Discussion b:w Thompson and Deborah Heisz re litigation

It sometimes takes a few seconds, but redirecting to Facebook, I'm going to check on another machine here.

Okay?

Okay. All right, Deborah. All right, everyone. Kevin Thompson here. I'm an attorney that represents network marketing companies and I'm here with Deborah Heiss. Did I pronounce it right?

You did. You did.

All right. Co CEO at Nerium Naora currently. And these folks reached out to me and just wanted to have a discussion to push it out there. And here we go. Disclosure for both of us, Deborah, for yourself and for the viewers here. I'm not pretending to be a talk show host. I'm not a professional. So we're just going to have very casual conversations. So no pressure on me. Hopefully, disclosure to the community out there. Naora is not a client of mine, nor have they ever been, nor is this an effort to make them a client at all. This is just genuine curiosity on my part. And for the first time in a very long time, somebody that's going through litigation is actually willing to talk, which I think is just a fundamental right. And it actually gives. It provides an AORA with an advantage. The company being pursued by the Federal Trade Commission or the SEC or whatever government agency, they can communicate. And a lot of times in this industry they do not. So, Deborah, enough of that. Tell us a little bit about yourself and your position with the company and when you started and all that good stuff. And then I've got a list of questions here. We'll go through.

Well, I've been in the network marketing industry, a direct selling industry, since 1995, either as you know, in a member in a company, or I worked on a supply side, basically services provider to the network marketing company. So I've been in this industry for a long time. I've been with neora itself since 2016. I came on in April of 2016. And my role here is co CEO. I really run the operational side, the nuts and nuts and bolts side of the business. But, you know, this is a, this is an industry that I take a lot of pride in being part of. I think we do a lot of great things in the world and I'm happy to be here.

Great. Well, all things considered, you had a pretty long week. Was it last week or the week before?

It's. It was last Friday was one week. So we're 10 days in from filing against the FTC.

You're looking pretty good. You, you know, you would think that you'd be all haggard and, you know, bags under the eye. You're looking all right. You're handling it very well. So. Okay, so first question on my list, and there's no particular order here.

Okay.

Do you have sufficient money to defend yourselves and to also pursue this case in Chicago that you filed?

Well, you know, the filing of the suit that. First of all, I want to make sure everybody understands that we filed suit from. And that's important for a variety of reasons, but mostly it's because we were trying to be pressured into accepting. Accepting a deal that was not beneficial to our brand partners. I mean, basically, we would have been putting our brand partners, which is what we call our distributors, out of business if we accepted a deal. And we would also be accepting a deal for something we weren't. So the answer to your question is we were going to fight either way. So do we have the money to sustain the fight? It's going to be difficult. It's a very expensive process. We've already spent a lot of money on it. We have had some outreach to some other people who are interested in helping support our monetarily, support our cause. And we're going to have more. More information about that in the coming weeks. But we're trying to set that up in a way for it's safe to them to do so, and of course, it's perfectly safe for us to keep fighting the fight. So that's where we are right now.

You know, for what it's worth, conversations that I've had, I think you're going to have a lot of people willing to contribute to whatever fund you establish or to affirm that can help with your defense and the prosecution, because it's an important case. And I think a lot of your competitors, even you would think that in some cases they'd say, well, it's a competitor of mine, and this is good for me. They realize this is pretty important. I have a suspicion that you guys are going to be able to sustain the effort. It's very important. I think the Federal Trade Commission counts on companies not being able to defend themselves, and that's part of the strategy, just to bleed you dry to where you shrivel up. And it's not an issue. It wasn't the case in Burn Lounge because they had insurance, and Burn Lounge actually did a pretty good job pushing that case all the way to the Ninth Circuit. So the FTC does not like protracted litigation. No.

