F.T.C. Public Comment 93

I don't think you guys are thinking there. I mean this is really obvious stuff. And it wouldn't take a rocket scientist to figure out that what I'm saying is true. And if you call a couple of attorneys around the country, I think you'll find out that's exactly what they are doing. Of course you'll have to be as sneaky as they are and disguise who you are.

FTC.jpg

U.S. Federal Trade Commission
June 6, 1997

Public Comment
Lance Winslow, franchisor

Request for public comment on possible revisions to The Franchise Rule.

Comment #93

ANPR Hotline

June 6, 1997 10:50 pm

Hi. I have a comment. My name is Lance Winslow. Car Wash Guys International. 5699 Cannon Road, Suite #130, Agora Hills, California 91301. You can reach me at 888-WASH GUY.

I have a comment. In the back of the franchise offering circular, each franchisor has to list all their franchisees. And I was talking to a couple of attorneys that specialize in franchising. Their specialization is actually in class action law suits. Wouldn't anybody who is an attorney in franchising? Makes sense. In any case, what they do is set up phone calling trees. And they are little telemarketing type departments of their, you know, part of their law practice.

And what they'll do is call up all the franchisees of various franchisors. And they get all the information because there are a couple of companies that service the franchising industry, that make UFOCs available to everybody and they sell you the information for cheaper than 20 cents a page, which is what the FTC, I think, charges for copies of the UFOCs.

In any case, they get through all this information and they send their telemarketers to ask every franchisee if they are happy or not. And if they get ten percent with a given franchisor, then they initiate some kind of committee meeting and try to form some kind of organization or instigate a class action law suit as fast as they can.

I think you ought to not require franchisors to list that information, unless a given specific franchisee who's signed that he's received the document and asks for it. In other words, it should not be public record because it is being abused. It is being abused by the same people that seem to be making the laws, and trying to help you change the laws, and help lobby the laws to be changed so it will be easy for these types of law suits.

I think someone really ought to look in to that. I don't think you guys are thinking there. I mean this is really obvious stuff. And it wouldn't take a rocket scientist to figure out that what I'm saying is true. And if you call a couple of attorneys around the country, I think you'll find out that's exactly what they are doing. Of course you'll have to be as sneaky as they are and disguise who you are. Otherwise they are not going to tell you they are doing it.

One more tip for you. Lance Winslow, the Car Wash Guy. Thank you.

For Review, see FTC “Table of Commenters”
http://www.ftc.gov/bcp/franchise/comments/tabcomm.htm


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Risks: F.T.C. Public Comments, United States, 1997, Lawsuits, class action, United States, 19970606 Comment 93

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