by on May 16, 2012 1 Comment

Herbalife, USANA and Big Shorts

David Einhorn, hedge fund manager for Greenlight Capital, rocked the MLM industry when he publicly asked Herbalife’s CEO about the company’s customer numbers.  During an earnings call, Einhorn asked, ”So what is the percentage that is actually sold to consumers that are not distributors?”  Herbalife’s CFO, Desmond Walsh, responds by saying, “So we don’t have an exact percentage, David, because we don’t have visibility to that level of detail.”

Shortly after the conversation, Herbalife’s stock plummeted 20%, resulting in approximately a $1.7B loss in value.  Immediately, people in the industry perceived this as some sort of an attack on the industry.  It even prompted a statement from the DSA.  In the statement, the DSA defended the practice of paying commissions on internal consumption (full statement below).  Here’s the issue I have with the DSA’s reaction: Einhorn never questioned the legality of paying commissions on internal consumption.  It has already been established, time and again, that it’s perfectly legal to pay commissions on distributor volume.  Instead, Einhorn’s decision to short the stock was basically a vote of “no-confidence.”  Based on how he bet his money, he senses a weakness in a business with anemic customer numbers.  It was a simple question, he got a squirrelly answer, he jumped ship and a boat load of people followed.  I didn’t sense anything nefarious.  He’s a capitalist, perceived a weakness, took a risk by shorting the stock and made a lot of money.

Being a publicly traded company, the percentage of customer volume is material information. Unlike what Herbalife’s CFO suggested, it’s certainly not impossible to obtain that sort of information.  I would agree that it’s impossible to produce an exact figure; however, a general sense should definitely be provided.  Today, when the customer can go directly to a replicated website and order product, there’s certainly some concrete information that’s immediately available.  As for the people that sell product face to face, it’s not hard to do a survey of a segment of the sales force and / or require that people self-report their customer sales.  The data is important and Herbalife, along with other publicly traded MLMs, should provide it in my opinion.

As for USANA, they got hosed

We’re dealing with a different set of facts with USANA.  In USANA’s case, Shortzilla, a popular site for short stock ideas, announced its short position on USANA stock shortly after watching the Herbalife drama unfold.  Instead of just asking a simple question and trading accordingly, the article on Shortzilla proceeds to make a lengthy argument that USANA operates as an illegal pyramid scheme; thus, justifying its decision to short the stock.  Check out Ted Nuyten’s site, Business for Home, for a complete report on the USANA short.  In the article, the author makes a number of factual assumptions and really mischaracterizes the legal standards distinguishing legitimate network marketing companies from MLMs.  The article smelled like it was outcome-determinative i.e. he wanted to trash USANA to further support the short position. The Shortzilla article, in my opinion, was a self-serving attack.

Conclusion

I’ve long been writing about the importance for strong customer numbers.  I’ve gone so far to write that we, as an industry, are deluding ourselves by pretending there’s not a problem.  Throughout my career in the industry, I failed to appreciate arguably the most powerful lever that will eventually lead to positive change: the market. While most companies in the space are not publicly traded, the ones that are will be pressured to provide some strong customer metrics in order to build investor confidence. Investors are getting educated.  Instead of re-hashing legal principles about the legitimacy of paying commissions on downline consumption, we need to be having a more serious conversation about ways to improve the space to improve confidence in the overall marketplace.

DSA’s Statement

WASHINGTON, D.C.—As the association representing more than 200 leading firms that manufacture and distribute goods and services sold directly to consumers, the Direct Selling Association (DSA) would like to set the record straight in response to questions raised about the direct selling business.

Unfortunately, even though the direct selling industry has definitively demonstrated the propriety of internal consumption to the regulatory community, stock prices of Herbalife and other publicly traded direct selling companies fell as a result of inquiries by hedge fund manager David Einhorn.

First and foremost, the direct selling business model is solid and strong. After falling slightly in the wake of the Great Recession, total industry sales grew nearly one percent in 2010 and are expected to show even stronger gains when 2011 numbers are announced in early June. Most publicly traded companies reported strong earnings and income in 2011.

Nearly 16 million Americans engaged in direct selling in 2011, some as full-time entrepreneurs seeking to build a business and some as part-time representatives hoping to earn a little extra money. Others sign up as representatives simply to purchase products or services for their own use at a discount and never sell to anyone else. Regardless of their income expectations, almost all direct sellers use the products themselves. This is what is known as “internal consumption.”

As the Federal Trade Commission (FTC) stated in a January 2004 Staff Advisory Opinion, internal consumption is not considered to indicate impropriety. Instead, “the critical question for the FTC is whether the revenues that primarily support the commissions paid to all participants are generated from purchases of goods and services that are not simply incidental to the purchase of the right to participate in a money-making venture.”

In short, what the FTC watches for—and what the DSA Code of Ethics is designed to protect against—are compensation systems that are funded primarily or exclusively by payments made for the right to recruit other participants. Compensation must primarily be based on the sale of products and services to the ultimate consumer—whether or not that consumer is also a seller of the products.

Unfortunately, direct sellers have been targeted in the past by short sellers who have deliberately injected inaccurate information or rumors into the marketplace with the goal of driving down stock prices for financial gain. In the end, it is the millions of hardworking American direct sellers who suffer the results of these attacks while the perpetrators walk away with millions in profit. DSA exists to protect and promote the direct selling industry by educating policymakers, the business community and the general public about the nature of the industry and how it works; and ensuring DSA member companies behave ethically in all aspects of their businesses through enforcement of the DSA Code of Ethics.

Filed Under: MLM Consulting, MLM News, MLM startup Tagged With: , , , ,
by on May 7, 2012 1 Comment

Living the Island Life and 7 Traits of Successful Companies

IMG 3404I had the privilege of speaking at the Island Life launch party in Cocoa Beach, Florida. It was an exciting trip! I packed up the family and made a little vacation out of it. Buca and I have been friends for a couple of years and I was excited to hear the news about he and his partner starting their own company. Buca will tell you straight up, the Island Life culture is not for everyone. When the first item on the itinerary was a BBQ with an ocean view and the last item was a karaoke costume party, it was pretty apparent that Buca was injecting his signature in the DNA of the business. Because he’s so focused on a unique distributor experience, it just might work.

I also had the pleasure of hanging out with Doug Wead, networking great and Senior Advisor to the Ron Paul campaign.