And let me. Let me address that a little bit. I mean, the other. Other side of that is, obviously, we have a robust business. I mean, we have lots of, you know, and it's Largely in the United States. I mean, our business is 80. 80% in the U.S. 85% in the U.S. and Canada, somewhere in that range. And it's. It's. It's a large. It's a robust business. So our business itself can sustain itself. The outside pressure from the ftc cost is something we're dealing with. But, you know, without being overly specific, we have had several companies and suppliers and already reach out to us saying they want to help without any solicitation, which is really good, because we were planning on putting out, doing a PR effort to try and garner some support, because ultimately, yes, Neora has taken on this battle. We've decided that we're going to fight for our. Really, for our brand partners, for our distributors. We're going to fight for our business and for our right to run a perfectly legitimate business here in this country. But the type and the nature of the case, both our case against them and their case against us, the nature of that case is such that I think it's something the entire industry needed. The industry needed someone, particularly in the advent of advocare, to step up and say, no, we aren't just going to cave because you're the government. We're not wrong. We are in the right here. And we've got to. We've got to not just work within what the government, however we feel like the ftc is trying to change the rules. We've got to not just roll over and capitulate to that.

I commend you for that. Where are you from, by the way?

I'm a military brat.

Because you don't take punches lightly. And it's a cultural thing that I can sense. I'm from tennessee, and I have an allergic reaction When I see the government doing things. Even if maybe. Maybe it's the right thing. I'm not saying that's the case here. But if the proper process isn't followed, or due process rights aren't honored. You know, tennesseans, we tend to have a really adverse allergic reaction when we hear things like that. A lot of folks in this industry, they get intimidated when they're pursued by the government. And they do. They cough up these checks, and they end up going out of business later. Or they agree to suspend all operations. I call it an ATM machine. I mean, the industry has been sort of an ATM machine for the Federal Trade Commission. Herbalife was a $300 million settlement. Advocare was $150 million settlement. I apologize. Herbalife, I think, was 200 million, 200 and it's just settlement after settlement and there's no litigation in these cases. And so it's going to be really, your case is very important before we get to the merits of the case, which I can tell you're kind of itching to go there to the extent that you can. When did the subpoena hit and what do you think triggered their interest in you all back in 2016? I know the subpoena hit in 2016. What triggered it, do you think?

I think that. Well, I know what triggered it. Tina triggered it and they've been proud to say so. And Tina posted, as they have for several companies in our industry, some income and product claims that were being made by some of our brand partners and they basically submitted that to the ftc and that's really what triggered it.

Yeah. So what was it like? So you got the subpoena. There was in your lawsuit you mentioned, I want to say 16 rounds of discovery responses.

Yes.

Tell us about that process. I mean, how does it go? Is it just, is it adverse day one? Is the other side difficult to deal with? I mean, are they angling to shut you down or is it more casual in the early stages?

Well, in the early stages it was just, they showed up and they asked for information and we made the decision. Knowing that, knowing that we, we really didn't feel like we had any, any, I'm going to call significant issues. Every company has some small issues. I mean, particularly in our industry. I, you know, income claims are a particular issue that you can, you can control your, your independent salesforce, you can educate them, you can enforce. But there's one that slips through the crack, particularly in the advent of social media. So we've all got, we've all got those that we deal with, but we really felt like when they showed up that our best, our best opportunity was simply to open, you know, open the kimono and share everything we had because we didn't feel like we had any other issues. The company was specifically built to comply with all guidance that the FTC had put out about, you know, how, you know, compensation or, you know, anti permanent scheme, all of that. So we built the company that way. So we felt like just open up. And so really we sent data, they made more data requests, we sent more data. It was not very confrontational at all until you receive that first draft complaint. When you receive that first draft complaint, that's when you really find out what they're thinking. Because before then it's just interrogatories, it's just Discussion.

Can you disclose when you got that draft complaint?

It was in June of 2018.

So relatively recent. Well, almost. I'm sorry, that was a year and a half ago. My goodness. Yeah, you know, it's. You would think that with a three year investigation, if they saw a terrible fraudulent company, they would have taken quicker measures to shut it down. The fact that they didn't meant that there were no serious alarm bells. That's my read of it. The fact that it took three and a half years to get to this point. So you get the draft lawsuit in June of 2018, there's discussions.

