KURT AND CINDY O’CONNELL


kco1Dates of Herbalife Distributorship: 1996 – present
Status in Herbalife: Chairman’s Club
Business Methods: Nutrition Clubs; Training Videos, Calls and Presentations; Recruiting Scripts

All statements in the report are made pursuant to Pershing Square’s disclaimer available at dev-facts-about-herbalife.pantheonsite.io/disclaimer.

 

 

 

 

Background on Herbalife-Related Businesses

  • Kurt and Cindy O’Connell own Freedom Lifestyles Group, Inc., a business that provides training videos, recruiting scripts and other business tools to Herbalife distributors, and promotes ownership of Nutrition Clubs as a way to build a downline organization and generate greater royalty income.  The O’Connells’ Herbalife organization is also referred to as the “Freedom Team.”  See, e.g. the logo on the O’Connells’ www.freedomsupportsite.com website, infra.  Freedom Lifestyles Group is registered as a corporation in Wisconsin (Filing Number:  F043513, registration attached as O’Connell Exhibit A).  The registration filing uses the address 2535 E. Downs Rdg, Appleton, WI 54913, and lists Cindy O’Connell as the registered agent.  The business is also registered in Nevada (Filing Number:  C6945-1993, registration attached as O’Connell Exhibit B).

o   In 2009, a separate entity called Freedom Lifestyles, Inc. merged into Freedom Lifestyles Group.  Freedom Lifestyles, Inc. was registered in Wisconsin (Filing Number:  F032044, registration attached as O’Connell Exhibit C).  The registration filing uses the address 4901 N. Providence Ave., Appleton, WI 54913, and lists Kurt O’Connell as the registered agent.  Freedom Lifestyles Group, Inc. is the surviving entity of the merger.  See O’Connell Exhibit D (p. 2, ¶ D).

  • The O’Connells operate Cool Blenz, an Herbalife nutrition club business registered in Florida (Filing Number:  G08262900264, registration attached as O’Connell Exhibit E).  The registration filing uses the address 10064 Magnolia Bend, Bonita Springs, FL 34135, and lists Kurt O’Connell as the owner.
  • The O’Connells also appear to operate Fuze Nutrition, another Herbalife nutrition club business.  Fuze Nutrition’s Facebook website, https://www.facebook.com/#!/pages/Fuze-Nutrition-Club/109081539164856?id=109081539164856&sk=info, lists http://comm unityweightcenter.com as the club’s official website.  The Community Weight Center website is registered to Kurt O’Connell.  See O’Connell Exhibit F.  The domain registration uses the address 10064 Magnolia Bend, Bonita Springs, FL 34135—the same address listed on the registration filing for Cool Blenz.  The Facebook website also lists Cindy O’Connell, as well the O’Connells’ daughter, Bethany Farless, as members of the “Culinary Team.”  On her LinkedIn website, Farless lists “Wellness Coach at Fuze Nutrition Club” as her current occupation.  See O’Connell Exhibit G, available at http://www.linkedin.com/pub/bethany-farless/28/205/574.  See also https://foursquare.com/v/fuze/4d80e7eb9d78a35d9cf44a0f for the Fuze Nutrition Club address (“3429 West College Avenue, Appleton, WI [54914]”).

Primary Source Data on Business Practices

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  • The O’Connells appear in videos promoting the Herbalife business opportunity.

o   Around 2002, the Herbalife Broadcast Network (HBN) assembled a five-part video series featuring the O’Connells, called “Five-Step Business Training” (the “O’Connell HBN Series”).  See O’Connell Exhibit H (Herbalife’s promotional flier for the O’Connell HBN Series), available at http://www.herbalifeww.com/shared/pdf/News_More_Info_Items/OnnellTape_FLY1.pdf.  In part two of the O’Connell HBN Series, entitled “Your Business—Start-up Stage”, Cindy O’Connell recounts that she and her husband “were struggling financially and we had a dream.”  Cindy later tells recruits that if they want to make “anywhere from a few hundred dollars a month really up to, like, $4,000 a month, you can do that by being in the position on the marketing plan called Supervisor or World Team.”  (27:24-27:35).  She continues, saying, “If you want to be somewhere in that $2,000 to $5,000 a month range, your goal is going to be GET [Global Expansion ] Team.” (28:09-28:16).  The O’Connells outline the expected income for each level, with no disclaimers, as follows:

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o   In part three of the O’Connell HBN Series, entitled “Your Business—Building-Up Stage” and available at https://vimeo.com/user15264273/review/152940247/fd5a1274a4, Cindy O’Connell tells potential recruits that starting an Herbalife business is a low-cost proposition that will quickly turn profitable:  “In my mind, I thought, it takes a lot more money to build this business than it really did.  And when I boiled it right down and actually kinda wrote down what does it cost me to keep my business running every month . . . when I broke it down and added it all up, it really wasn’t that much.  And then when I looked at what the income for my business, how much retail profit was I making, how much wholesale profit was I making, how much royalty profit was I making, how much production bonus was I making, when I was able to add and put that all together I realized, boy, it really doesn’t take that much money to run this business and for the most part, you know, your cash flow is keeping things going and then boom, before you know it, you’re into that profit level.”  (44:58-45:51.)  Kurt O’Connell then makes it clear that recruiting is the primary means by which an Herbalife distributor can achieve a substantial income.  Referring to “royalty income,” he says, “That’s the dream money.  The dream money will come from that royalty, for those of you that are building that big dream.”  (47:58-48:05.)

o   Similarly, in part four of the O’Connell HBN Series, entitled “Downline Mentoring—Keys to Royalties and Wealth”, both Cindy and Kurt O’Connell repeat the point that the bulk of their income is made through royalties from recruiting.  Cindy notes that once they started to “mentor” their downline, their check grew to “over a million dollars last year and our check is still growing.”  (13:58.)  Kurt later adds, “Our royalties have gone explosive.  Okay, explosive.  Explosive, okay?” (15:35.)  Further emphasizing the importance of recruiting, Kurt notes that “[i[f you have a group full of people who also know how to teach, now you can get rich.”  (42:13.)

o   Also in part four of the O’Connell HBN Series, Cindy O’Connell states that “[t]he saddest time that ever comes for me in this business is when somebody quits.  It’s always very, very sad for me because, you know, I think this is the best business in the world.  It’s the best opportunity in the world, it really is.  It’s the greatest opportunity for any person, any circumstance.  I believe that firmly with my whole heart.  You know, I don’t care what the circumstance is, I know that if a person continues to build their business they will become successful to whatever degree they want.”  (47:50-48:17).

o   In part five of the O’Connell HBN series, entitled “Advancing to the Next Level”, Kurt O’Connell reassures new distributors that they do not need to fully comprehend all the details of the Herbalife business model:  “If you don’t understand it all, don’t worry about it.”  (16:33.)  Later, Kurt tells distributors that as long as they “teach” their downline, and then teach their downline to teach other new recruits, their Herbalife business will “duplicate extremely powerfully and you’ll make it . . . .”  (47:47-48:05.)

o   Part five of the O’Connell HBN Series also places a heavy emphasis on recruitment.  As Kurt O’Connell puts it, “What’s that magic word?  Duplication.”  (39:30.)  Kurt tells distributors, “We’re in a business of duplication.  If you learn something from this, you will get paid a whole lot more if you teach it.”  (6:10-6:18.)  Kurt further notes that “it isn’t a complicated thing.  For those of you who are maybe at World Team or Get Team and you’re thinking, ‘Oh, how could I become this great leader?’, you just teach them how to get to where you are.”  (37:34-37:44.)  Cindy O’Connell continues this theme, encouraging distributors not just to “teach somebody how to produce volume,” but rather to “[t]each somebody how to teach somebody how to produce volume.  Then that will automatically push you to the next rung [of the Herbalife marketing plan].”  (38:52-39:02.)  Talking about the advancement from World Team to GET Team, Kurt says, “You’ll notice that things change a little bit here.  Getting to World Team is based on what you do, alright, but getting to Global Expansion Team—the only way you can get there is through royalties produced by your team.  So now it isn’t directly related to what you do that gets you there.  It’s what your team does.  And this is where teaching becomes extremely critical.”  (34:10-34:36).