At the event, I gave a talk about the seven traits successful companies have in common. I threw together the video below to serve as the highlights. It’s not the best production quality but I think you’ll enjoy the content. I’ll package this in a more professional manner in the future and re-ship. But for now, catch a glimpse. The seven traits are also listed below. Take care, for now.

1) Leadership
2) Product
3) Design
4) Systems
5) Compliance
6) Capital
7) Field

Filed Under: MLM startup, MLM Video Blog Tagged With: , , , ,
by on April 27, 2012 Leave a Comment

ACES Radio Live With Troy Dooly and Jim Gillhouse

When both Troy Dooly and Jim Gillhouse call me to be a guest on their program, I jump every single time. They ask great questions and lead fantastic conversations on their program.

During this episode, we talk about the troubling language in the final BurnLounge order. Feel free to listen and share your thoughts below.  Already after this interview, I’ve been a part of some great conversations about the future of the space.  It’s a very healthy discussion.  

Listen to internet radio with ACES Radio Live on Blog Talk Radio
Filed Under: Distributor Resources, mlm attorney, mlm legal, MLM News Tagged With: , , , , , , , ,
by on April 17, 2012 1 Comment

Pokorny / Amway Settlement Explained

It’s official. The long fought Pokorny Class Action lawsuit has finally been resolved. Unlike the last Pokorny / Quixtar settlement, which was delayed by the judge (or denied, depending on who you ask), this one seems to be sticking. If you were a Quixtar IBO between January of 2003 to February of 2012, you might be eligible to take a slice of the settlement pie. The official settlement page with instructions can be found here. I’ve summarized the key ingredients of the settlement below. I’ve also included direct quotes from the settlement beneath my summary.

If you learn something here, show some google love and hit the +1 button above.

In Summary

Amway must:

1) Provide 90 refund period for registration fees;
2) On registration forms, explain that income claims provided to prospects represent gross, not net income; explain the availability of free training; explain the refund policy; explain the availability of retail prices on-line;
3) Maintain policies prohibiting tactics which require people to buy tools (Business Support Materials, or “BSM”) upon enrollment;
4) Enforce its retail sales rule. As stated in the settlement, they must use “reliable reported levels of sales to end-user consumers.”;
5) 5% price reduction from the 2007 pricing levels;
6) Increase its IBO training budget by $7M over 2007 levels. Such training must be provided for free to its IBOs;
7) Maintain and enforce quality control over BSMs. The standards must prevent BSMs from making misrepresentations about the Amway business;
8 ) $55M in economic relief with $34M going to a cash (reimbursements) fun and $21M going towards a product credit fund (free schwag);
9) With the cash fund, Amway must provide a cash payment of up to 20% of the IBO’s “verifiable net BSM expenditures.” The cash payment is capped at $2,000. In other words, if you spent $10,000 on tools between 2003 and 2012, you could be eligible for a $2,000 check.
10) Upon a showing of a Special Hardships i.e. bankruptcy attributable to Amway or a loss of at least $10,000, an individual can be eligible for more money (with a $10,000 cap).

CONSENT JUDGMENT & ECONOMIC RELIEF (abridged)

5.1.1 Quixtar shall modify its agreements with its IBOs to provide not less than a 90-day refund period for registration fees. The 90-day refund period for an IBO’s registration fees will begin from the time that Quixtar receives the registration fee from the IBO.

5.1.2 The application form that new IBOs are required to execute to register as a Quixtar IBO shall disclose the following information: (a) that income figures provided to potential IBOs represent gross, not net income; (b) the availability of certain free company provided training for IBOs in marketing and merchandising; (c) Quixtar’s refund policies for products purchased by IBOs; (d) the availability of a retail product price list schedule accessible on-line; and (e) that product purchases and purchases of BSM are optional.

5.1.3 Quixtar shall: (1) not compensate any IBO primarily for the act of recruiting or registering other IBOs; and (2) not require any IBO to purchase or maintain any specified amount of inventory of products or BSM. In addition, Quixtar shall maintain policies prohibiting acts or practices which require a person to buy BSM as a condition to becoming an IBO and prohibiting acts or practices which discourage buy backs of product on commercially reasonable terms. In addition, when making sales based bonus payments or incentives to IBOs who are below the Platinum PIN level, Quixtar will emphasize consumer sales by conditioning such bonus payments and incentives on reasonably reliable reported levels of sales to end-user consumers. (The phrase “end user consumer” means any individual who intends to use or uses Quixtar products.) Quixtar shall maintain policies prohibiting Quixtar, its IBOs, and companies that are authorized by Quixtar to provide training and support to IBOs from making statements or representations or taking actions contrary to (i) the application form referenced in Paragraph 5.1.2 above; (ii) the requirements of applicable state and federal law; or (iii) the requirements of Paragraphs 5.1.2, 5.1.3, or 5.1.6 of this Settlement Agreement. Quixtar shall not be liable for contempt of the Consent Judgment solely on the grounds that Quixtar’s policies are breached by its IBOs or others.

5.1.4 Quixtar will maintain for twenty-four months from the Effective Date or from June 30, 2011, whichever occurs first, a price reduction that averages at least 5% from January 2007 pricing levels to distributors across Quixtar-branded products (existing SKUs, excluding freight). . . .

5.1.5 Quixtar will increase its annual IBO training budget for product, product merchandising, business skills . . . by an average of $7 million or more over 2007 levels for twenty-four months from the Effective Date . . . such training to be provided free to IBOs.

5.1.6 Quixtar will maintain and enforce quality control over BSMs that are: (1) sold or distributed by Quixtar IBOs or by companies authorized by Quixtar to provide training and support to IBOs and (2) sold or distributed in a manner suggesting sponsorship, affiliation or approval by Quixtar. Quality control shall include standards that are designed to prevent BSMs from making factual assertions regarding the Quixtar business that contain either material misrepresentations or omissions that render a statement materially misleading. Quality control shall provide that BSMs comply with the standards and policies contained in Paragraphs 5.1.2, 5.1.3, and 5.1.6 of this Settlement Agreement. . . .

. . .

5.2 Economic Relief Quixtar shall provide a total of $55 Million in direct economic relief (in addition to the economic value to the Settlement Class of the injunctive relief described in Subsections 5.1.1-5.1.6 above). The $55 Million in direct economic relief shall constitute a common fund composed of: (1) a $34 Million Cash Fund; and (2) a $21 Million Product Credit Fund.