Well, it was beyond discussions because the initial draft lawsuit, they had discounted a large section of our data in their economic analysis and it came through in the numbers. So when we got the draft, when we drew out the draft complaint, it was obvious that something had gone awry and we let them know and they went back and revisited again. So the delay timeframe had to do with the, you know, I think they had to do a secondary economic analysis and we, we hired our own econometrician to also look at the data as.

Well, who was there.

So it wasn't. It's a gentleman named, well, at the end, I don't know who did it throughout, but a gentleman named David Givens.

Who works for the ftc, he's their chief economist.

I don't know if he's their chief economist. I don't think.

Speaking of data, my gosh, I just had a question. You implied that they had their own analysis but they wouldn't disclose it. Any reason why? Why not? Is that just not their method of operation? They just keep their cards close to their chest?

They don't have to disclose it was their answer when we asked for it. And we asked for it on multiple occasions because we're trying to wrap our heads around their conclusions without looking at how they got there in our own economic analysis, showing something entirely different than what their conclusions are. But if you look at the complaint against us, there's very little in the way of numbers.

There's no victims. Actually, I didn't see any affidavits from victims. It's interesting. In the Vemma case, for example, people that purchase product and lose money are victims. And when they calculate the amount of consumer harm out there, the amount that needs to be collected from the company, they assume that the consumers lost 100% of all their money and they got zero value. So it's an example to make sense of this point is Red Bull cost, let's say $2.50 and Vemma hypothetically cost $3. BK's argument was that people are getting value. Surely you can't say the whole $3 purchase is fraudulent and the result of consumer harm. They're getting value. Was that ever discussed between you and the FTC when you're talking about, you know, the size of the check that they want from you guys, where you say, look, you know, people are buying skin care products, they're buying something valuable.

Well, the, the entire amount in the complaint was related to. That's basically the disgorgement of all EHT sales for a certain time period.

It's just eht.

That's, that's where the amount came from. That's in their current complaint. As far as what we've been told, I mean, you know, we're probably several years away from having that discussion in court as to what that. But, but that is, that's what we were. That's what I've been informed of. It's the entire disgorgement of EHT profit is the only accounting for their profit.

Revenue.

Revenue. I'm sorry, Revenue, not profit. Thank you for the correction. But yeah, so we did discuss, we did discuss and they generally believe that product purchases that are made by participants, they seem to have some issue as to whether those are a business expense or not. Certainly some people implied that if you buy a product, product because it's your qualifying purchase. So you know, we, in our program, you can either in the program during the time period they looked at, it's changed since then, but they could look at, you could either have a bottle of product or the equivalent of our original. We were originally one product company on ADO every month to qualify or you could sell $200, roughly three bottles of product to qualify. It was an either or not, not a must. They were considering any product purchased by the brand partner to be a business expense.

Right.

Which is very strange when it's something that comes in a 30 day consumable and the average purchase is roughly, it's a little bit more than your average customer, but not so much more that it looks like they're stockpiling at all.

So you're getting the purchase pattern there. So, so when your distributors purchase product and customers purchase product, it's sort of on parity is what it is.

Distributors purchase a little more, which that isn't a surprise to us. I mean we sell at this point, we sell a myriad of products so they purchase a little more. Whether that's for using a sample at a home party or it's because they like more of the products and they use larger line. But roughly, you're Talking about a 20% disparity on a low purchase value. So you're looking at $100 to $120. It's not massive.

Yeah, well, you referenced the FTC guidance and they wrote a website or a blog on their site back in 2018 where they say that of course commissions that are generated from downline consumption is fine, which means those are rewards related to end users. And so then for them to say it's, you know, on the one hand they are end users and can be end users for distributor consumption, on the other hand, say, well, it's not for end user consumption, it's a business expense. That doesn't make a whole lot of sense to me.

It didn't make sense at all to us either.