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o   In a webinar for distributors “Interested in Opening a Nutrition Club,” featured on www.freedompathcenters.com, an O’Connell website that provides training videos for new Herbalife distributors,2, and available at https://vimeo.com/user15264273/review/152940249/16b9f4ce06, Kurt O’Connell provides new recruits with exaggerated claims of income growth while discussing the Herbalife business opportunity generally:  “We broke a six figure income inside of our fourth year in business.  Others have gone faster than us, a lot of others, but that was pretty darn good for us.” (4:18.)

o   Another promotional video, available at https://vimeo.com/user15264273/review/152940248/db3f055874, features the O’Connells describing their rise through the Herbalife marketing plan.  Referring to their advancement from GET Team to Chairman’s Club, Kurt O’Connell notes that “we were recruiting people, but not investing that amount of time into teaching them and helping them and making sure they learned what they needed to learn.”  Cindy O’Connell then states that “[w]e went from a very low income to a very high income so quickly that it really took a while to even sink in what kind of money we were making because I was so used to living my life on that budget.”  The video then presents photographs of the O’Connells’ Wisconsin home as the couple discusses their new “lifestyle.”  Cindy O’Connell remarks that she needed to choose between marble or limestone and exotic hardwood or local hardwood flooring when building the home.

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o   Speaking to an audience of distributors at Herbalife’s 2010 Los Angeles Extravaganza, Cindy O’Connell once again speaks about her rise from financial difficulty to building her “dream home.”  “You have to understand, we came from less than nothing.  We had, we were in the poverty level according to American standards with our income. . . .  We were poverty-stricken.”  (0:37-0:52.)  She continues by explaining how Herbalife has enabled the O’Connells to build their “dream home without any budget limitations.”  She recounts that the couple traveled to France to shop for antiques at a Paris flea market with a hired professional shopper.  “I spent $100,000 in like five minutes,” she says.  (1:19 – 2:11.)  Kurt O’Connell then goes on to teach the audience that “Duplication is the key to stable royalties.”  (5:23-5:39.)  Kurt clarifies that “recruiting is not duplication,” but rather “it gives you the potential to duplicate. . . .  [W]hen you recruit, make sure you have a commitment to support [that new distributor]”  (7:26-7:37.)kco5

 

o   During the same speech at the Herbalife Extravaganza, while explaining that “intentional duplication beats passive duplication,” Kurt draws a pyramid on a pad of paper when demonstrating for the audience how to “duplicate” within one’s Herbalife organization. See https://vimeo.com/user15264273/review/55671595/9550332c3c Speaking to the alleged ease of moving up through the Herbalife marketing plan, Kurt states that “it’s not complicated stuff.  Tell, show, try, do.”  (0:59.)

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  • Kurt and Cindy O’Connell also appear in videos and audio clips promoting their Herbalife organization, Freedom Team.

o   In one such audio clip, available at https://soundcloud.com/#hlfaudio/05-collecting-referrals,4 Kurt O’Connell explains that Herbalife distributors cannot make substantial income by selling Herbalife products to retail customers and should focus their efforts on recruiting new distributors into the scheme:  “If we’re someone who says, look, I’d like to make Herbalife my career and to make enough money in Herbalife for that to be my career, then you need royalty income.  And royalty income will only come and grow stable if you are adding active supervisors on two, three, four, five, six levels deep.  So the goal is always to have new distributors joining the team and new distributors who will work their hot list. . . .  [A] retail income is not enough to support us.  Retail income is there, we all need customers, it supports the marketing plan, but retail and wholesale that come basically from sales will not be enough for a substantial career.”  (0:48-1:50.)

o   Kurt O’Connell frequently posts videos promoting the Freedom Team organization on his Facebook website, available at https://www.facebook.com/kurt.oconnell.10.