5.2.1 $34 Million Cash Fund: within ten (10) business days after entry by the Court of the Preliminary Approval Order, Quixtar shall deposit the sum of thirty-four million dollars ($34,000,000.00) (the “Cash Fund”) into an interest-bearing escrow account for an anticipated distribution to Settlement Class Members and to pay administrative costs, costs of class notice, and attorneys’ fees and expenses pursuant to this Settlement Agreement and the Court’s orders. . . .

5.2.2 $21 Million Product Credit Fund: Quixtar shall provide $21 Million in free product for benefit of the Settlement Class (“Product Credit”). . . .

6. ALLOCATION OF CASH FUND AND PRODUCT CREDIT

6.1 Cash Fund. The $34 Million Cash Fund shall be distributed as follows:

6.1.1 Cash Payments. Subject to other terms herein, Settlement Class Members who are former IBOs as of the date of this Settlement Agreement, including the named Plaintiffs, with the exceptions set forth below, who have at least $100 in Verifiable Net BSM Expenditures are entitled to a cash payment of up to 20% of their Verifiable Net BSM Expenditures, up to a maximum recovery of $2,000 per claimant, or an appropriately pro-rated amount under Paragraph 6.1.4. To obtain this cash refund, Settlement Class Members must submit to the Claims Administrator the approved Claim Form together with documentation of their Verifiable Net BSM Expenditures within a 90-day refund period as specified in the approved form of Notice. The Claims Administrator may accept receipts, credit card records, or other proof of purchase as documentation.

6.1.2 Special Hardships. Settlement Class Members who are former IBOs as of the date of this Settlement Agreement, including the named Plaintiffs, who either (i) can show that their recruitment into and operations of their Quixtar business caused them to file for personal bankruptcy or (ii) can show a loss of at least $ 10,000 from operating their Quixtar business, may apply for a special hardship award not to exceed 20% of their loss. A Special Master, who shall be appointed by the Court with input from Plaintiffs’ Counsel and Quixtar at the time of final approval of the Settlement Agreement, shall determine whether each claimant for a special hardship award has made this showing. The Special Master shall then prepare a schedule of recommended special hardship awards, if any, to each claimant and submit the schedule to the Court for final approval of the awards. The special hardship awards shall be governed by the following:

a. No individual shall receive a special hardship award greater than $ 10,000.

. . .

Full Settlement Below

Quixtar / Pokorny Settlement Agreement

Filed Under: Distributor Resources, mlm attorney, mlm legal, MLM News Tagged With: , , , , , , , , , ,
by on April 14, 2012 Leave a Comment

Direct Sales Model Discussed on TechCrunch

Jeremy Lieu, managing direct at Lightspeed Venture Partners, wrote a fantastic guest post on TechCrunch about the direct sales model.  The article is titled “Is Direct Selling The Next Driver of Startup Commerce Companies?”  In the article, Jeremy highlights three reasons why direct sales is being “invigorated” in this new economy.  It’s great to see venture firms take notice at the amazing power the industry offers.  In January, I wrote about ViSalus’s amazing success.  When venture firms like Blythe and Lightyear place successful bets on MLM startups, it’s attracts more capital for the space, which raises the bar for everyone.  In Lieu’s article, the three key reasons for the uptick in direct sales are:

First, the sluggish economy.  He writes, “In this slow economy, people are more willing to supplement their income (and seek alternative career paths) than they have been over the last few decades. Direct sales is one of the most attractive and accessible ways for people to supplement their income.”

Second, the rise of social media.  He writes, “When you add Twitter and Facebook, that is a tremendous reach for an average person. Direct selling is all about selling through your network – friends and friends of friends. The social networks make this whole network far more visible, and accessible, than ever before.”

Third, technology.  He writes, “These devices, combined with lightweight SaaS ERP, CRM and SFA software, dramatically improve the productivity of direct sales reps.”

Check out the article here.  This is great visibility for the industry.  At the end of the article, several direct sales companies were referenced.  They all have one thing in common: they were all companies with merchandising cultures i.e. focus on product.  The companies referenced were Stella and Dot, Chloe and Isabel, Gigi Hill, Miche Bags, J Hilburn and Thirty One Gifts.

 

Filed Under: Distributor Resources, mlm attorney, MLM News, MLM startup Tagged With: , , , , , , , , , ,
by on April 9, 2012 10 Comments

Self Deception: a cancer holding the MLM industry back

It’s a strong title, I know.  But it’s true.  We all suffer from “self deception” to a certain extent.  It’s a trick we play on ourselves to shift accountability. We tell ourselves that we’ll start that diet….next week.  We tell ourselves that we lack the time to read and learn new skills.  We tell ourselves that exceptional people are just born exceptional.  We tell ourselves that we need just a little more education and work experience before we start our own businesses.  We give ourselves every possible excuse to maintain our view of the world.  Change is scary.  It hurts; hence the saying “no pain, no gain.”  Yet, there’s no way around it.  Change is a prerequisite for progress.  Strong leadership is required to ensure that the RIGHT kind of change is being pursued.  Right now in the MLM industry, we’re heading in the wrong direction, in my opinion.  I’m just calling it like I see it.  I’ll admit, I’m part of the problem.  I’ve got leadership positions and I’ve done a poor job at communicating the scope of the problem.

So what’s the problem?

We need clearer standards.  The MLM industry is cloaked in a veil of ambiguous law where there’s an ocean of gray separating legitimate companies from pyramid schemes.  I was prompted to write this article based on the industry’s response to the BurnLounge Final Order (click here for a summary of the BurnLounge decision).  Since BurnLounge’s fate was officially sealed when the final order hit last month (pending an appeal), people are now figuratively saying “yeah, I always knew those guys were really stupid.  After all, their product could not really stand on its own in the marketplace.”  (See comment above about self deception).  And now, people are rightfully unnerved by some verbiage in the BurnLounge order.  In particular, the Order defines a “Prohibited Marketing Scheme” as:

[A]n illegal pyramid sales scheme . . . in which participants pay money or valuable consideration in return for which they obtain the right to receive rewards for recruiting other participants into the program, and those rewards are unrelated to the sale of products or services to ultimate users.  For purposes of this definition, a sale of products or services to ultimate users€ DOES NOT include sales to other participants or recruits or to the participants own accounts. (emphasis mine).

In other words, according to this Order, it’s illegal to pay commissions on volume consumed by other participants in the downline. This is a practice EVERYONE does, across the board. In fact, in it’s advisory letter to the DSA, the FTC has stated this is fine.

Consequence of the BurnLounge Order?

