Business Opportunity Rule #522418-12721

Submission Number:
Lorraine Ulrich
Initiative Name:
Business Opportunity Rule
Federal Trade Commission/Office of the Secretary, Room H-135 (Annex W) 600 Pennsylvania Ave., NW Washington, DC 20580 RE: Business Opportunity Rule, R511993 Dear Sir or Madam, I am writing to express strong opposition to the proposed Business Opportunity Rule R511993. I do understand that the Federal Trade Commission must protect the public from "unfair & deceptive acts or practices," but the rule, as proposed, would make it impossible for me to operate my business as a Shaklee Independent Distributor----as I have for over 30 years. If my neighbor Joe wants to sponsor his cousin, who lives in Washington DC----I wouldn't know 10 people who are Shaklee Members who live in his neighborhood in Washington, DC. Nor would I have 10 business builders in his vicinity that I could try to disclose personal information that I could use. I wouldn't be able to sponsor him, and he wouldn't be able to become a business leader and sponsor his cousin in Florida. The 7-day rule is really confusing! The Membership fee is only $19.95, for which they get a 15% discount on product. They sometimes get a free membership with a beginning order. It sounds like that wouldn't even be allowed. We talk with someone, they are interested and want to join, and do it today....look at the air of suspicion that you are introducing!! Also....the proposed rule requires the names of minimum of 10 purchasers nearest the prospective purchaser. In this day of identity thef, I am uncomfortable giving out the personal informaton of other Shaklee distributors. , without their knowlege or consent. Who would want their identity to be passed on to others.....that is ridiculous! Where would we go to get this information...(even if it was a good idea) That would be impossible. What about law suits that the Company has been found innocent. (I'm not sure there have been lawsuits against Shaklee, and they have been around for 50 years) but in this suit-happy environment----it doesn't matter what someone says about you, if they are found innocent......this proposed law wouldn't cover that...rendering the whole concept pretty ridiculous! Your competition could file frivolous law-suits to make the competition look bad. Better re-think that one. I have been in Shaklee for over 30 years. I originally joined because I had been pregnant for 4 yrs (in fact the fourth Daughter was born the day before our 4th wedding anniversary. I got well with the product. Those children grew up, were smart & planned on going to college. We knew we were in trouble. I started a little part-time business two yrs. later which allowed me to help kids through school, one went to Law School and some went to Graduate School----If we had had restrictions like this proposal we would never have made it. If this law goes into effect, I won't be able to pass on that opportunity to others. The rules should NOT apply to business opportunities that cost less than a common household appliance, as is true of the Shaklee opportunity. The PREVIOUS LIMIT WAS $500. The proposed rule would make if $0. We could live with $500. I have been a Shaklee Distributor for over 30 yrs. I originally became a Shaklee Distributor because their nutritional products made me well. Two years later we needed money for college and looked at the opportunity and knew we had found a wonderful, caring, healthy way to earn additional income from I started very part time until I had replacedd my full-time income. I quit my Medical job and built my business from home where I could multi-task and take care of my family better. Now I depend upon this extra income for my livelihood. I work hard at my business and want to share it with others. Thank you for considering my comments. Lorraine Ulrich