 

 

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o   In a video featured on www.freedompathcenters.com, Farless states that “[w]hen I started my business, I made $700 my first month part time, which was way better than my [minimum wage] job. . . .  Since then, my income has skyrocketed.  Since going full time, in the last twelve months, I’ve made almost $70,000, and I’m projected to go to a six-figure income very soon.”  See http://freedompathcenters.com/bethany_interview.  Farless tells distributors that success is easy and virtually guaranteed.  “You really don’t need to figure out anything on your own. . . .  Once you start to actually see the plan working the way it’s supposed to, you honestly feel like it should have been harder and all of a sudden your life is just going way better than it ever did before, and it’s really like a dream come true, literally.”

Recruiting Materials

  • At Herbalife’s 2011 Las Vegas Extravaganza, Kurt O’Connell delivered a presentation entitled “Building Your Royalties.”  See O’Connell Exhibit I, available at http://open.nutrition-for-us.com/Herbalife/548-2011_Ext_OConnellKurt_usen.pdf.  The presentation explained that the “Essence of Royalty Income” is “Othersthat you train sell” and “you get paid.”  Id. at 5.  O’Connell further notes that “[t]he key to royalty growth” is “[n]ew distributors qualifying as Supervisor every month.”  Id. at 8.  To illustrate his point, O’Connell uses the familiar pyramidal diagrams that appeared during his 2010 Los Angeles Extravaganza speech (supra) and in his Freedom Team nutrition club webinar (infra).  Id. at 7, 15.

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o   The Freedom Support Site encourages members to fill out “profiles” of nutrition club customers, which collect information that members can use to recruit new distributors.  See http://www.distributorsupportsite.com/profile_documents,5 which offers the following different profile options:

o   The O’Connells also provide Freedom Team members with a telephone script aimed at persuading potential recruits to visit the member’s nutrition clubs and provide information for a “profile,” attached as O’Connell Exhibit J (dated Sept. 17, 2013) and available at http://m.b5z.net/i/u/6149163/f/Business%20Startup/002%20Enrollment/Practice_Profile_Invitation_Script.pdf.  Members are instructed to call a potential recruit and claim that they “need to practice doing Metabolism Profiles as part of [their nutrition club operation] training.”  In exchange for “helping [them] out,” distributors are told to offer the recruit a free smoothie.  Even if the recruit rejects the invitation, the distributors are told to offer them a “coupon for a free smoothie and energy drink at (Nutrition Club Name).”  On the first page of the script in a boxed-off section entitled “READ FIRST!”, the script sets forth the Freedom Team’s “Lead Assignment policy” governing which team member can claim the new recruit as part of their downline (see infra  for more details on the O’Connells’ lead assignment policy).  See also http://m.b5z.net/i/u/6149163/f/Retail/Presenting/Wellness%20Profiles/How_to_Ask_For_Referrals_During_a_Profile_v2.pdf for a script that members can use to ask recruits to refer other potential recruits.

  • The Freedom Team organization creates incentives for members to fill out profiles of nutrition club visitors by offering prizes for every ten profiles completed.  The Freedom Team’s January 2014 “Club Profile Blitz” worksheet, attached as O’Connell Exhibit K,6 states that after filling out 20 profiles, the distributor will receive touchscreen gloves, and after 40 profiles, the distributor will receive an Herbalife duffle bag.

o   One training worksheet, attached as O’Connell Exhibit L and available at http://m.b5z.net/i/u/6149163/f/The%20Profile/Introduction/Profile_Overview_Flow_Chart.pdf, states that “The Bottom Line” is transforming leads who visit nutrition clubs profiles into customers, and transforming customers into distributors — a.k.a. “Royalty Express Passengers.”

