A REGULATORY DEPOSITION ON DIRECT SELLING
Richard Bliss Brooke
A Regulatory Deposition on Direct Selling
In this hyper-paranoid regulatory environment for Network Marketing, most companies are running from their roots and seeking creative and reactionary ways of “reinventing” how they do business. Customer-centric is the call sign of the day. Social selling, social retail, and a myriad of other more modern labels are assigned to what we do as a profession. This does not change what we do. Direct Selling/Network Marketing defined: • We sell products to our network. • We often do so just by offering a link for them to order. • Our network is made up of people with whom we are already connected to in some way (warm market). • We only sell products we personally use and love. • Our customers receive a 100%-satisfaction guarantee. • We can earn a modest income doing so. We may also offer our customers the same option of selling the products they love. In fact, the rule that defines Network Marketing is that every customer may also acquire other customers and earn a profit. When every customer may acquire other customers, an exponential growth of sellers is possible.
In fact, the more sellers you have, the more customers you have. And the most ethical and expeditious way to acquire the largest number of customers is to promote the option for each of THEM to acquire THEIR own customers. The political correctors like to say it is called Direct Selling, not Direct Recruiting . Cute. They do not actually understand how the model works. They have probably never built a Direct Sales/Network Marketing business – ergo, a talking blog head. Ninety-eight percent of the “Direct Selling Association” members are actually Network Marketing companies, defined by the fact that their customers may all choose the option of acquiring other customers, creating the exponential growth of the sales organization: 1-4-16-64-256-1024-4096, etc. (No team EVER grows in perfect math, but rather in a random and organic pattern.) And 95% of those who “try” to build a network of customers fail to do so. But some do. Here is the list of Direct Selling Association members and how they define the model of distribution they use: Organization Products/Services: 1. 4Life Research Health/Fitness/Wellness, Nutritional Supplements 2. ACN, Inc. Home Technology, Internet Services, Security Systems/Devices, Telecommunications Services, Utilities 3. AdvoCare International, LLC Health/Fitness/Wellness, Nutritional Supplements, Skincare, Weight Management 4. Aerus LLC (formerly Electrolux LLC) Homecare, Vacuum Cleaners 5. Aloette Cosmetics, Inc. Cosmetics, Haircare/Hair Accessories, Personal Care, Skincare 6. Ambit Energy Utilities
7. Amway Business/Commercial, Health/Fitness/Wellness, Home Technology, Homecare, Nutritional Supplements, Personal Care 8. Arbonne International, LLC Aromatherapy, Cosmetics, Essential Oils, Health/Fitness/Wellness, Nutritional Supplements, Skincare 9. Become International, Inc. Health/Fitness/Wellness, Personal Care, Skincare 10. Big Planet (Division of Nu Skin Enterprises) Internet Services, Telecommunications Services 11. Boisset Collection Clothing/Shoes, Fashion Accessories, House and Kitchenwares, Party Supplies, Tableware, Wine/Wine Accessories 12. Calerie Health Holding LLC Nutritional Supplements 13. Carico International Air Filters/Air Filtration Systems, Cookware, Crystal/China, Cutlery, House and Kitchenwares, Tableware, Water Treatment Systems 14. CUTCO/Vector Marketing Corporation Cutlery, House and Kitchenwares 15. Damsel in Defense Security Systems/Devices 16. DAXEN, INC. Coffee/Tea/Specialty Beverages, Cosmetics, Health/Fitness/Wellness, Nutritional Supplements, Personal Care, Skincare 17. Dudley Beauty Corp, LLC Cosmetics, Fragrances, Haircare/Hair Accessories, Skincare 18. Enagic USA Inc. Water Treatment Systems 19. ENERGETIX GmbH & Co. KG Health/Fitness/Wellness, Jewelry 20. Enzacta USA Nutritional Supplements 21. Essential Bodywear Lingerie/Sleepwear 22. Forever Living Products Health/Fitness/Wellness, Nutritional Supplements, Personal Care, Weight Management 23. Global Domains International, Inc. Home Technology, Internet Services, Software/Computers 24. H2O at Home Aromatherapy, Essential Oils, Green/Organic/Eco- Friendly, Health/Fitness/Wellness, Homecare, House and Kitchenwares, Personal Care, Skincare 25. Health-Mor (An HMI Industries Inc. Company) Air Filters/Air Filtration Systems
