Business Opportunity Rule #535221-00119

Submission Number:
Len Clements
MarketWave, Inc.
Initiative Name:
Business Opportunity Rule
Please disregard, and omit from the comment list, my previous comment. This was in regard to a request to extend the comment period so additional responses could be included in this public list (although not part of the official record). Since comments are still being accepted for posting within the public record my previous comment is now moot. In response to the FTC's decision to omit all MLM companies from consideration per the Revised New Business Opportunity Rule, I first commend your thoughtful and fair decision. However, there is language that remains within the revised rule that can still inadvertently capture MLM programs within the net cast by this revised new rule. The specific language has been spelled out quite well by previous commenters Babener (#535221-00071) and DSA (#535221-00050) so I will not repeat it here. However, I concur with their suggestion that there should be specific language within the New Rule that categorically declares MLM companies to be outside the scope of this New Rule. Further incentive to include such definitive language can be found in the online commentary published by various anti-MLM propagandists who are suggesting that such ''hidden'' language was left in the revised new rule deliberately by the FTC to lull the MLM industry ''into a false sense of security'' in preparation for its eventual regulatory slaughter. Thank you for considering the addition of this suggested new language. Len Clements (court certified multilevel marketing expert), Founder and CEO, MarketWave Inc.