Special thanks to Len Clements for the permission to post his MarketWave Alert Newsletter…

If you are involved enough in your MLM
business to subscribe to MarketWave Alerts you are probably already aware of
the FTC’s proposed new Business Opportunity Rule that could seriously effect
your ability to do business. If you are new to MLM, check out the details
here:

http://www.ftc.gov/opa/2006/04/newbizopprule.htm

The
FTC accepted public comment about this proposed new rule up until July 17,
2006. Almost 13,000 unique comments were submitted along with over 5,000
form letters. They can be viewed at:

http://www.ftc.gov/os/comments/businessopprule/index.htm

Among
these approximately 18,000 total comments there was, of course, a few from
members of the MLM Haters Club (what I refer to as "Anti-MLM
Zealots"). The vast majority of responders submitted one comment. Robert
FitzPatrick, founder of Pyramid Scheme Alert (PSA), felt the need to submit
five (three as "PSA", two personally). Doug Brooks (anti-MLM attorney)
submitted three, two of which were legal documents pertaining to a settled
class action suit against Herbalife and completely unrelated to the FTC’s
proposed new rule. Dr. Stephen Barrett from QuackWatch and ex-Assistant AG
Bruce Craig (PSA’s go-to guy when it needs to create the illusion of
credibility) both submitted, appropriately, one albeit lengthy comment. MLM
"Survivor" Ruth Carter and "What’s Wrong With MLM" author Dean Van Druff are
surprisingly absent from the comment list. But the always verbose Jon Taylor
more than made up for them by submitting a record eight comments (all under the official sounding name
"Consumer Awareness Institute"). As is his MO, most of it is the same tired,
baseless arguments repeated over and over, and virtually none of it directly
related to the FTC’s proposed new business opportunity rule. Taylor has been
trying to get the attention of the FTC for years and has been utterly
ignored, so the FTC’s comment facility related to this proposed rule was a
great way for him to draw their attention to his anti-MLM manifesto. Being,
for the most part, irrelevant to the specific rule the FTC is seeking
comment on (which applies to all forms of business opportunities, not just
MLM), his anti-MLM propaganda will likely be ignored yet again.

All
of the Anti-MLM Zealots named above are, directly or indirectly, connected
to each other. Their comments in support of the new rule are, not
surprisingly, very similar to one another, in some cases almost verbatim. I
chose exactly 100 other comments at random from the remaining comments
(closed by eyes and just clicked on random spots on the list) and 99% of
them were pro-MLM and against the proposed rule (one was from an ex-MLMers
who used the comment form to vent about her failure, but made no comment
specific to the proposed new rule). I read all 35 representative samples of
the 5,000+ form letters that were submitted and 100% were pro-MLM, and
against the rule.

Now comes the fun part!

We have until
September 29th to submit comments in response to the comments previously
submitted. That means the other 17,995 of us get to submit a rebuttal to
what the five Anti-MLM Zealots had to say. Why should you? Well, because
they’ve actually made a pretty good case to back up their criticisms! The
challenge is that their case only applies to a single, but very large, MLM
company, and they’re doing a masterful job of painting us all with the same
brush! I won’t go into a rebuttal of their arguments or specific expos�s of
each of them now (you can find that HERE), but
suffice it to say the primary, and in many cases the entire, case made
against MLM by these anti-MLMers pertains to factions within Quixtar (aka
Amway), and occasionally past (long since resolved) legal actions against
Equinox, Herbalife and/or Nu Skin. That’s it. They rarely, if ever, relate
any of their attacks to the many hundreds of other MLM programs that don’t do business even
remotely the way that those few they attack do business. For example, the
backbone of their anti-Amway crusade is the multimillion dollar tapes, tools
and seminars business that have made a select few Amway Diamonds mega-rich.
The obvious, easily verifiable fact that 99% of all other MLM companies sell
their tools at or below cost – and offer training seminars for free – makes
no impression on them at all. It doesn’t matter to them. Their belief is
that some organizations within Quixtar do it this way (not even all of
Quixtar), so all MLM companies do it this way and thus should be shut
down.

So this is what we (you) need to focus on in your rebuttal
comments:

1)  Be clear on the specific comment and commenter you
are responding to (reference the Comment Number at the top of the comment
you are rebutting).

2)  Make it clear that those experiences
described by the anti-MLM zealot are an aberration and not typical of your
personal experiences (that is, what happened to them in Amway is not
indicative of what happens to everyone in every other MLM
opportunity).

3)  Don’t insult the FTC by calling them names or
suggesting they, or their proposed rule, is foolish or stupid. Remember, the
FTC isn’t a thing, it’s a group of human beings!

4)  Don’t be
insulting to the person you are rebutting (leave that up to me 🙂 Try to be
professional in your response.

5) Try not to just dismiss the whole
anti-MLM commentary with generic statements like "He’s just wrong" or
"That’s not true". Pick specific points and counter them with logic, facts
and opinions based on your own personal experiences.

Here’s where you
can go to submit your rebuttal comments:

https://secure.commentworks.com/ftc-bizopNPR/

Thanks
for your help in supporting our great industry!

Len
Clements
MarketWave, Inc.