Melaleuca Loses Important Ruling in Idaho

by louabbott on December 5, 2010

Portion of Statement of Policies “non-solicitation” clause ruled illegal in a summary judgment that could have far reaching effects for independent contractors with other multilevel marketing (MLM) companies as well

At the heart of a large number of lawsuits in multilevel marketing (a.k.a. network marketing) enterprises, is the question of what rules should govern the business behavior of a distributor (associate, independent consultant, IBO, etc., whatever the designation in the particular company) when that distributor decides he or she wants to work with another company.

For example, here are just some of the questions that arise regarding Distributor A of Company A:

  • Can a distributor for Company A participate in other MLM companies or businesses in general?
  • Can a distributor of Company A “recruit” or sell the products of Company B to any other distributors in Company A?
  • If so, which distributors? Ones they knew before they joined Company A? Only distributors who were personally sponsored into Company A by Distributor A? Or none at all?
  • If Distributor A quits or is terminated by Company A, then should there be a “non-compete”  or  “non-solicitation” clause?
  • If so, for how long? What activities would be covered by the clause?

These are not easy questions to answer to make sure that Distributor A has the appropriate freedoms of being an Independent Contractor while making sure that Distributor A does not hurt other distributors in Company A and other distributors in the sales organization that he built with Company A.

In Melaleuca, the associates are called “Marketing Executives” and are, like with other companies, legally defined as independent contractors. The non-solicitation provision in this case is defined in Melaleuca’s Statement of Policies and Definition of Terms at Policy 20.

The parties’ chief disagreement concerns the applicability and, importantly, the legality of Policy 20 of this Policy as part of Melaleuca’s Independent Marketing Executive Agreement (IMEA).

Below are some of the pertinent sections of Melaleuca’s very long Policy 20. Non-Solicitation and Conflicts of Interest as discussed in Judge Jon J. Shindurling’s Opinion, Decision and Order for Summary Judgment filed December 3rd, 2010 in Bonneville County Idaho:

Policy 20 is a lengthy section of the IMEA entitled Non-Solicitation and Conflicts of Interest. It forms the basis of Melaleuca’s complaint against the Foellers. The Foellers argue that Policy 20 contains an illegal liquidated damages provision and that Melaleuca’s cause of action is barred under Idaho law.

Policy 20 allows Melaleuca contractors to participate in other business activities while they work for Melaleuca. However, the IMEA contains a number of limitations on the competing business activities. The relevant limitation is: “During the period that their Independent Marketing Executive Agreements are in force Marketing Executives and all members of their Immediate Household are prohibited from directly, indirectly or through a third party recruiting any Melaleuca Customers or Marketing Executives to participate in any other business ventures.” –Policy 20 (a)(i).

The IMEA Melaleuca Definitions of Terms defines “recruit” as:

1) To attempt to enroll, enlist, or solicit an individual or entity to join a business, program or organization; or 2) to attempt to promote, influence or encourage an individual or entity to join a business, program or organization; or 3) to present, or participate or assist in the presentation of a business, program, organization or its products. To constitute recruiting, such efforts or attempts may be performed either directly through personal contact or indirectly through a third party.

The policy goes so far as to state that such activities are violations “even if the Marketing Executive (ME) does not know that the prospect is also a Melaleuca Customer or Marketing Executive.”  For example, if the ME presented on a national call or webinar for the new company and a Melaleuca ME was on the call, that would apparently be a violation of Policy 20.

Policy 20 also states:

Violation of any provision of this Policy 20 constitutes a Marketing Executive’s voluntary resignation and cancellation of his/her Independent Marketing Executive Agreement, effective as of the date of the violation, and the forfeiture by the Marketing executive of all commissions or bonuses payable for and after the calendar month in which the violation occurred. —Policy 20(c)(i).

Note that it was this particular provision of the policy, Policy 20(c)(i), that was at the heart of Melaleuca’s Motion for Summary Judgment in their case against Rick and Natalie Foeller, NOT the whole non-solicitation policy. (Non-solicitation clauses are generally regarded as necessary and important parts of any MLM company’s policies.)  But, this is one of the provisions that put real teeth in to Melaleuca’s whole policy.

Melaleuca argued that the quoted provisions of the IMEA allow it to demand repayment of all commission payments since June 2008, when the first violation of Policy 20 was alleged to have occurred.