Before you lose sleep over the BurnLounge Order, keep in mind this definition is not automatically binding for future decisions.  It has no authoritative value beyond this Order.  But what if a judge with an axe to grind against the industry wants to adopt a similar interpretation of “Illegal Pyramid Scheme?”  And what about your future customers?  What if they come across this definition?  It could easily be interpreted as the law of the land, causing more confusion and disharmony in the industry.  Someone could very easily read it and falsely think, “Huh, that makes sense.” Whether it carries authoritative value or not, I’m not comfortable with this definition inked on an Order.

But here’s the kicker.  Given the ambiguity in the law, what do we expect?  What IS the definition of a pyramid scheme? It’s basically been boiled down to a “you know it when you see it” test.  Universally, we all agree that products in the industry need to have the ability to stand on their own in the marketplace irrespective of the compensation plan.  So we all admit that there’s needs to be SOME revenue attributable to outside customers i.e. people unaffiliated with the program.  In the BurnLounge case, only 3% of its revenue came from customers.  How much is enough?  There’s no firm answer.

Was BurnLounge really that different?

While we’re coming up with reasons to distinguish BurnLounge from the rest of the companies in the MLM industry, I see more similarities than differences.  While they made some very stupid mistakes, whether it be by bad counsel or corporate hubris, at the end of the day, they were buried by their paltry customer numbers.

So how do we respond?  How do we improve?

One option is to seek peace. To try to convince ourselves that the owners were simply reckless. The better option would be to seek improvement by having an honest conversation about the problem.  While we easily roll BurnLounge under the bus and reference their junk products as the main reason for their demise, we should at least acknowledge, industry-wide, the major importance of accruing revenue from external customers.  When proving the marketability of a product, the only metric that really matters is revenue from customers.  More is better.  While we all agree that BurnLounge was a bad business, we need to have an honest discussion about WHY it was a bad business.  And all roads leads to the offering of a legitimate product with true value.

Instead…

We’re trying to “get tough on crime” by passing legislation that would effectively legitimize a model very much like BurnLounge.  Instead of shrinking the gray and increasing the standards in the industry, we’re falling back to old tricks, talking about resurrecting old bills to “clarify” the ambiguity in the industry.  We all know the FTC and regulators want to see external sales.  So why are we even discussing old bills that obliterate all external sales obligations? The DSA model legislation, in my opinion, does not go far enough.  In the bill, it carves out an exception for an illegal pyramid scheme as:

(A) Nothing in this Act may be construed to prohibit a plan or operation, or to define a plan or operation as a pyramid promotional scheme, based on the fact that participants in the plan or operation give consideration in return for the right to receive compensation based upon purchases of goods, services, or intangible property by participants for personal use, consumption, or resale so long as the plan or operation does not promote or induce inventory loading and the plan or operation implements an appropriate inventory repurchase program.”  (emphasis mine).

Inventory loading is defined as:

The plan or operation requires or encourages its independent salespeople to purchase inventory in an amount, which exceeds that which the salesperson can expect to resell for ultimate consumption or to consume in a reasonable time period, or both.

It might take you a few times to read it to understand the gray area.  But basically, if the product gets consumed in reasonable quantities each month, the company is not a pyramid (in most cases).  Suppose we sell a membership to a Facebook-wannabe website.  In this business, we charge $10,000 per month to access a clunky social network, one that offers half of the features found on a free alternatives.  Is it “inventory loading?”  The site, after all, is being used.  What if we sold $10,000 shots of lemonade?  If people drink the lemonade, is it “inventory loading?”  Clearly, it’s a case of opportunity driven demand.  Clearly, it would be a BurnLounge-esque program where the lemonade is a token product concealing a money transfer scheme. I want to engage in a conversation with the DSA to simplify and tighten the current bill. One thing is for sure: nothing is going to get done on a legislative level without the DSA’s support.  

HR 1220

And what about the congressional bill that was proposed in 2003, titled HR 1220 Anti-Pyramid Promotional Scheme Act?  In that bill, a similar definition of “Pyramid Scheme” is illustrated:

The term `pyramid promotional scheme’ means any plan or operation in which a participant gives consideration for the right to receive compensation that is derived primarily from the recruitment of other persons as participants in the plan or operation, rather than from the sales of goods, services, or intangible property to participants or by participants to others.

Again, the bill creates a carve-out that would allow a company like BurnLounge to skate by with NO retail sales to customers.

Before we complain about a judge’s dangerous definition of a “pyramid scheme,” we need to acknowledge that we’re not exactly helping ourselves by fighting for fewer safeguards.  If we’re not able to get on the same page regarding sensible standards, a judge will do it for us at the stroke of a pen.  Somewhere along the way, we’ve been convinced that it’s in our best interest to push for these sorts of solutions.  I’m telling you, we NEED to do better.

Saving the industry by defining the gray

When I first started my practice, I wrote an ebook titled “Saving the network marketing industry by defining the gray.”  The thesis is right there in the title.  The industry needs saving.  And it can only be saved by creating clear standards to distinguish good companies from the bad ones. And it’s going to take courage and a little bit of sacrifice.

Conclusion

There’s a lot of people upset at the verbiage in the BurnLounge order. The outrage makes sense. But…I think this Order is just the tip of the iceberg if we’re not able to improve the standards. And in order to improve the standards, we need to stop with the self-deception, pull ourselves out of the box and acknowledge the problem. If we do not find a viable solution to the problem, a judicial body will!

Proposed Solution

The sponsor relationship between a distributor and a new participant is the foundational element in the industry. How a participant is recruited generally dictates how they build the business in the future. The idea of recruiting someone and training them to only get on autoship and recruit more people is broken. In theory, when someone sponsors someone else, they’re committing themselves to teaching that new person how to move product and build an organization. Before they’re allowed to build an organization, it makes sense that they demonstrate SOME proficiency in selling product. Before I teach you how to sell soap, I should at least have some demonstrable results doing the same, right?

Until someone provides a better idea, I’m a believer in a required retail sales rule. Before someone can earn a bonus on downline volume, they must make a single sale each month to a nonparticipant customer. Keep in mind, this is only an idea. It’s not currently the law, so it’s perfectly fine for companies to operate without a retail sales rule. If each distributor were required to sell something, they’d think long and hard before joining a company with gratuitously inflated prices on the products. When Amway got in trouble in the UK, they were saved by their decision to require $200 in retail sales before someone can sponsor other participants. This incredibly high standard is not necessary here, but we can learn from it. In the 70s when Amway got into some heat with the FTC, they were saved largely by their retail sales rule. I drafted a proposed bill for Tennessee lawmakers a couple of years ago. I still think it advances the industry in the right direction.