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o   The Freedom Support Site promises immense profits from the operation of a Nutrition Club.  In a “Financial Analysis” information sheet published on the site, attached as O’Connell Exhibit M and available at http://r.b5z.net/i/u/10108042/f/Financial_Analysis.pdf, the O’Connell’s tell members they can earn $2,864.02 in monthly profit just from selling shakes, teas and aloe at the club.  They estimate a 44% profit margin.

o   The Freedom Support Site provides a presentation for distributors to use when conducting Herbalife Opportunity Meetings (HOMs).  The presentation tells recruits that they can make an annual royalty income of $105,300 by recruiting three distributors into their downline who then each recruit three more distributors into a downline of their own.  See O’Connell Exhibit N at 18.7

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Website Registrations

Nutrition Clubs

  • The O’Connells run two Herbalife nutrition club businesses:  Cool Blenz and Fuze Nutrition.  Fuze Nutrition maintains a “Nutrition Bar” and runs free “Fit Camps” and “Fit Challenges” to attract new visitors to the club.  See generally https://www.facebook.com/pages/Fuze-Nutrition-Club/109081539164856.
  • The O’Connells provide Freedom Team members with training materials on how to recruit new distributors using Herbalife nutrition clubs.

o   The O’Connells produced a webinar entitled “Interested in Opening a Nutrition Club?”, available at https://vimeo.com/user15264273/review/152940249/16b9f4ce06.  See also supra.  Kurt O’Connell describes nutrition clubs as “a method of building business.”  (6:24-6:39.)  Speaking about the “minimum start up costs” associated with opening a nutrition club, Kurt states that “[t]his is within reach of virtually anybody, any average person, in the United States today” (9:18-9:24), and claims that he has “seen people get these things started with less than they would spend on their Christmas present budget” (11:12-11:22).  Describing the financial mechanics of a club, Kurt notes that the “earnings structure is powerful.  This is not like a job.  This is not like a typical business where you have employee costs.  It’s not a typical franchise where you have to pay royalty fees up to the owners.  This is absolutely reverse.  [Herbalife] actually pay royalties back to us.  [Herbalife] will actually pay you royalty.”  (11:25-11:49.)  Indeed, Kurt makes clear that the nutrition club business model is primarily focused on recruitment, not consumption, saying, “it’s really amazing.  You bring customers in and then they expand to go open these clubs, as well, and then you collect royalties as a result.  So it’s pretty cool.”  (28:42-28:52.)

o   The webinar then presents a series of misleading claims regarding income potential for nutrition club operators.  Kurt presents a slide entitled “Owning a Nutrition Club is Affordable,” which states in separate bullet points that “Break Even” is “often 1 to 3 months,” and cash flow of “$10,000+ by month 6th [sic] is common.”  (12:46-13:56.)  Later, Kurt displays a series of pyramidal diagrams to explain the “powerful” income possibilities available to a nutrition club owner.  Kurt tells the viewer that “as [the clubs] duplicate, here’s the thing.  Remember I told you  can get that royalty.  When those customers—or maybe you have a friend who wants to learn how to do this as well—when they learn and open a club then the product supplier will compensate you royalty based on their volumes as well.”  (38:08-38:32; see 36:49-39:42 for diagrams.)  Describing the “typical” results that can be expected from operating a club, Kurt states that “[a] typical club, the typical Nutrition Club, by the time it matures a handful of months in, produces around 10,000 in retail a month, ok?  Our club last month did over 30,000, and that club, the doors have only been open on that, that was 11 months on that club.”  (36:51-37:13).