The Foellers argued that the forfeiture provision of Policy 20 constitutes a liquidated damages policy and an illegal penalty.

Interestingly, the judge argued that it really didn’t matter whether the clause was a liquidated damages clause or not and ruled that the clause was not allowed by Idaho contract law in any case:

However it is not necessary for a provision to be styled as a liquidated damages clause in order for it to be an illegal penalty. “[W]here the forfeiture of damage fixed by the contract is arbitrary and bears no reasonable relation to the anticipated damage, and is exorbitant and unconscionable, it is regarded as a ‘penalty’, and the contractual provision therefore is void and unenforceable.” Magic Valley Truck Brokers, Inc. v. Meyer, 133 Idaho 110, 117, 982 p.2d 945, 952 (Ct. App 1999).

Clauses intended to punish a breaching party are not allowed in Idaho contract law.

Melaleuca states that the amount requested is reasonable because it exactly matches the damages Melaleuca suffered as a result of paying commissions to the Foellers. This argument is unconvincing based on the evidence currently before this court. Melaleuca seeks to retroactively take money paid to the Foellers for sales commissions; there is no argument or evidence that these commissions were not tied to profitable sales as a result of the Foellers’ work as contractors for Melaleuca or that these are recognizable damages. Rather it appears that, lacking other evidence, Policy 20(c)(1) acts solely to “deter a breach or to punish the breaching party.”

There remains a genuine issue of material fact as to what damages Melaleuca suffered as a result of the Foellers’ recruitment of Melaleuca customers and executives into Max. Summary judgment is not appropriate on this issue and will be denied.

In other words, there was no evidence presented that Melaleuca did not profit from the sales that produced those commissions, in fact, there was no evidence presented that Melaleuca had been damaged at all by the Foellers’ alleged breach of Policy 20. If the judge allowed Melaleuca to reclaim those commissions paid after the alleged breach of the contract, it would allow an “illegal penalty” (and policy provision) that sought only to punish the breaching party to be enforced and, very probably, an injustice to rendered.

Over the years, how many times have we heard of companies taking away a distributor’s business over alleged violations of similar rules in the company’s P&Ps?

In many of those cases, might the forfeiture of the distributor’s entire business and income stream be an “arbitrary” penalty that bears no “reasonable relation” to the real damages sustained by the company and be “exorbitant and unconscionable?” There is no question that may be true many times, and not true other times.

Should not the punishment fit the crime?

It is important that these matters be handled in a way that is just for all concerned.  And that rarely is as easy as taking away a business and income stream that a distributor, and independent contractor, may have worked many years to build over policy infractions that may have cost the company little or nothing in actual damages.

[Bold fonts are inserted by the author of this post.]

Natalie Foeller’s Facebook page carried this post dated the 3rd of December:

Attention all networkers: I have been hoping that this day would come….Melaleuca sued us 1 1/2 years ago and so far has not won any motion against us. Today, they had their biggest loss. Melaleuca proudly say they never lose a case, well they sure did today! This is a huge set back for Melaleuca and a huge win for those that will come up against them in the future!

December 11, 2010 update: We received a letter of response from Melaleuca’s General Counsel, Ryan D. Nelson.  Here are a few of the points included in the letter:

First, you repeatedly refer to Melaleuca’s Policy 20, the clause addressed by the Court, as a “non-compete clause.” Policy 20 is not a non-compete clause; it is a non-solicitation clause. There is a significant difference between a non-compete and a non-solicitation clause. Marketing Executives are free to leave Melaleuca and join a competitor at any time without violating Melaleuca’s policies.

Editor’s Comment: Thank you.  We have modified the post to reflect the more accurate terminology.

Second, your statement that a clause in Melaleuca’s policies was “ruled illegal” is completely inaccurate. The Court did not find that any part of Melaeluca’s policies are illegal. To the contrary, other courts — including the Court that issued the Foeller decision — have consistently upheld Melaleuca’s Policy 20 as an enforceable provision. In this case, the Court merely found that the exact amount of damages should be decided by the jury at trial and not by the judge. … The exact damages the Foellers caused are far greater than what Melaleuca originally asked for. The Court’s ruling allows Melaleuca to go back and request a much greater amount from the Foellers than what Melaleuca originally had asked for.

