A very long time ago I ordered a product from M.O.R.E. Inc. called “Dialing for Dollars”. It was a pretty decent product – especially for the time – about using automated answering machines as part of a 2 step direct mail sales process.

It included information about risks involved and was pretty well laid out step by step.

However, immediately after that I remember getting bombarded with direct mail from M.O.R.E. Inc. that made some extremely outrageous claims. I’m going from memory here, but I think one had to do with making a bunch of money just by “mailing two letters” and another had to do with becoming a list broker (which requires a lot of specialized knowledge to do correctly).

Apparently the outrageous claims haven’t stopped according to a recent BBB review of M.O.R.E. Inc.’s advertising practices:

“Advertising Review

The company has failed to substantiate advertising claims when requested by the BBB on December 21, 2007 and February 7, 2009.
The business claims the following through mailings and faxes:

• Average customers have earned between $20,000 and $100,000 per month
• $10,000 can be earned in the first week prior to “know(ing) anything;
  and
• the referenced bonous gifts are worth $97,760.

The business has also sent out mail and fax communications stating that their firm is having “big problems” and asking the recipient to assume an equity position in their firm. The BBB requested that the business clarify the nature of the problem and they failed to do so.”

Before proceeding I should mention that I don’t know the exact procedures that the  BBB uses to verify that advertising pieces are actually from the company in question and haven’t been modified or created by a third party.

Also, considering that that company has been in business for 15 years, the complaint history

If this BBB report is accurate, then obviously those are some pretty bizarre claims, not to mention that if M.O.R.E. Inc. was truly offering an equity position in their firm they would possibly be violating SEC regulations on private offerings:

“B. Private Offering Exemption

Section 4(2) of the Securities Act exempts from registration “transactions by an issuer not involving any public offering.” To qualify for this exemption, the purchasers of the securities must:

• have enough knowledge and experience in finance and business matters to evaluate the risks and merits of the investment (the “sophisticated investor”), or be able to bear the investment’s economic risk;
• have access to the type of information normally provided in a prospectus; and
• agree not to resell or distribute the securities to the public.

In addition, you may not use any form of public solicitation or general advertising in connection with the offering.

The precise limits of this private offering exemption are uncertain. As the number of purchasers increases and their relationship to the company and its management becomes more remote, it is more difficult to show that the transaction qualifies for the exemption. You should know that if you offer securities to even one person who does not meet the necessary conditions, the entire offering may be in violation of the Securities Act.

Rule 506, another “safe harbor” rule, provides objective standards that you can rely on to meet the requirements of this exemption. Rule 506 is a part of Regulation D, which we describe more fully on page 24.”

You can read the full BBB report on M.O.R.E., Inc. here

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