning the lesson a quarter century later. I've heard of "the wheels of justice grind slowly, but this is ridiculous. I concur with comment 535221-00075 submitted by Peter Mingils. At the very least, telephone interviews should be conducted to ensure you have a full, complete, and accurate understanding of the previously mentioned tool scam.