Editor’s Comment: In discussing the specific clause in question in Policy 20, I will repeat what Judge Shindurling wrote, “However it is not necessary for a provision to be styled as a liquidated damages clause in order for it to be an illegal penalty. ”  And concludes with this decision, “Melaleuca states that the amount requested is reasonable because it exactly matches the damages Melaleuca suffered as a result of paying commissions to the Foellers. This argument is unconvincing based on the evidence currently before this court. Melaleuca seeks to retroactively take money paid to the Foellers for sales commissions; there is no argument or evidence that these commissions were not tied to profitable sales as a result of the Foellers’ work as contractors for Melaleuca or that these are recognizable damages. Rather it appears that, lacking other evidence, Policy 20(c)(1) acts solely to “deter a breach or to punish the breaching party” which he previously equated to being an illegal penalty. I suppose even attorneys may have different opinions on what is being said by the Judge.  This is mine.

Third, far from being “a huge set back for Melaleuca,” as asserted by Natalie Foeller in her Facebook posting republished in your Article, the Court’s ruling vindicates Melaleuca’s claims against the Foellers. In particular, the Court recognizes that the Foellers violated Melaleuca’s Policy 20 non-solicitation policy, noting that “the Foellers enrolled a number of Melaleuca customers in Max programs while receiving Melaleuca commissions.”

Finally, your discussion of companies “taking away a distributor’s business” for “policy infractions that may have cost the company little or nothing in actual damages” is misplaced and misleading. The Court, of course, does not address that issue at all. Melaleuca’s ability to terminate Marketing Executives who violate Policy 20 has been well established by previous courts. And, there is no indication whatsoever in the ruling that the Foellers’ violations cost Melaleuca “little or nothing in actual damages” as you suggest. To the contrary, Melaleuca is confident that as this case proceeds, it will be established that the total amount of damages the Foellers owe Melaleuca is many times greater than the $23,856.41 originally sought through this motion.

Editor’s Comment: Agreed. The court did not discuss the issue of “taking away a distributor’s business” for “policy infractions that may have cost the company little or nothing in actual damages” nor did I say that was true in the Foeller’s case.  I certainly don’t know all the facts in the case.  (I do wonder why, if Melaleuca had more evidence of being damaged, that Melaleuca did not present it.) That said, many distributors do think that this happens in the industry at large at times. Therefore, in my opinion the comments are not “misplaced” or “misleading” considering the larger context of the entire post.

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{ 13 comments… read them below or add one }

Ken Klocke March 11, 2015 at 5:52 pm Thumb up 1 Thumb down 0

” I believe Melaleuca, Inc. is an operating an “Illegal pyramid scheme.” I also believe – when the FTC/ FBI/ CIA does a Judicial review / Federal Investigation, and has the advantage of a clear understanding of what’s gone on, and what’s really going on the “Federal Government” will agree. “Vander Nat Journal of Historical Research in Marketing”

“No Recruit No Pay™” ~KK

I pray for a full ± Federal Investigation of Melaleuca, Inc. and it’s enabling bodies. Treasures, Ken Klocke ‘Concerned Veteran/ Freedom Fighter. Δ “Whistleblower” Idaho State Bar •Federal Bar


John Counsel January 5, 2012 at 1:40 am Thumb up 1 Thumb down 0

Living and doing business in Australia certainly has its advantages. None of this stuff holds a candle under Australian commercial law. Companies that try this kind of antic soon find themselves staring down the barrel of prosecutions by the ACCC (Australian Consumer and Competition Commission — our equivalent of the FTC) for unconscionable conduct under the Trade Practices Act (minimum fine AUD$1.1 million per offence — ie: per person), and other charges including collusion, restraint of trade, tortious interference with business, retail price maintenance and many more.

It’s time MLM companies in the USA were called to account for their predatory conduct in applying these anti-competitive practices, and their tactics, which typically include unilateral confiscation of earnings, delays and technical issues designed to block and soak up victims’ cash reserves, mandatory arbitration (where they appoint the arbitrator), and other practices intended to force the other side to withdraw from proceedings or to capitulate due to lack of funds to continue legal action or defence.

Justice must not only be done. It must be seen to be done. No wonder there’s such a stench about some practices — including inventing cases in order to hijack high-flyers’ incomes because owners and stockholders resent paying them.