The alternative: nothing gets done. If you’re not supportive of higher standards in the industry, at least stop complaining when judges create their own definitions.

What do you think?

Does the BurnLounge order concern you? What can we do to improve? If you learned something in this article, please hit the +1 button or “Like” it.

Filed Under: mlm attorney, mlm legal, MLM News, MLM startup, MLM Video Blog Tagged With: , , , , , ,
by on March 5, 2012 7 Comments

VanderSloot Denies Melaleuca Operates as a MLM

SMH.  It’s a new acronym I’ve recently learned.  It means “Shaking My Head.”  And that’s what I immediately did when I read about Melaleuca’s CEO, Frank VanderSloot, denying all ties to the MLM industry.

While it certainly seems like a ridiculous exercise, I list a few obvious reasons in the video why VanderSloot is wrong to make such a distinction.

In the video, I reference his statement to the press (included below). I also reference the FTC’s definition of a “Multilevel marketing program” as per the FTC vs. FUTURENET case.

Note, this is not a controlling definition given the circumstances of the case; however, it gives us a good idea of how the FTC defines a MLM.

FTC’s definition:

“Multi-level marketing program” means any marketing program in which participants pay money to the program promoter in return for which the participants obtain the right to (1) recruit additional participants, or to have additional participants placed by the promoter or any other person into the program participant’s downline, tree, cooperative, income center, or other similar program grouping; (2) sell goods or services; and (3) receive payment or other compensation; provided that: (a) the payments received by each program participant are derived primarily from retail sales of goods or services, and not from recruiting additional participants nor having additional participants placed into the program participant’s downline, tree, cooperative, income center, or other similar program grouping; and (b) the marketing program has instituted and enforces rules to ensure that it is not a plan in which participants earn profits primarily by the recruiting of additional participants rather than retail sales.”

Essentially, it boils down to whether there’s a recruitment component to a pay plan. If there’s an an opportunity for an override commission from downline productivity, where participants can sponsor other participants and earn income from their sales, it’s a MLM. Using the factors above, and some of the obvious factors referenced in the video, Melaleuca would clearly qualify as a MLM. There’s an enrollment fee that gives people the right to sponsor other participants (element #1) and the right to sell products (element #2), which gives people the ability to receive payment for product volume (element #3) assuming the commissions are not driven by enrollment fees.

VanderSloot’s Statement

(emphasis mine)

“It’s unfortunate that someone would suggest that Melaleuca is something like Amway. It’s not. We started Melaleuca 26 years ago to market environmentally responsible products and to provide a business opportunity for folks who weren’t successful in climbing the corporate ladder and didn’t inherit wealth from their parents. We try to be champions of the little guy. My father was a little guy. And I still see myself as a little guy.

Contrary to those who do not know us, our business model is nothing like Amway or Herbalife. I challenge anyone to find any similarity whatsoever. There is no investment of any kind unless you want to call a $29 membership fee an “investment.” And anyone can get a refund on that by just asking.

We do offer a home-based business opportunity. But it is no “pyramid scheme.” We have long been critical of the many MLM/pyramid schemes operating in this country. I agree with those who say that typical MLM companies destroy people’s finances. Most are designed to attract people to “invest” in large purchases with the promise of “getting rich” quickly by getting others to invest. The guy at the top always wins and the guy on the bottom always loses.

In Melaleuca’s case there is no investment and no getting others to invest. We do pay commissions to those who have referred customers based on what those customers purchase. There is really no way to lose money on referring customers. And there’s no way for customers to lose either when they’re buying high-quality products at grocery store prices. Customers just order the products they use every month directly from the factory. We have hundreds of thousands of customers who buy from us each month. They don’t ever resell anything. They don’t invest in any inventory. There can be no pyramiding without some kind of investment. In 26 years, no one has ever complained that they lost money. It’s simply not possible.

Our business model works pretty well for most folks. We have already paid over $2.9 billion in commissions to households across the country. Our mission is to enhance lives by helping people reach their goals regardless of their beliefs, backgrounds, or affiliations. Last month we sent out almost 200,000 checks to American households alone. Members of those households tell us we are doing a pretty good job achieving that mission.”

Filed Under: MLM Consulting, MLM News, MLM Video Blog Tagged With: , , , , , , , , ,
by on February 25, 2012 6 Comments

33 Reasons NOT to Start a MLM

Photo by @i am marlon

I was speaking with a prospective client the other day about his MLM Startup and on his first question, he asked, “Are there any reasons why I should NOT start a network marketing business.”  I thought it was a neat exercise.  He was clearly testing me to see if I could be objective.  After all, the MLM model is not a great fit for everyone.  See below for 33 reasons why the model might not be the best for YOU as a means of distributing your product or service.  It’s ok to launch with some of these challenges.  But if the list stacks up high, exercise caution.  And of course, it all depends on the complexity of your business.

Product

1) Your margins are too low.  It’s hard to run a legal compensation plan with anemic margins.

2) Your product is already a commodity. There’s an equivalent in the marketplace with mass distribution and lower price points. If the main driver leading people to buy your product is the financial opportunity, it’ll lead to trouble.

3) You’re solving a problem in the marketplace that you’re not personally experiencing. While you might think it’s a cool product, you don’t really understand your target audience.

4) Your business is a “Meatball Sundae.”  Just because you like meatballs and you like ice cream, it’s not a good idea to put the two together.  While your product is interesting and the MLM component is interesting, it might not be a great idea to combine the two.

5) Your product is dangerous.  The ingredients are so cutting edge, you have no idea of the long term consequences. After taking your pill, customers can’t feel their fingers for three days.

6) Your product story is uninspiring. Unless your product has unique properties with unique benefits, your distributors will choose to stay home instead of building their business.

7) You don’t own any proprietary rights to your product, leaving you vulnerable for rapid value erosion.  If a competitor can knock off your product and sell an equivalent at half the price, it places your distributors in a bad situation to make sales.

8: You’ve got a nifty pay plan with no product to sell. In this scenario, since you’re not really passionate selling a particular product, the focus will clearly be on the pay plan.  It takes more than a token product to make a program legitimate.

9) You’re inventing a new definition for “customer sale.”  Instead of requiring that your distributors purchase inventory they can either use or sell to customers in a month, you’re going to require that they purchase product and give it all away and conveniently count those “gifts” as customer sales.