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  • The O’Connells “mentor” other Herbalife nutrition club owners who also make misleading claims about the supposed ease with which large amounts of money can be made by running a nutrition club.

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https://www.facebook.com/kinutrition#!/photo.php?fbid=709881809044811.

  • The O’Connells require a Freedom Team member who wants to operate a nutrition club to attend several different training sessions before receiving a certificate of completion.

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http://m.b5z.net/i/u/6149163/f/TAB%20Team/Freedom_Team_Club_Cert_Doc.pdf.8

  • The Freedom Team has strict rules concerning “lead attachment”—the assignment of a club visitor to a particular upline—in a document entitled “Club Lead And Member Assignment Policy.”  See O’Connell Exhibit O, dated Oct. 25, 2013 and available at http://m.b5z.net/i/u/6149163/f/Nutrition%20Club/Club%20Policy/Club_Lead_Assignment__Policy.pdf.  The rules state that “[t]he first time a person steps into the club or club program, the person is immediately attached.  The club team now must determine who they are attached to basing the decision on the answer to ‘Why did this person step in?’    . . .  All Club team mates who assist first time visitors to the club are to do their best to determine who the visitor is attached to.  This may require some investigative questioning . . . .”  Id.

o   In a section of the Club Lead and Member Assignment Policy called “Training Your Clients,” the O’Connells require their downline distributors to “teach and train” their “clients”—a.k.a. “attached leads”—to purchase products from their upline within the O’Connell organization, which increases the Herbalife royalty payment opportunities for the Freedom Team.  Id.

Links to Other Senior Distributors

  • In a 2006 consolidated class action lawsuit in Los Angeles superior court, the plaintiffs sued Herbalife, the O’Connells’ Freedom Lifestyles Group, and Vertical Skip Marketing (VSM), which is a lead generation business operated by Paul Michaels and Mark Zuckerbrod.  See O’Connell Exhibit P (Complaint, Minton. v. Herbalife International Inc., et al., No. BC338306 (Super. Ct. L.A. Cnty. Jan. 17, 2006)).  Plaintiffs alleged that by selling lead generation systems laden with “fraudulent earnings claims and fraudulently omit[ted] material facts concerning the Herbalife ‘business opportunity,’” Freedom Lifestyles Group and VSM committed common law fraud and violations of the California Endless Chain Scheme law (Cal. Penal Code § 327) (i.e., California’s pyramid scheme law), among other violations.  See Id. at ¶¶ 1-9.  Herbalife and its co-defendants settled the Minton action in late 2009 for an undisclosed amount.
  • The O’Connell’s were guest speakers at the 2011 Dallas Herbalife Leadership Development Weekend (“Dallas LDW”).  The Dallas LDW was organized by and promoted on www.dallassts.com, which is registered to Chairman’s Club member Dan Waldron (domain registration attached as O’Connell Exhibit Q).  Dallas STS’s Facebook page is administered by President’s Team member Michael Burton (see https://www.facebook.com/dallassts/info).

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https://www.facebook.com/permalink.php?story_fbid=154931231236506&id=148616501867979&stream_ref=2.

Links to Herbalife Corporate Leadership

  • The O’Connells were featured in a 2002 edition of Herbalife Today, a magazine published by Herbalife, upon qualifying for the Chairman’s Club.  See O’Connell Exhibit R for full issue, available at http://factsaboutherbalife.com/media/2012/12/86.pdf.  After describing the couple’s former financial struggles, the article featured photographs of their new mansion and “$50,000 Mercedes sport utility vehicle.”  Id. at 3.  The article further noted that “[e]ach [O’Connell] daughter will have her own bathroom with whirlpool.”  Id. at 4.  The article quoted the O’Connells as saying, “Last year we made more than $1 million, and we make more than $100,000 a month now,” and, “We get to stay at home with our kids and go on vacation whenever we want.”  Id.