26. Herbalife Nutrition Health/Fitness/Wellness, Nutritional Supplements, Personal Care, Skincare, Weight Management 27. Hy Cite Enterprises, LLC Cookware, Water Treatment Systems 28. Immunotec Research Inc Health/Fitness/Wellness, Nutritional Supplements, Personal Care 29. Initials, Inc. Baby/Childcare, Fashion Accessories, Giftware, Home Accessories/Décor, House and Kitchenwares 30. Isagenix International Essential Oils, Health/Fitness/Wellness, Nutritional Supplements, Personal Care, Skincare, Weight Management 31. JAFRA Cosmetics International, Inc. Cosmetics, Fragrances, Skincare 32. Java Momma Coffee/Tea/Specialty Beverages 33. jBloom Designs Jewelry 34. Jeunesse Global Essential Oils, Nutritional Supplements, Skincare 35. John Amico Haircare Products Essential Oils, Haircare/Hair Accessories, Personal Care 36. Jordan Essentials Aromatherapy, Cosmetics, Essential Oils, Fragrances, Green/Organic/Eco-Friendly, Personal Care, Skincare, Spa Products 37. Kirby Homecare, Vacuum Cleaners 38. Kyäni, Inc. Nutritional Supplements 39. L’BRI PURE n’ NATURAL Cosmetics, Skincare 40. Lemongrass Spa Products Cosmetics, Essential Oils, Skincare, Spa Products 41. Lifestyles USA Haircare/Hair Accessories, Health/Fitness/Wellness, Nutritional Supplements, Skincare, Weight Management 42. LifeVantage Animal/Pet Care, Health/Fitness/Wellness, Nutritional Supplements, Skincare, Weight Management 43. Mannatech, Inc. Nutritional Supplements, Skincare, Weight Management 44. Market America, Inc. Autocare, Homecare, Internet Services, Nutritional Supplements, Personal Care 45. Mary Kay Inc. Cosmetics, Skincare 46. Medifast Health/Fitness/Wellness, Weight Management 47. Melaleuca, Inc. Homecare, Nutritional Supplements, Personal Care
48. Modere Animal/Pet Care, Haircare/Hair Accessories, Health/Fitness/Wellness, Nutritional Supplements, Oral Hygiene, Personal Care, Skincare, Weight Management 49. Nefful U.S.A., Inc. Fashion Accessories, Lingerie/Sleepwear, Nutritional Supplements 50. NeoLife International, LLC Haircare/Hair Accessories, Health/Fitness/Wellness, Homecare, Nutritional Supplements, Personal Care, Skincare, Weight Management 51. Neora, LLC Skincare 52. New Earth Life Sciences Health/Fitness/Wellness, Nutritional Supplements, Skincare 53. NewAge Essential Oils, Haircare/Hair Accessories, Health/Fitness/Wellness, Nutritional Supplements, Personal Care, Skincare, Spa Products, Weight Management 54. NHT Global, Inc. Cosmetics, Health/Fitness/Wellness, Nutritional Supplements, Skincare, Weight Management 55. Noevir USA, Inc. Cosmetics, Haircare/Hair Accessories, Nutritional Supplements, Personal Care, Skincare 56. Noonday Collection Fashion Accessories, Home Accessories/Décor, Jewelry 57. Nu Skin Enterprises Cosmetics, Haircare/Hair Accessories, Health/Fitness/Wellness, Nutritional Supplements, Oral Hygiene, Personal Care, Skincare, Spa Products, Weight Management 58. NYR Organic Aromatherapy, Baby/Childcare, Candles/Candle Accessories, Cosmetics, Fragrances, Green/Organic/Eco-Friendly, Haircare/Hair Accessories, Nutritional Supplements, Personal Care, Skincare, Spa Products 59. Omnilife USA, Inc. Cosmetics, Health/Fitness/Wellness, Nutritional Supplements, Skincare 60. Orenda International, LLC Nutritional Supplements 61. Pampered Chef Cookware, Cutlery, Food/Gourmet Items, Home Appliances, House and Kitchenwares 62. pawTree Animal/Pet Care 63. Pharmanex (Division of Nu Skin Enterprises) Nutritional Supplements, Weight Management
