Direct Selling Self-Regulatory Council Refers Income and Incentive Trip Claims to the Federal Trade Commission
New York, NY – October 21, 2019 –The Direct Selling Self-Regulatory Council (“DSSRC”) has referred certain marketing claims made by MojiLife, LLC (“MojiLife” or the “Company”) for its home fragrance products to the Federal Trade Commission for possible enforcement action after the Company failed to fully participate in the self-regulatory process. At issue in DSSRC’s inquiry were income representations concerning the amount of money that MojiLife distributors could reasonably expect to earn from selling the Company’s products as well as claims regarding incentive trips that could be earned by distributors of the Company.
DSSRC is the direct selling industry’s self-regulatory forum and a division of BBB National Program, Inc.’s self-regulatory and dispute resolution programs. The subject marketing for MojiLife came to the attention of DSSRC through its own independent monitoring of the direct selling marketplace. Specifically, DSSRC requested substantiation for both the income representations made by salesforce members and the incentive trip claims made on the Company’s website.
The income claims reviewed by DSSRC were representative examples of those made generally in the marketplace on behalf of MojiLife and included:
- “Groceries🍏 Credit card debts💳 private school tuition 👧🏼👦🏼 bills💸 vacations🌴 cars🚗 homes🏡 tithe more 🙌🏻, hobbies/sports for kids🥁🎸🏀🏀🏈⚾️, etc.”
- “If you’re looking to replace your income, add to your income, pay off debt, build your savings, or have some fun money, then MojiLife is for you!!”
- “Fast forward only 2 1/2 years and we are now proud home owners again 🏡, we were able to purchase a new truck, took our first of many family vacations & have been living life to the fullest since!”
- “Work at Home Moms – More time with family. No boss. Make great money.
Baby Boomers – Sock Away Some Retirement
College Kids – Pay off student loans and not have to start off with new career without all that debt.
Realtors – Steady income when market is low.
And the list can go on with benefits!
Did you also know, my business (MojiLife) can help you with, your taxes, no worries if a layoff from job comes, retiring early, have more money to enjoy with family or needs, and can also make difference in someone’s like for a safer product!”
On the Company’s website, MojiLife makes claims regarding incentive trips that can be earned by the Company’s distributors. The representative claims that were the subject of this review are as follows:
- “Escape the mundane—earn incentive trips and getaway on a pay-cation! MojiLife pays, you vacation!”
- “Escape from the mundane
Paradise awaits! Are you ready to escape the mundane? Do you need a retreat from reality? MojiLife has just the ticket and this ticket can lead to locations of pure bliss all around the world! The ‘Life Getaway’ incentive trips are just what the doctor ordered to de-stress and unwind. You need a little more Vitamin Sea! Past destinations have included a California retreat to the beaches of San Diego with some theme park fun at the ‘happiest place on earth.’ Cruises have set sail to the Grand Caymans and Cozumel. MojiLife is your escape destination. Earn an incentive trip, MojiLife pays, you vacation! Pay-cation has never been better. Bon voyage with MojiLife!”
DSSRC brought the representative claims identified above to the Company’s attention by letter dated August 7, 2019 and requested substantiation for such claims. MojiLife responded by email on August 26, 2019 stating that it was MojiLife’s position that neither MojiLife nor its Distributors made any improper earnings claims. The email response also stated that the Company’s incentive trips claims on the Company’s website highlight a common program used by other direct selling companies.
By letter dated September 11, 2019, DSSRC reiterated its concerns with respect to the representative claims identified above and requested substantiation for such claims. MojiLife did not respond and was thereafter unresponsive to DSSRC’s additional efforts to contact the Company.
MojiLife ceased its participation in the DSSRC self-regulatory forum and did not respond to DSSRC’s repeated efforts to contact the Company. In accordance with DSSRC’s Policies and Procedures, in the event the company whose marketing is the subject of a DSSRC inquiry fails to participate in the self-regulatory process, DSSRC may refer the matter to an appropriate government agency for review and possible law enforcement action. Accordingly, DSSRC will refer this matter to the appropriate government agency.
DSSRC’s full written decision is available at: https://bbbprograms.org/programs/dssrc/dssrc-decisions/case-6-2019--monitoring-inquiry--mojilife-llc.
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