Yeah. All right, so let's, let's sort of get into the, the heart of the allegation here. And that's your customer numbers. Now, I saw a percentage. My immediate reaction was, they're lying, the ftc. And these are my words, not yours. I know you're being trolled here is watching. I know they're their chief litigator, o'. Toole. He's a, he's, he's aggressive and he'll twist anything you say if you're not really careful. And he'll threaten to even sue your kids. I've heard of that. So be careful with him. Regarding your customer percentage, The FTC says 1%. And you know, I'm old fashioned. Maybe it's because I'm from Tennessee and we tend to, you know, have a simpler approach to things, but I think there should be consequences when people are wrong or when people lie. The FTC seems to do it repetitively and there's no consequence. First of all, where did they get the 1% number and is it inaccurate?

It's incredibly misleading. Now, I said I was a military brat, but you got to know I'm from Texas. Technically, I was actually born here and I've lived here most of my adult life. So I think we feel a lot like you Tennesseans when it comes to that sort of stuff. So the 1% is our retail sales number and they call it 1% retail sales. Now what that means is that when someone comes through one of our brand partners and pays absolute full retail value and basically doesn't enroll as a preferred customer, they don't get on any list. Maybe they just want to try the product one time. That's our retail sales number. That's where that 1% comes from. We have a very small amount of retail sales. What we have instead is a very large, robust preferred customer program. Now, at our company, a preferred customer has always and currently still does enroll as a customer. And they were never a distributor, They've never been a distributor. We don't have Social Security number. They come and buy from us as a customer and basically they enroll as a preferred customer and they order product whenever they want it. Now, they set up an auto order when they order it, but they can cancel it right away. They can literally set up the auto order and cancel it and not be obligated to buy anything else ever again. And some of them do that and some of them don't. But that's a preferred customer base. Now, that preferred customer base from the time period they're looking at, the FTC looked at comprised 60% of our sales in 2017.

That's incredible.

So you take 1% retail and 60. That, last time I checked, that 61% of our sales going to people who do not participate in our.

Not in the income opportunity, not in the genealogy, not at all.

They're just customers. And so, yeah, that 1% number is incredibly misleading.

Yeah. Just to tell an old ghost story to get the ex parte injunction in the Vemma case, the attorney said we are confident that more than half of Vemma's volume comes from starter kits and I think auto ships even, and it was less than 10%.

Wow.

Problem is, these are my opinions, not yours. These government attorneys, they're able to make these aggressive assertions of fact because there's no consequence when they're wrong. So why not? If, to use a football analogy, I was at the Tennessee Titans game yesterday. If I throw bombs down the field and if it's intercepted and I still got the ball back after the interception, I'm going to keep taking throwing bombs down the field. And so that's the reality this agency has been living with for maybe for decades. And so it's good to see that you. Number one, it's good to see that they didn't just get an immediate asset freeze and play it that way. The FTC currently has to be a bit more honest about the approach with the subpoena, with the lawsuit and give you a chance to respond, which I think puts you in a better position, but hopefully, I just hope you guys pulled off keeping on here. 60%, no asterisk, that's 60% customer volume. I'll tell you this I mean, I represent network marketing companies. That's high.

It's very high. We know it's high.

Deborah, you lost your video camera.

I'm sorry, hang on. Someone was calling. I forgot to block.

That's the kind of number you see in party plan companies. Right? That's a clean number I've got. You know, I asked folks for questions that they kind of wanted me to ask you. Just full disclosure. I was told not to go near the subject of DSA and what their level of cooperation is. It might be high, might be low. Nobody knows. I'm not going to go there. That's understood. But that was kind of a recurring question. One was Mel Atwood asked, when did you all make a decision to file your lawsuit?

We made the decision.

What was the final straw?

The final straw was when we, when we absolutely ascertained that the only way that they, that the FTC would agree to settle was if we would agree to go to a plan where only the person making the sale and their enroller were allowed to earn income from a product sale, which basically meant that we were going to be taking the businesses away from our brand partners. And we absolutely were not willing to do that. And we tried a million different combinations of offers. I say a million, but we tried three or four different. We'll make this concession. We'll make that concession because it is an expensive, attention, diverting.