64. Plexus Worldwide Inc. Weight Management 65. PM-International AG Health/Fitness/Wellness, Nutritional Supplements, Skincare 66. Primerica, Inc. Financial Services 67. Princess House, Inc. Cookware, Home Accessories/Décor, Tableware 68. Pure Haven Essential Oils, Homecare, Personal Care 69. Regal Ware, Inc. Cookware, Cutlery, Tableware, Water Treatment Systems 70. Reliv International, Inc. Nutritional Supplements, Personal Care 71. Rena Ware International, Inc. Cookware, Water Treatment Systems 72. Rexair LLC Homecare, Vacuum Cleaners 73. Rodan + Fields Skincare 74. Sabika, Inc. Jewelry 75. Saladmaster (Regal Ware, Inc.) Cookware 76. Sanki Global LLC Nutritional Supplements 77. Scentsy, Inc. Candles/Candle Accessories, Essential Oils, Fragrances, Home Accessories/Décor 78. SeneGence International Cosmetics, Personal Care 79. Shaklee Health/Fitness/Wellness, Homecare, Nutritional Supplements, Personal Care, Skincare, Water Treatment Systems, Weight Management 80. SimplyFun, LLC Toys/Games 81. Southwestern Advantage Books, Software/Computers 82. Stampin' Up! Rubber Stamps, Scrapbooking/Photo Albums 83. Steeped Tea Inc. Coffee/Tea/Specialty Beverages 84. Sunrider International Cosmetics, Essential Oils, Homecare, Nutritional Supplements, Personal Care, Skincare 85. SwissJust Aromatherapy, Cosmetics, Essential Oils, Fragrances, Health/Fitness/Wellness, Homeopathics, Personal Care, Skincare 86. Talk Fusion Internet Services, Telecommunications Services, Videos 87. Tastefully Simple, Inc. Food/Gourmet Items 88. Team Beachbody Nutritional Supplements, Sporting Goods
89. The Avon Company Clothing/Shoes, Cosmetics, Fashion Accessories, Fragrances, Giftware, Health/Fitness/Wellness, Holiday Decorations, Jewelry, Lingerie/Sleepwear, Oral Hygiene, Personal Care, Skincare 90. The Body Shop at Home USA, LLC Personal Care, Skincare 91. The Juice Plus+ Company, LLC Essential Oils, Nutritional Supplements 92. Thirty-One Gifts Fashion Accessories, Giftware, Home Accessories/Décor, Stationery/Paper Products 93. Touchstone Crystal, Inc. Jewelry 94. Trades of Hope Clothing/Shoes, Fashion Accessories, Home Accessories/Décor, Jewelry 95. Traveling Vineyard Wine/Wine Accessories 96. Tristar Enterprises, LLC Vacuum Cleaners 97. USANA Health Sciences, Inc. Haircare/Hair Accessories, Health/Fitness/Wellness, Nutritional Supplements, Oral Hygiene, Personal Care, Skincare, Weight Management 98. Usborne Books & More Baby/Childcare, Books, Educational Materials, Encyclopedias, Toys/Games 99. Vollara, LLC Air Filters/Air Filtration Systems, Health/Fitness/Wellness, Home Technology, Homeopathics, Nutritional Supplements, Personal Care, Skincare, Water Treatment Systems, Weight Management 100. WineShop At Home Food/Gourmet Items, Party Supplies, Tableware, Wine/Wine Accessories 101. World Book, Inc. Educational Materials, Encyclopedias 102. Xyngular Nutritional Supplements, Weight Management 103. YOR Health Essential Oils, Nutritional Supplements 104. Young Living Aromatherapy, Cosmetics, Essential Oils, Food/Gourmet Items, Haircare/Hair Accessories, Health/Fitness/Wellness, Nutritional Supplements, Oral Hygiene, Personal Care 105. Younique Clothing/Shoes, Cosmetics, Fashion Accessories, Jewelry 106. Zurvita Health/Fitness/Wellness, Nutritional Supplements, Weight Management
The politically correctors shame us for speaking to an income option as the motive for selling the products. They would like the world to believe that
customers ought to just promote the products they love just because they love them. In actuality, our data proves that customers who do NOT have a financial incentive to do so, do not offer links for others to order, nor do they promote the products with a call to action for others to order. Customers just use the products. Ambassadors, Brand Partners, Brand Promoters, Coaches, Stylists, Educators, Social Sellers, and a bunch of other creative labels all define "distributors"... people who are selling the products for profit. There are two ways to earn profits in Network Marketing. One, acquire new customers