• Since 1991, NuSkin Enterprises has been investigated, subject to cease and desist orders and/or other enforcement actions related to its business practices by the Federal Trade Commission (FTC) and the Attorneys General of Michigan, Georgia, Pennsylvania, Florida, Illinois, Ohio, Connecticut, Texas, and Utah.
• In 1993, NuSkin International, Inc. (now NuSkin Enterprises, Inc.) and associates were ordered by the Federal Trade Commission to stop misrepresenting in any manner past, present, and future profits, earnings, income, or sales from participation in its marketing plan.
• Since that time, NuSkin has published and made available to prospects who inquire an annual report entitled Actual Average Incomes.
• This report includes faulty assumptions and survey results, omissions of costs and other important data, and statistical distortions that -- taken together -- significantly mislead and misrepresent earnings to potential distributors who are recruited into its plans. For example, sales at retail price are assumed at far greater rate than actually occurs, and odds of success are calculated without considering the vast majority of participants who quit the NuSkin program after losing their investment.
• In particular, a person reading the report may conclude that 100% of those who make an effort to apply the NuSkin program as distributors (the "actively participating distributors") earn at least some profit. But careful study by qualified analysts, who are intimately familiar with the report and with NuSkin's recruiting practices and compensation system, have concluded that less than 1/10 of 1% of all distributors who have signed a distributor agreement have earned a profit after subtracting all expenses, including both operating expenses and products purchased from NuSkin.
• As a result, hundreds of thousands of persons who joined the NuSkin program since 1993, and who based their decision to participate partly on the verity of this report, may have been defrauded collectively of as much as hundreds of millions of dollars.

We, the undersigned, therefore request the Federal Trade Commission to examine whether NuSkin's Actual Average Incomes document is a violation of the 1993 Order for NuSkin and its distributors to stop misrepresenting past, present, and future earnings of distributors.