Absolutely. They don't lose. They're the Terminator. They just jump in there and.

Well, we really appreciate our brand partners standing behind us at this point because that's the scariest part. We're doing something to protect their business. And, you know, but you still have the reality that it's, it's, you know, our brand partners love our product and they, and they're part of this, part of, part of our business and they have their own businesses, but they also are free to make their own choices at all time, at all times. But our final straw was when we really ascertained that literally the only way they would settle is if we made that concession. And that was just not a concession we were willing to make. And I'll tell you, we made it very late in the process. We made the decision to file the lawsuit against them very, very late in the process because we were hopeful until the 11th hour that we were going to be able to come to some other agreement.

I think, just my opinion, for what it's worth, you hired a really good firm. So a lot of firms that I see, they get in these sorts of cases and they know somebody at the FTC and they pretend to have an inside track and, and nobody knows what the hell is going on inside those places. But they say, well, I used to work at the SEC 10 years ago, or Bob over here worked at the FTC. They don't know any more than you or I and they'll really pressure settlement, which just means that you go out of business. Now the problem is you get the wrong lawyer. A lot of lawyers are risk averse. They don't know what it's like to start a company. They don't know what it's like to invest eight years of your life building a company. And so for some attorneys, it's just easy to advise an entrepreneur. I just walk away, fold the doors, right, because in most cases the attorneys are just salaried employees and they don't know risk. That's a problem that you've got at the FTC as well. You've got salaried people that are pretending to try to protect consumers and try to measure risk and make sure people are taking a healthy amount of risk, which in my opinion, who are they to decide what's a healthy amount of risk or not? But anyways, the lawyers that you have, they seem to be willing to take a risk with you. And for a firm to be adverse to the government, it's a big deal. Hard to find attorneys that'll do it. And just the way I read your complaint, these guys seem to, they've got good brains and they've got some courage.

Well, they've been with us for a long time. They were with us before, before the, you know, the original CID was served. And I think that when it comes right down to sounds really flip, but you know, we're right. We are not, we are not a pyramid scheme. We're in all the guidance and you know, they really, as good attorneys will advise us to settle if at all possible. You do not want to take on, you do not want to take on the government. But there's a certain point where you have to. And since they were with us from the beginning, they know our numbers, they were involved, heavily involved in the data analysis. It just came down to it that, you know, they're, they're willing to, they're willing to step up and do the right thing. In fact, I think like a lot of the companies out there in our industry, it's almost became obvious that it was necessary that somebody do it. You know, we're not, you know, we're not thrilled to be the ones, but if we need to be the tip of the spear. We will be because it's the right thing to do. And if you're in this industry, you understand how many families, how many families benefit? Not full time income benefit, but you know, $200 a week, an extra car payment, something private school for their kids, you know, youth soccer, whatever it is. But families benefit from our industry and, you know, it's kind of an honor and a privilege to be the company that's protecting it. But our attorneys, I think, feel, feel the same way.