James Kinney January 29, 2011 at 12:50 pm Thumb up 0 Thumb down 0

Several years ago there was a independent distributor that had become disatisfied with the company he was selling for and decided to enter another business. He began quietly building another business without contacting the present downline he had with the company and was doing quite well,
but the first company found out about it and suspended his distributorship. He started legal action against the company to recoupe the loss of income and have his downline reinstated. The law suite went all to the Supreme Court and there was a rulling in his favor. The ruling stated that he had the right to pursue building the other business and the former company was depriving him of a means of income. They ruled that the company had to reinstate him and pay all of the lost commissions to him. I have tried to search the records for this but have never been able to find the case #. Maybe there is someone that could help me find it.

Reply December 15, 2010 at 3:27 pm Thumb up 0 Thumb down 0

This company is a big boy and sometimes big boys turn into big bullies, independently speaking were all have the right to seek other business ventures and invite who so ever we like to.partake to join inn. I think some companys feel intimidated over the success of some affiliates and the influence they carry as leaders and mentors but part of it comes from inconfidence in part of the mlm company. If these companys really appreciated there affiliates by pressenting them
perhaps a real comp plan maybe these problems wouldn’t be taking place. Letting go of a person after producing so much money is unethical in book , but in other hand it could go both ways in this case desiring to be in another relationship after being in a healthy one in the present time could be taken as infidelity . Im speaking symbolicaly of course and looking at it in a human view. Now proffesionally I consider the courts decission to be correct in part of the affiliate for the simple fact that this company took wrong actions against the affilate by triyng to blemish the affiliates reputation. Hopefully we all learn from this for the better good of this great industry.


Roy Harper December 15, 2010 at 12:21 pm Thumb up 2 Thumb down 2

I have followed Melaleuca’s pursuit of the businesses of Marketing Executives with great interest. What I’ve seen is selective enforcement of their Policies and Procedures. I personally reported my enroller to Melaleuca for trying to shift my downline to another opportunity, and supplied them proof of my enroller’s actions. I think nothing was done because he wasn’t high enough in the compensation plan to make an example of him.

Building a network marketing business isn’t easy, and the difficulty is compounded when the person whom enrolled you is cannibalizing your downline. I know the Policies and Procedures are there to protect an MLM, or in Melaleuca’s case a Consumer Direct Marketing company. However, in the case of Melaleuca I feel the intent of the policy prohibiting solicitation of people to another opportunity by Marketing Executives is intended to protect Melaleuca’s track record of never doing less business in any year than the previous year.

Of this I’m sure, Melaleuca isn’t a reliable, leveraged, long term, residual income opportunity because of the way the compensation plan is structured. The Policies and Procedures of Melaleuca are written as they are so Melaleuca has leverage over the activities of their Marketing Executives, so they can compel Marketing Executives to actively work their businesses or lose significant amounts of income.

My personal opinion here, anyone building a Melaleuca business needs to pause and ask themselves if what they’re seeking is a business they can actually walk away from yet the business will continue to pay them for their efforts. If they answer yes, a Melaleuca business isn’t what they should be building. Seek another opportunity.


BETTY NEWBOLD December 15, 2010 at 11:08 am Thumb up 0 Thumb down 0

I believe there are some inherent issues in the mid-west in general, given the fact that these problems seem to be arising for the most part out that area of the country. I don’t know the dynamics there. But it cannot be a coincidence. Further, the DSA has assisted our company in tightening up the loose ends to bring the company into compliance. It’s not that these things are often intentional. I think that the best intentions can sometimes be misinterpreted. This is a great industry. And the only one that affords the ‘average joe’ an opportunity to change their lives for better in relatively short order and with minimal investment. That in and of itself is enough to make the ‘powers that be’ come after us whenever they can. We are creating wealth in areas where they don’t want wealth created!
For anyone who never saw the documentary THE ONE PERCENT, you need to take the time to look at it. It is a historical look at the distribution of wealth in this country:


Mark December 14, 2010 at 8:25 pm Thumb up 3 Thumb down 0

I’m know there are a lot of opinions on this situation but I honestly don’t see the big deal here in this. It’s really pretty cut and dry unless I am really missing something. Melaleuca lets you do whatever you want to do and work as many different businesses that you want so long as you don’t use existing Melaleuca customers or immediate family. If I started my own company, I’d probably have a similar policy to protect others.