Management

10) You have not agreed on equity terms with your partners. Your partner thinks he’s getting 50% while you think he’s only worth 1%.  Get on the same page early.

11) You’re an army of one. You need help!  Do you really plan on handling compliance, product development, marketing, customer support, media inquiries, logistics and accounting? There are easier ways to kill yourself.

12) You gave your younger brother an executive role in the company, despite the fact that he’s been unemployed for over five years and lives with mom.

12) You and your partners lack a good understanding of the MLM industry.  While you’re intrigued with the concept, you’ve never worked at an MLM and/or built a sales force with an MLM pay plan.  If you all are not part of the tribe, it’s going to be hard to attract top talent.  The old adage is true: “Dig your well before you’re thirsty.”

13) Your executive team is not “all in.”  They’re still working their day jobs, making it very difficult to do the massive work necessary to build a large company.  This can be cured with adequate funding to account for small salaries.

14) You don’t want to be the “face” of the business.  You want to be the “person behind the curtain,” creating the system and sipping on fruit drinks in Costa Rica while your distributors do the work.  The field needs more than a product to sell, they need a leader to follow. It’s got to be you.

15) You cut a deal with a distributor that promised to deliver 5,000 new enrollees in the first 90 days of the business. He got equity before the launch with no vesting schedule and no restrictions. On day 91, he brought in 3 people, including himself. He still owns a piece of your business…forever.  This can cause problems in future rounds of fundraising.

16) You always wanted to be a world traveler.  Instead of stabilizing your business operations in North America, you’re flipping the switch and opening up shop in all countries before honoring the formalities of doing business in those regions.  This leads to a substantial increase in risk.

Resources

16) You lack adequate funding. You’ve saved just enough to cover legal, software and pay plan consulting services. What happens when the skeleton is built, the money is gone and you’ve got another several months until you’re profitable?

17) You have no capital allocated for compliance.

18) You have no capital allocated for intellectual property protection i.e. trademarks, trade secrets, patents, copyrights, etc.

19) You have no capital allocated for marketing.  While the field is responsible to tell the product story and closing sales, you’ve got to take the time to craft a brand worth sharing.

20) Where’s your logo?  The name of your company in 16 point “Helvetica Bold” font is not considered a logo. If you’re not working with a graphic designer, I like 99 Designs for this.

Operations

21) You’re cutting corners on your software.  Just because you “know a guy” doesn’t mean that you should hire him.  Programmers that are unfamiliar with the industry usually take the money up front, build something reminiscent of the 1994 dial-up days and disappear after the site implodes on day 3.  Understandably, the software can theoretically be built from scratch.  But is it worth the risk?

22) Due to the high-risk nature of your business, you’ve been approved by only one merchant account processor for credit cards.  If it goes down, you’re out of business.

23) Congratulations.  After facing several rejections from reputable banks and merchant account processors, you’ve been approved.  Sadly, the processor wants you to deposit $250,000 into a “reserve” account in their bank in Nigeria.  They sent you the following message: “Pleese snd mony too r addrsses with Western Union.”

24) You’ve setup your merchant account with PayPal because they make it easy and “people trust them.”  Since PayPal has terminated all accounts associated with network marketing companies for violation of PayPal’s Acceptable Use Policy, I strongly disagree that your business will be an exception.

Pay Plan

25) You just copied MonaVie’s plan…and you didn’t even bother changing the words.  I suspect you’ll get a letter in the mail after you highlight your new “Hawaiian Blue Diamond” qualifiers.

26) People are required to join your business as distributors before purchasing product.  There’s no customer option.

27) You’re offering training bonuses.  In order to advance in the pay plan, your people need to be “certified” by paying a substantial fee. While your distributors are strongly insisting for this sort of bonus, it’s not a good idea.

28) You did your own pay plan and you really lack the experience to craft a plan that’s appealing for distributors and easily shareable.  Your plan for a 110% payout is really not a good idea.

29) You’re not allocating enough revenue for operational costs.  While it’s good to offer a generous payout, it’s important to maintain enough cash to run solid operations.

30) Your pay plan is not generous enough. By a combination of weak margins and a flimsy math model, leaders will be more attracted to companies with a better ROE (Return on Effort). While they love your $5 widgets, they’ve got to sell a ton of those items before they can reap a decent return.

31) In order for your distributors to remain eligible for bonuses, they’re required to purchase a requisite amount of product each month…this amount grossly exceeds what a reasonable person can sell and/or use in a given month. It’s clearly a program that relies on inventory loading, which is indicative of a pyramid scheme.

32) Fast Start Bonuses are a big piece of your pay plan. And the money collected from the $300 enrollment fee is being used to fuel those bonuses. If you remove the FSB, the pay plan falls apart. And paying a bonus with enrollment dollars is illegal, which puts you in a tough spot.

Conclusion

I hope you found this article informative and somewhat entertaining.  The goal is to get you thinking through some of the details.  It’s great to have an idea, but it takes more than an idea to build a great company.   You’re definitely encouraged to share your own reasons.  Speaking of reasons…there’s one more reason why you should NOT start a MLM…

33) Passion.  There’s got to be more to your mission than just making money.  Unless you truly care about impacting lives in a positive direction, it’s going to be near impossible to create the emotional connections necessary with the right people.  At the end of the day, it’s about inspiring people to change their habits, thereby changing their lives.  If your PURPOSE is not in line with your BUSINESS objectives, save your money.

 

Filed Under: Distributor Resources, mlm attorney, MLM Consulting, mlm legal, MLM startup Tagged With: , , , , ,
by on February 8, 2012 2 Comments

FTC vs. BurnLounge – Case Summary

A few months ago, I published a concise ebook that summarized the FTC / BurnLounge decision.  This ebook was pre-released only for my MLM newsletter subscribers.  Now, it’s available for you.  The article is below. There’s a lot to be learned from this decision. If you prefer a PDF copy, click here.  It’s a concise summary of exactly what went wrong with the BurnLounge business model. And I apologize if the formatting is a little janky in spots. I had a hard time converting the Word file to work with this page

Introduction

BurnLounge was a purported network marketing company. They positioned themselves as a blend between iTunes, MySpace and Amway. The FTC filed its initial complaint against Burnlounge in June of 2007. After a bench trial (and a two year wait), the judge held Burnlounge to be an illegal pyramid scheme.