Yeah, yeah. Well, good facts make good lawyers and you guys seem to have some good facts on your side. I'll say this anecdotally, my experience with Naora and Nerium reps has been fantastic. My wife is actually a customer. She is one of your 60%, no joke. And the rule is she can't join any programs because I represent, you know, God knows how many of them. But there was a rep, she buys product. So anyway, take that for what it's worth. Real quick regarding, you know, this obligation that you guys have sort of borne on yourselves. Companies do win. So if there's ever been a time to be adverse to the ftc, it is now. So I mean, to state the obvious, the lower district courts are being remade with different justices. There's a case, and this is probably too academic for everybody, but there are a couple of cases now where the FTC is losing power. You know, you guys filed your case in the 7th Circuit in Chicago, and in the 7th Circuit the FTC essentially has lost. So somebody stood up and said, you know what, you guys are pushing too far. We're going to try our odds at looking at the language of what's called 13B. It's the FTC's 13B power. And essentially it says that the FTC can step in if you are currently violating or about to violate the law. Well, somebody says, well, that doesn't apply to you can't sue me for past conduct if we correct. So that company won that case also 13B. It says nothing about money. So that's another 7th Circuit opinion where the 13B gives the FTC power to get an injunction. It says nothing about monetary fines or penalties, discouragement of profit, all that stuff. And for 20, 30, 40 years, the FTC has sort of had this understanding with the courts that we can ask for money. And you get a judge in there in that district and then it was appealed to the 7th Circuit and the judge says, you know what, I'm looking at the language here and it doesn't say anything about money. So go to Congress and change the law, but you have to live with the law. So the point is, without companies willing to push, these agencies just completely spin out of control. And so I think it's great that you guys are in the 7th Circuit because that's what the FTC is having problems. I noticed that they ran to New Jersey in the third Circuit. I wish you guys the best, ultimately.

Well, thank you.

And I don't want to wrap up just yet. I want you to think about anything that we forgot to talk about. And I'm going to look at comments here to give folks an opportunity to ask questions. Here we go. Deborah, has the industry been, for the most part, supportive of you, of you all?

Yes, I would say universally. Probably the biggest shock we've the biggest. The closest you can get to negative is somebody saying, wow, that's bold. But it has been overwhelmingly supportive. Large companies, small companies, DSA member companies, non DSA member companies, vendors, people that service the industry. It's been overwhelmingly supportive. I think a lot of companies have been living under the threat of what is basically an unclear standard. And this is an opportunity, I don't want to say to clarify the standard, but it's certainly an opportunity to say you have to have a standard before, before you can take action. And that's really where you can't make.

Up your own facts. But the 1% retail figure is absolutely pitiful. My last question, I'm almost done here and I forgot to ask this. What triggered the investigation was Tina, and she highlighted some income claims and health claims, and that was referenced in the lawsuit, the eht. Just what sort of measures do you employ to sort of monitor the field and catch that sort of behavior before it gets out of control? What are you currently doing and what have you been doing?

Well, first of all, I want to bring up part of the case which is a bit unusual, is that there's this product named Me Sports mentioned throughout it, which I think is important only because it's a product we never sold or marketed and didn't participate in the marketing of. And if you look at the claims, a significant portion of them are about that product. So I just wanted to put that out there. But what we do is we employ software. We employ software which if I said the name, everybody who's a direct selling company would know who I'm talking about. We police, we have terminated more than 100 brand partners since 2015 for income and product claims. And we've sent between three and 4,000 letters for income and product claims. We are constantly policing in this area, and that's what you have to do. In addition to that, we educate. I mean, we get up at our, at our large events and we talk to people about what they can and cannot say. And one of the interesting things is in the, in, in the suit is that none of that is the company saying that. It's all, you know, things brand partners have said or they've linked one thing to another or they've said, you know, but we, we take action against those. And I think everybody, everybody who runs a responsible company or industry knows about those restrictions and takes action and does the right things, and we're doing those same things. But all you can do is educate and enforce. You know, where you have independent sales forces there. They're going to stand up and say something they shouldn't have said, and then you just have to, you have to come on the back end and fix it. And that's what we do. And we've got a robust. We've got a department of, you know, people sitting here and plus our partners on the software who help us with that as well.

Sure. The reason why I sort of forgot about those issues, I mean, they're important. It's advertising and claims and whatnot. But I think the fundamental issue is the business model. And that's what I'm focused on. That's what the community's focused on. And really, you know, the Marlboro man. Marlboro used to tell people that smoking was safe for children. Marlboro is still in business. So those are the kinds of issues that a company can survive. But being called a pyramid scheme. Clearly the FTC is trying to put you out of business.