Especially to these making $10,000, $20,000, $30,000 a month or more, why is that such a huge issue? Why would you even toy with a different company once you build to that level of income? So many thousands are trying to get to that place themselves, it seems such a small policy to ask people earning a comfortable six figures to not raid their own organization because by default you would be raiding the organization of others and that would be very bad of course… so i just don’t see what the big deal is.


Visitor December 11, 2010 at 5:23 am Thumb up 0 Thumb down 0

I received the following via email and thought I would share what Melaleuca has said: (original found at

Dear Mr. Abbott:

I am responding to your recent online post entitled “Melaleuca Loses Important Ruling in Idaho,” posted on the Internet at: http://www.mlm-thewholetruth.cominetwork-marketing-news/melaleuca-loses-important-ruling-in-idaho. The Article reports on a recent ruling by an Idaho state court in an injunctive relief and breach-of-contract case filed by Melaleuca against its former Marketing Executives, Rick and Natalie Foeller.


louabbott December 11, 2010 at 11:12 am Thumb up 0 Thumb down 0

Yes, “Visitor”. We received it, posted it in it’s entirety above, and commented on some of the points as well.

Thanks for posting here just in case we had not.


Maggie Kress December 9, 2010 at 9:52 pm Thumb up 0 Thumb down 0

Lou, I ask myself how companies are surprised when they are caught. I feel they know what they are doing when they write the Comp Plans and P&P’s. They are written for the protection of the company not the rep. The rep is the one that makes the money for the company but like many, the company only thinks of themselves first.

I agree with Peter that integrity should be the number one attribute of a Network Marketing Company but many cases, this is not the way. I usually, not only, google the company but the owners of the company before I decide to join. You can tell a lot by the character of the owners when you google their profiles. If they have been owners of many companies and defaulted in those companies, then strike them off your list.

I feel to keep this from happening to you, you must know your leaders. If the leaders do not have Integrity and Character, then I would not get involved.

There are a few good MLM or Network Marketing Companies out there but you must do your homework before putting all your money and time into them.

Wishing the best for all and Merry Christmas to all and look for a good New Year.
God Bless
Maggie Kress


Jeff Young December 8, 2010 at 12:53 pm Thumb up 0 Thumb down 0

Thank you for this informative news! This is great and will help increase the FREEDOMS of all Independent Distributors (IDs) in the MLM industry. Seems to me, this is why many of us are part of this industry.

As long as an ID is not encouraging someone to leave their current MLM for another or representing competing products, there should be no conflict of interest in representing multiple companies (i.e. a communications company and vitamin company). It would be a positive to have multiple lines of business should the MLM disappear leaving the ID high and dry (or other various issues). We are INDEPENDENT DISTRIBUTORS and [following ethical/moral practices] should have the FREEDOM to run OUR businesses as we wish.

As Peter says in a previous post, “We’re leaving ourselves open to possible abuse – we’re far too vulnerable if that becomes our “primary” source of income. Instead, our MLM should be (an important) “part” of our overall BUSINESS ENTERPRISE (diversification + multiple income streams – both for personal protection and for much higher profitability).” It would be much more difficult for the MLM to take advantage of a distributor if they can’t ‘scare’ you into submission. I’ve talked to many IDs who can’t leave because it is their only source of income and their hands are tied (i.e. they need that next bonus). They might as well be an employee for a corporation. At least then some of these practices could be regulated by L&I!

As Robert Kiosaki says, “Who’s running the Ship?” (The Business of the 21st Century). If they have restrictive or unreasonable policies then maybe you don’t want to be in business with that MLM. There are some out there that have great leaders, products, pay plans, training and NO Non-Compete clauses.

Thanks for you time,


Peter Arnold December 6, 2010 at 12:06 am Thumb up 2 Thumb down 1

Hi Lou:

Thank you for advising of this very, very GOOD NEWS!

I’d like to share some thoughts about this HIGH RISK factor in our industry…

POLICIES & PROCEDURES (P&Ps) – These are the ((critical)) Legal Agreements we all sign when we decide to associate with an “MLM” company. And for some (amazing) reason, almost NObody ever talks about “P&Ps” – especially the Big Hitters. And yet, the P&Ps should be one of the “most important” first steps in the EVALUATION process when selecting “any” MLM company / biz. Those P&Ps will quickly tell us the very ‘heart’ of the company owners – their thinking – their vision – their attitude about the Reps – their integrity (or otherwise).