Facts

Business model

It’s important to understand the Burnlounge model for purposes of understanding the pyramid scheme analysis. Also, it’s beneficial to understand the Burnlounge model because their failure is very informative for other companies in the network marketing space. At its core, Burnlounge created a network of replicated websites, referred to as “BurnPages.” These BurnPages allowed the independent “retailers” (a/k/a distributors) to sell music and other items. There were multiple entry points into the Burnlounge program:

1) Retailer: Paid a $30 fee for the right to operate their own BurnPage. Retailers were not eligible to receive income from music sales. Instead, they received “Burn-Rewards,” which they could redeem for music.

2) Mogul: If they wanted to earn cash rewards, they had to pay $7 per month and purchase one of the below product packages. Upon this occurrence, they were dubbed “Moguls.”

Product Packages

1) Basic: Basic members pay a $7 monthly fee in addition to paying $30 for the Basic package. The package included:

a. BurnPage

b. Editing software for the BurnPage

c. Back-office support

d. Sample copy of BurnLounge Magazine

e. Annual subscription to “FrontBurner Magazine, which was an online website.

2) Exclusive: Exclusive members pay a $7 monthly fee in addition to paying $130 for the Exclusive package. The package included:

a. All of the items in the Basic package

b. Annual subscription to “BurnLounge Presents,” which was a monthly bundle of 10 songs selected by the company and available for download

c. Monthly DVD subscription featuring independent artists chosen by the company

d. Annual subscription to “BurnLounge Magazine”

3) VIP: VIP members pay a $7 monthly fee in addition to paying $430 for the VIP package. The package included:

a. All of the items in the Basic and Exclusive packages

b. The “Event Pass,” which provided for better seating and early access admissions at certain concert events

c. “BurnLounge University,” which consisted of six DVDs documenting the history of the music industry.

NOTE: Retailers always maintain the option of converting to “Moguls” at any time. The vast majority of Retailers chose to become Moguls (97%).
 

Compensation Plan

The BurnLounge compensation plan is confusing. When referencing it, the judge wrote, “Indeed, it would appear that BurnLounge was attempting to create a labyrinth of obfuscation rather than a readily understood compensation system.” Essentially, there were multiple income opportunities in the BurnLounge plan. There was a unilevel component where the participants earned a percentage of the volume generated by their personally enrolled representatives. In addition to this program, Moguls earned the “real money” in the binary plan. In order to qualify for the binary compensation, Moguls had to “sell” two VIP packages to members in their downline (the VIP package was the most expensive offering) and hit monthly performance standards. In the binary plan, Moguls earned a percentage of the total volume from their business by optimizing their two legs.

Income Claims

 


BurnLounge had policies in place that prohibited the field from making income claims. Despite this policy, aggressive income claims were still made by top leaders. Claims were made where people said they were earning in excess of $200,000 in income. BurnLounge officers testified that they made efforts to police the income claims. BL’s head of Customer Service testified that he dealt with income claim issues a few times a week. Furthermore, BL’s Executive Vice President made a strong statement from a company event about the importance of ending the use of income claims. According to BL, nobody was ever terminated for making income claims. While it was discouraged, apparently nobody was penalized.When income claims were made, income disclosures were not provided to the prospective participants. The FTC argued that the income claims made by field leaders was pervasive throughout the BurnLounge organization.

Issues

Was BurnLounge operating as an illegal pyramid scheme? Were the income claims made by BurnLounge leaders “misleading?”

Law

Pyramid Scheme

Operating a pyramid scheme is an unfair and deceptive act affecting commerce, which triggers the FTC Act. Pyramid schemes are inherently fraudulent because they’re destined to collapse.As determined by the Koscot case, pyramid schemes are:

Characterized by the payment by participants of money to the company in return for which they receive (1) the right to sell a product and (2) the right to receive in return for recruiting other participants into the program rewards which are unrelated to the sale of the product to ultimate users.”

The judge referenced Omnitrition, which is an unpopular case in the MLM industry. Referencing Omnitrition, the judge wrote, “The satisfaction of the second element of the Koscot test is the sine qua non of a pyramid scheme.

Income Claims

“A statement is misleading if the representation is likely to deceive reasonable consumers to their detriment.” Southwest Sunsites, Inc. v. FTC.

Application of the Law to the Facts

Pyramid Scheme? BL consisted of two components: 1) the sale of music and music-related products through the BL software; and 2) the BL Mogul program, which was the income opportunity. It was only through the latter that anyone could possibly achieve any “significant financial return.”

MLM Attorney Commentary: Given the minuscule amount of revenue accrued from external sales (3%), it was apparent to the court that the only real way to earn income via the BL opportunity was by focusing almost exclusively on recruiting new participants who purchased the product for themselves. After a detailed breakdown of the BL offering and prices, the court concluded the BL prices were gratuitously inflated to support the pay plan.

“[B]ecause participation in the program required the purchase of a product package, and Moguls earned cash for selling these product packages to those they sponsored, they by default received compensation for recruiting others into the program.” The Basic package was the only required package, technically. The court wrote,

BurnLounge argues that the sale of the Basic Package is the sale of a product to an ultimate user. While it is true that the BurnPage could be considered a “product” and a Retailer to be the “user” of that product, this argument ignores the nature of the use itself. That it is a tool for sales and (more importantly) for recruitment, as demonstrated by a review of the BurnLounge promotional material, the presentations of its spokespersons, and the statistics as to the participants who bought into the enterprise. While it is true that Retailers could merely sell music downloads through their BurnPages, Retailers/Moguls generated many times more revenue from the sale of the business opportunity to new participants than the meager rewards of vending the music downloads available on the BurnLounge system.

MLM Attorney Commentary: In order for a transaction to be commissionable, the item sold needs to have some kind of relevance for people outside of the program, lest it be labeled a recruitment scheme. With the Basic package, the court concluded the BurnPages to essentially be “non commissionable” because they were primarily used as tools by distributors to sell music and recruit more distributors, not as actual products.

