12/04/2022
https://www.federalregister.gov/documents/2022/03/11/2022-04679/deceptive-or-unfair-earnings-claims
Deadline is May 10! There is only 3 comments relating to ONLY Paparazzi! You CAN submit anonymously! We’ve got work to do friends. You can use Tracey’s letter as a template to write your own but you CANNOT copy and paste her letter!
In an effort to help people formulate a letter to the FTC for their Public Comment Period about the Deceptive & Misleading Practices of MLM’s like Papa-puke, here is my letter…use it to help you write your own!
I was enticed to join the multi level marketing company, Paparazzi LLC, through claims on social media by current company representatives and the company’s own website posting that showed people making money selling $5 jewelry that was advertised as nickel and lead free. Because my daughter was sensitive to nickel in products, I was thrilled to have a reasonably priced product to offer to my friends and family that had no nickel and lead in it, according to the company. The company’s statements that the jewelry is nickel and lead free is false and misleading, as proven by the attached lab results, which materially defrauds both consumers and potential business competitors. The company had absolutely NO income disclosure statement when I joined in 2017 and the one that the company issued in 2020 does NOT disclose how people make money in that company. The company representatives that I saw posted “lifestyle” posts showing piles of cash, new cars, new homes, etc, with the social media hashtag “because of Paparazzi” (see attached photos of social media posts). While the company’s website says that you can make 45% commission on sales of products, the statements I saw all said “making fortunes $5 at a time”, inferring that they make $5 on sales….this is just not true. Even the company’s claim of 45% commission is not true, as any costs of selling products such as website fees, postage, shipping materials, etc. are never included in this calculation. No overhead costs are included in the income disclosure statements, artificially inflating the potential profit that can be made on each piece of jewelry. Even the company’s motto of “changing the world $5 at a time” is deceptive, since no one makes $5 on the sale of a piece of their wholesale inventory. In addition, Paparazzi’s income disclosure statement is deceptive as it only shows income earned by recruiting other consultants whereby earning 10% of THEIR purchases. IT DOES NOT TRACK INCOME FROM PERSONAL SALES, despite the fact that they claim your make your money from selling the product. They do not even track personal product sales. In point of practice, more than 75% of the jewelry sold by Paparazzi LLC is sold to CONSULTANTS and NOT to consumers, so the consultants are the actual target customer of the company. Instead of helping you MAKE income, they are collecting money from you and doing nothing to help you sell the product to any other customer besides the consultants themselves. The company provides absolutely NO business training and constantly pressures consultants to buy inventory on a daily basis (whether or not they have a customer need or request) as it is touted as “limited” quantities that will “never be released again”. The limited quantities and constant pressure to purchase the product creates an environment where the consultant is the final customer. This is deceptive and misleading. This is further proven by the corporate policy that one consultant can NEVER sell the product at wholesale to another consultant or they will be “cancelled” as a independent contractor. I have included the Paparazzi Policy & Procedure Manual here to prove their restrictive oversight. Consultants MUST pay full retail price for Paparazzi’s product if purchased from any venue OTHER than the company, further showing that the consultant is actually Paparazzi’s target customer. Paparazzi goes so far as to FORBID consultants and even former consultants from selling their product for less than the fixed market price of $5, threatening legal action. Paparazzi fixes prices. Consultants have no option to adjust their price to reflect market need or interest and they are constantly barraged with pressure to purchase more and more directly from the company. Consultants are also incentivized with contests and competitions endorsed by the corporate oversight group to require minimum wholesale purchase activity to participate. Sales of products to end user are NEVER tracked. The income disclosure statement is based on commissions earned when you recruit other consultants into the business and they then purchase inventory, whether or not they ever sell it and see a profit. Once you join, it is made VERY clear to you that the way you make money in Paparazzi is to RECRUIT. You make a commission by recruiting new consultants and then encouraging them to recruit even MORE consultants. Consultants are constantly on social media doing “opportunity lives” where they promise all of the business support and resources your need to “make money like me”. I have included some of the consultant created “training” materials with this letter as an attachment. Paparazzi LLC’s income Disclosure Statement, in conjunction with their corporate and independent consultant marketing, does NOT reflect how little money there actually is to be made selling their jewelry that is actually full of nickel and lead (attached find lab testing reflecting false advertising).