The most widely-cited description of an unlawful MLM structure appears in the FTC’s Koscot decision, which observed that such enterprises 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.” In re Koscot Interplanetary, Inc., 86 F.T.C. 1106, 1181 (1975).1
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Belonging to a self-regulatory organization, however, does not shield MLMs engaged in unfair and deceptive practices from FTC law enforcement action. Under appropriate circumstances, the FTC can and will bring law enforcement actions against companies that claim to follow self-regulatory guidelines but in practice do not. Similarly, the FTC can and will bring law enforcement actions against companies that, despite following such guidelines, nonetheless violate the FTC Act.
In an October 15, 2010 article, it was stated that documents of a MLM called Fortune Hi-Tech Marketing reveal that 30 percent of its representatives make no money and that 54 percent of the remaining 70 percent only make $93 a month, before costs. Fortune was under investigation by the Attorneys General of Texas, Kentucky, North Dakota, and North Carolina with Missouri, South Carolina, Illinois, and Florida following up complaints against the company. The FTC eventually stated that Fortune Hi-Tech Marketing was a pyramid scheme and that checks totaling more than $3.7 million were being mailed to the victims.