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  • In earlier editions of Herbalife Today, Herbalife profiled the O’Connells’ rise to Millionaire Team (1999) and President’s Team (2000) with articles that each (1) mention the O’Connells’ financial struggles before they discovered Herbalife; (2) note that Kurt was able to quit his job of 19 years after just 11 months in the Herbalife business; and (3) conclude with a reference to their current substantial monthly income (“over $20,000 a month” in 2000).  See http://factsaboutherbalife.com/media/2012/12/63.pdf at 18; http://factsaboutherbalife.com/media/2012/12/67.pdf at 13.

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  • A 2003 edition of Herbalife Today included a two page article advertising the O’Connells’ five-part video series on “duplication.”  See http://factsaboutherbalife.com/media/2012/12/96.pdf at 11-12; see also supra for details on this five-part series.
  • In 2003, Herbalife awarded the O’Connells the Mark Hughes Bonus Award—a large, discretionary bonus that Herbalife awards to top distributors.

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Available at https://dev-facts-about-herbalife.pantheonsite.io/content/uploads/2016/02/97.pdf at 4.

  • The O’Connells presented at Herbalife’s 2003 Las Vegas Extravaganza (see https://dev-facts-about-herbalife.pantheonsite.io/content/uploads/2016/02/100.pdf at 3), 2010 Los Angeles Extravaganza (see supra), and 2011 Las Vegas Extravaganza (see supra).
  • The O’Connells are featured speakers on Herbalife’s Chairman’s Club Tour.  Cindy O’Connell appeared at these Herbalife-sponsored events as recently as December 2013, speaking in Oklahoma City, OK, and Dallas, TX. The Herbalife flier promoting Cindy’s Chairman’s Club Tour quotes Kurt O’Connell as saying, “Eventually, our income increased so much that it allowed me to quit my job!”

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http://herbalifemail.com/1New/Flyers/2013_CC_TourCity_CindyO_usen.pdf.

 

 

[1] To the extent that any of the videos in this report requires a password, the password is “oconnell”.

[2] While the site’s domain registration is private, Kurt O’Connell refers to “Freedom Path Events” on his Facebook website.  See screenshot infra; see also https://www.facebook.com/kurt.oconnell.10/posts/1421228251453698.

[3] The original source for this video is http://www.freedompathcenters.com/nutrition_club?pass=enter.  The password is “enter”.

[4] The original source for this audio clip is http://distributorsupportsite.com/collecting_referrals, which requires an email address and password.

[5] As noted above, the O’Connells’ www.distributorsupportsite.com website requires an email address and password.  Once a Freedom Team member is logged in, the member is redirected to http://m.b5z.net or http://r.b5z.net websites—the final source destinations that host the given recruiting materials.  For the purposes of this Report, we include links to the final source destination to avoid the need for personal log-in information.  Through our investigation, we have confirmed that each of the documents cited in this Report is hosted on www.distributorsupportsite.com, or was hosted there within the past year.

[6] Originally available at http://m.b5z.net/i/u/6149163/f/Promotions/2014.January.Club_Profile_Blitz.pdf, but now http://m.b5z.net/i/u/6149163/f/Promotions/2014.May.Club_Profile_Blitz.pdf.

[7] Originally available at http://m.b5z.net/i/u/6149163/f/Retail/Presenting/Discount%20Customers/Pitchbook_v3.pdf, but no longer active.  While the exact slides are not visible, the content from those slides is still available on a Google cached version of the former website:  http://webcache.googleusercontent.com/search?q=cache:I7PySx1YV1kJ:m.b5z.net/i/u/6149163/f/Retail/Presenting/Discount%2520Customers/Pitchbook_v3.pdf+&cd=1&hl=en&ct=clnk&gl=us (see p. 56 for text from the above-cited slide).

[8] While the original www.distributorsupportsite.com link that hosted this chart is no longer active, we believe the O’Connells have moved this chart to http://distributorsupportsite.com/tab_team1, which also requires an email and password log-in.