Most P&P documents are harsh, cave-man style, boiler-plate ((my words)) agreements that are written by the company’s bank of attorneys – to protect the “company” – NOT the Reps. Under those P&PS, it is the ‘companies’ that have all the power, control and asset ownership (including YOUR ‘downline’) – not the ‘Reps’. And MLM companies can “change” those P&Ps in a heart-beat – at any time they wish – at their sole discretion – while you and I (as Reps) have absolutely NO say in the matter whatsoever. None. There is nothing we can do to alter this RISK factor.

Regrettably, it is very, very hard to find “any” MLM company with Rep-friendly P&Ps.

THE ‘OTHER SIDE’ Of The COIN – Now in fairness, the companies (MLM or otherwise) certainly have a right to protect “themselves” too – no question. But somehow, there needs to be a way to craft these Agreements so that “both” sides can feel safe and comfortable, as in a true “business partnership”.

There are RISKS in “any” business venture, for sure (including MLMs) – that’s a given. We cannot escape that. But in this enlightened age, our industry ought to be able to soften those risks greatly.

BUSINESS “OWNERSHIP”? – Simply “joining” an MLM company will not give you your OWN business. With Network Marketing, we’re “creating” a business, yes – but we’re not “owning” a business (the MLM company owns that business – THEY own both our customers and downlines).

The fact is – as Network Marketers, we’re “commissioned Sales Reps” for the MLM company’s products & services – not business OWNERS ((it is the “company” that has the power, control and ownership – dictated by their P&Ps – Policies & Procedures)). By associating with an MLM, we gather customers for them – we recruit/sponsor other Sales Reps for them – THEY own these assets – not US.

Yes, we are “ICs” (Independent Contractors – but for “tax” purposes only – so that we’re not treated as employees) – but we are not “IBOs” (Independent Business Owners). Most in this industry do not realize that, partly because they’re seduced by all the sweet promises in the glossy brochures – “Own Your OWN Business”.

Not that “being a commissioned Sales Rep” is a bad thing, no – it’s just not real business “ownership” – and that’s the reality.

I-N-T-E-G-R-I-T-Y – This is SO important to look for. It should be the very “foundation” of the company’s Leadership. It is moral soundness – it is honor – truth – character – freedom from corrupting influence, or motive. It is about practicing the Golden Rule. It is about treating people with respect – without judgement. It is the most ‘fundamental source’ of one’s personal worth.

Integrity should cause the Management / Ownership to provide the highest level of ACCOUNTABILITY and CARE to those they lead. We need to look for it – in their Vision – in their Mission – in their Leadership – in their Purpose – in their Values – in their Promises =====> so that we will always “know” we have the SECURITY of being able to pass our businesses on – to our children and to their children.

SELF Branding + DIVERSIFICATION – My own strong recommendation is to NOT make our “MLM” be our BUSINESS. We’re leaving ourselves open to possible abuse – we’re far too vulnerable if that becomes our “primary” source of income. Instead, our MLM should be (an important) “part” of our overall BUSINESS ENTERPRISE (diversification + multiple income streams – both for personal protection and for much higher profitability).

This is one of the reasons that some of the ‘pioneers’ of Internet Attraction Marketing (like Joe Schroder, Mike Dillard, Ann Sieg, Mike Klingler, etc) all put SO much weight on the critical need for us to brand OURSELVES first – and “not” the companies / products / services, etc. It reduces the risk greatly – it makes us far less vulnerable.

More Detailed Info on this =>

Further Detailed Info on this =>

Again – love your message on this issue – just wanted to add my own 03-cents worth (Canadian :>)

Sincerely / Peter A.

Peter Arnold, CLU, CFC / Founder
Business Achievers Academy / Canada


Andries Johannesen December 5, 2010 at 9:57 pm Thumb up 2 Thumb down 1

It’s good Melaleuca is being forced to look at it’s rules
im my 20 years I have not found a company as bad as Melaleuca in this area. Distributors need to be respected and treated fairly Melaleuca say they are not an mlm company and they openly say they dont like mlm people, this is a disgrace as just about all their leadeders come from mlm. Most Melaleuca people have no idea of the many unfair things Melaluca do and the many hidden rules they have.


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