personally. Two, build a team of sellers who do the same. The first way does not scale. The second way scales exponentially. The first has a minimal profit upside. The second has an unlimited upside. The political correctors would have us only promoting the way with the least income potential. The political correctors are champions of transparent, truthful and ethical representations. In this we are in lockstep. Hype, lying, manipulation, and false promises and innuendo are all fraud. We as a profession must move powerfully to the truth, and we must be held accountable to do so. I wonder if the truth can cut both ways. Have I represented Direct Selling and Network Marketing truthfully here? Could we all embrace these truths as we educate regulators, the media, and the public about how we do business?
Imagine a deposition where I interview the FTC. These are yes or no questions, just as it would be in a real deposition. 1. Is recruiting in Network Marketing illegal? 2. Is recruiting a lot of people in Network Marketing illegal? 3. Is recruiting a sales team quickly in Network Marketing illegal? 4. Is there a law that specifies what percentage of your customers in Network Marketing may also earn an income by acquiring other customers (distributors)? Customer/Distributor ratio? 5. Is it sufficient transparency and ethics to show a truthful, accurate and candid Income Disclosure Statement showing how much gross income before expenses each rank earns, how long it took to earn it, and what percent of all distributors earn what incomes? 6. Are customers who never choose to or attempt to sell the products considered distributors? 7. Should the IDS then include customers or just distributors? 8. Is the pursuit of financial freedom in the USA illegal? 9. Is attempting to retire from a full-time job illegal? 10. Is pursuing or earning residual (semi-passive) income illegal? 11. Is it possible for a Network Marketing sales leader to build a team and community of repeat customers, such that the majority of said sales leader's income is generated from customers that sales leader did not personally acquire and does not personally maintain as a customer? 12. Do you know how many years generations of families have been repeat monthly customers of NeoLife products? Shaklee? Nature's Sunshine? Arbonne? Amway? Herbalife? Natura? Avon? 13. Is it illegal for Network Marketing companies to offer luxury cars and vacations as incentives? 14. Is it illegal for sales leaders to earn those incentives? 15. Is it illegal for a sales leader to post pictures of said trip or car on social media? 16. Is it illegal for a sales leader to pursue earning as much income as possible?
17. Is it illegal for a sales leader to coach and train a sales leader on their team to earn as much income as possible? 18. Is it illegal for a sales leader to encourage, edify, champion, and generally be a positive influence for sales leaders who want to be as successful as possible, as long as such communication keeps an accurate IDS in context? 19. If you had a child with a dream of becoming an Olympic medalist or professional athlete, would you encourage them, invest in them, and be willing to lose money in their quest, while being honest with them about the risks? 20. Or would you encourage them to limit their dream to as small an impact/income and achievement as possible so as to minimize their risk? Would you focus all of your education for them on the people who failed, the odds against them, and those who cheated along the way? No further questions. If you want to tell the truth about Direct Selling, then let's tell the whole truth. Yes, fraud and abuse of the consumer is part of the history of Direct Selling. It tends to come with a capitalist, free-enterprise society.
Do you do business with any of these companies? Here are some answers to us coming together to Be the Truth . Network-Marketing-Manifesto2.0 Direct Selling Certified
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