Well, we were shocked to have a pyramid scheme allegation because we did open our kimono, we did know our numbers, we did understand the law. We're still shocked that, that. And we thought through negotiations on the incomes and product claims issues that we would be able to come to a resolution that was reasonable and it would allow us to continue. And the reality is they wanted, they were. The FTC was not focused on those things. They were not talking to us about income and product claims. We never had discussions or disputes about that really at all. We had a little bit of dialogue about it, but really nothing, nothing on that side prevented us from coming to a settlement. It was 100%, this pursuit of us being a pyramid scheme that brought us here. And we're not. I mean, fundamentally, that's the issue. We're Not.

Yeah, no, based on what I'm saying, if I thought you were, I'd say it. I mean, 60% retail or preferred customer volume is insane. You know, it's almost like a Rorschach test when people look at the model and it's an ideological test and not to get political at all, but some people think that there needs to be an algorithm that protects people. Right? And it's government's job to create this algorithm and enforce this algorithm. And there needs to be bright line rules. Reality is, it just doesn't work very efficiently because the FTC is run by human beings with, with certain biases and a certain way of looking at things. And those people tend to look at our model and they're just. They just don't like it. Right. They see. Well, a lot of people try and they fail. Thank goodness we don't have the Federal Trade Commission in professional sports. Right. But, you know, they just, they see the model and it doesn't matter how much you or I talk to them and educate them and say, look, I mean, people, yeah, there will never be gain in anything without risk. And for the most part, adults are adults and they can assess that risk on their own. You know, we're not stupid. Well, the ftc, they sort of assume that we're stupid and they want, you know, they just don't like the model. Then the other side of the Rorschach test, when people see the model is, well, let adults be adults. Let people do what they want, and let the market decide if a company's good or not. Anyways, that's me kind of droning on and on. I don't think we'll ever convince the employees in a federal agency to see the world the way we see it, but you can win in litigation and sort of confine their options. And I really hope that's what you guys do long term. I hope you get the support that you need. You know, batten down the hatches. I mean, these guys are pretty aggressive. It's not about protecting consumers. I didn't see any references to victims in the lawsuit. It's about winning. And if they have to sue your kids or if they have to pressure you in any possible way, they're going to do it. So, you know, I just. I commend you for not handing over the company and rolling over and just writing a check. So hang in there.

Well, our owner, Jeff Olson, who is. Who is obviously not on this call, but you see, he's a named defendant. He's very. I'M sure he's very appreciative of those comments. But I, you know, ultimately, you know, we have a culture here of, at Neora, of, you know, we like to. It's real, right? Be real, get real. You know, it's all, it's all about being, Being real. And part of this is, you know, we want to protect. And he, and I know from working with him, I've known him for a long time, but working with him, that ultimately there's no way that we could look, look our brand partners in the eye and say, hey, you know what? You helped us build this company. You're a big part of the reason why we're here, but we're going to run off and do something else. That just was not an option that was open to us. And, you know, we're here to protect their business. And ultimately, at this point, from where we're positioned, you know, the businesses are the more than 20 million people who participate in direct selling the United States. And no, not all of them are going to be successful. We know that about our business. Right, But a lot of them. But at least it's an opportunity. A big part of our industry is, you know, the opportunity to do something. Some people buy that kit and never do anything, never make a phone call. Some people buy a product and try it and think they may want to share it. And then they decide, well, you know what? That's too much hassle, don't have time for that. And other people buy it, sit it on the shelf, and six months later realize, hey, I want to do something with it. I mean, it's a business of personal choice and opportunity, and I think it deserves to be protected. As I said at the top of this call, I really believe in the opportunities that this, I'm calling it an industry, but that direct selling brings. Brings to people. And I hope that this case will ultimately protect them. And I hope that. I hope that everybody understands that this is a long fight. We aren't going to have news tomorrow. It's going to be quite a while. But, you know, the aura is here to stay. So we're here and we're going to write it to the end and hopefully end up with a positive result for our entire industry.

Good for you. All right, well, that's a wrap. Thanks so much, Deborah. I appreciate you taking the time.

Thank you.

And end.