Unlike the Basic package, the premium packages, the Exclusive and VIP packages, were optional. BL argued that the sale of these packages were truly sales to end users. The court acknowledged that the items bundled in the Exclusive and the VIP packages had SOME value (“extremely limited”). However, regardless of this limited value, the court concluded that it was the financial incentives that ultimately led the BL distributors to purchase those items. Because of this fact, the court concluded that the sale of the Exclusive and VIP packages were pyramidal in nature. Specifically, the court held, “Inventory loading pyramids are not illegal simply because there are wholesale purchasing requirements. They are illegal because the purchases are incentivized by commissions that result from recruiting others to join the scheme through similar purchases.” (emphasis mine)

MLM Attorney Commentary: “MOTIVE” is the key word here. Because of the limited value of the items coupled with the small external sales (3%), the judge concluded that the primary driver that led distributors to buy the premium packages was the compensation plan. In my opinion, it’s ill-advised to make certain rewards in the pay plan contingent on a distributor purchasing a certain item. Distributors should never be required to purchase a higher ticket item in exchange for an ability to earn more compensation. It can always be argued that the true motivation behind those purchases is for the money, not for the value. It makes no sense for a company to expose itself to the additional risk.

Misleading Income Claims? The defendants (BurnLounge and the individual leaders) argued that the misleading statements about income were mere “puffery” i.e. not material. “Generalized or exaggerated statements upon which reasonable consumers would not rely are considered ‘puffery’ and are non-actionable.” With BurnLounge, the judge found that the statements were not vague. On the contrary, the statements were very specific. The judge further noted, “In addition, where a person markets [a pyramid scheme], he/she must at a minimum advise potential investors of the unlikelihood of any substantial returns. The court concluded that the defendants did not provide the material information

MLM Attorney Commentary: Whenever an income claim is made, whether it is express or implied, it’s imperative that adequate income disclosures be provided. Since the company is usually not involved in making income claims, it’s important to (a) provide good income disclosures to the field; and (b) implement AND ENFORCE policies designed to get the leaders to share those disclosures with prospects when income claims are made. With BurnLounge, it appears that they actually had policies in place against sharing income claims; however, those policies seem to have been ignored. If those policies were actually enforced and their was a history of enforcement i.e. suspensions and terminations, this particular issue might have been mitigated.


Conclusion

 


After waiting for two years after the trial, the judge finally concluded that BurnLounge was, in fact, a pyramid scheme. It’s important for serious students of the network marketing industry should take a hard look at this case. There’s a lot to be learned. In my opinion, if I were to point out one toxic element in their business model that ultimately led to the regulatory action, it would be the extra incentives in the compensation plan that led the majority of BL participants to buy the premium packages. The compensation plan drives behavior. When the barrier to the “real money” was the purchase of a premium package, the vast majority of participants will do it regardless if they really want the products. This appears to be the case with BurnLounge. While BurnLounge tried hard to argue that its products were valuable, the extra incentives in the pay plan provided an easy opportunity for the FTC to argue that the participants bought the bundles to crack into bigger commissions. Simple mistakes, big consequences.

If you learned anything at all by reading this article, please take the time to hit the +1 button above or the Like button. Share the love!

Do you think this was a fair decision?

Filed Under: mlm attorney, mlm legal, MLM News, MLM startup Tagged With: , , , , , ,
by on January 31, 2012 1 Comment

Direct Selling Edge Part Deux!

The Direct Selling Edge conference for MLM startups is back!  After a very successful conference in September, we’ve done the impossible by adding even more content to an already stuffed agenda.  Check out what attendees said after our last event below. The event kicks off on Thursday, March 8th in Las Vegas.  I’d love to see you there and meet you.  The details of the conference can be found on our main page here.  At this event, we’re very pleased to announce three new speakers!  MLM Consulting firm, Launch Smart, will be with us teaching about important systems for customer support, operations and distributor education / retention.  As the 2010 DSA partnership award recipient, we’re delighted to have them on board.  The value David Taylor and Terrel Transtrum bring to the attendees will be well-worth the cost of admission.

We’ve also added MLM software guru, Mel Atwood, from YourSolutions.net.  Mel brings an incredible level of commitment, energy and passion to his work for MLM clients.  Whether he’s serving as the Vice President at the Association of Network Marketing Professionals or adding value as a fellow DSA supplier member, Mel’s activity inside and outside of his software firm adds tremendous value to the industry.

At our conference, we’re covering many advanced principles in creating and launching a network marketing business, guaranteed! If you’re skeptical, check out what people said after the last one.

Some testimonials

  • Definitely worth the money. As a matter of fact, after 30 minutes, I think I got my money’s worth. I found out that my business plan was not legal and by the end of this, I’ve learned all the tools and information to make this work. It’s a really good program.  Zach Taylor
  • Thank you for the most crucial information supporting my Party Plan Business. This 2 day class was exactly what I needed! Great job by everyone! Absolutely every aspect of my business was covered. Thank you again. Cheryl Wollrab
  • I was amazed at the information. I thought it was going to be a broad stroke event to get you with different vendors. I was very surprised to see all of the targetted topics, how in depth they went into discussing very important issues, for anyone whose considering getting into the MLM business as a startup company. Mike Duke

    • At the end of each day, from 5 until 8 pm, you’ll have the the opportunity to meet with conference speakers for 30 minute appoints at no additional cost! Add the six hours up and you’re easily walking away with over $1,000 worth of consultation.

    Register Now

    Starting at just $199 per ticket, the value greatly exceeds the cost of a ticket. Purchase a ticket here. Information is the only asset separating you from your competitors. If you’re not satisfied with the program, we’re offering a 100% guarantee, no questions asked.  Join us and we look forward to meeting you. Our agenda is loaded with information specifically chosen to advance your business. Check out the full Edge agenda.

    Some more testimonials

  • It’s been a very good conference really on the nuts and bolts of trying to figure out how to turn a company into an MLM. I think these people are very talented and knowledgeable and will really help you to build your business and help you to move forward. Susan Averett
  • Jay, Kevin and all other other speakers provided us with great information, in-depth, thorough, and painted a perfect picture for us so that we have a good sense of what we’re getting into. I want to thank all of them for their time, their effort, and for providing myself and my wife with the information that we need to go forward with our company and make it grow. Thanks a lot. Stanley Chang
  • As a former distributor, as a board member for a large network marketing company, as now an owner of a network marketing company myself, this conference has been extremely helpful. Great speakers, great content, A to Z, everything that you need to know as a startup. Brad Doyle
  • Attending the DS Edge was different from any other MLM conference I had been to before. I’ve been to other conferences, They try to sell you services, they do give you information, but the difference with this one was we actually left with actual steps, tasks we can take, things we can get done to make sure we are successful, so I highly recommend it. It was a great use of time. Bethanie Nonami
Filed Under: MLM Consulting, mlm legal, MLM News, MLM startup Tagged With: , , , , , , , , ,
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