Franchise Rule, 16 CFR 436, Comment, Matter No. R511003

The Service Employees International Union and Change to Win hereby submit an update of a petition we submitted almost exactly five years ago, requesting that the Commission investigate and address long-standing problems in the franchise industry. The Service Employees International Union unites two million diverse members working in healthcare, the public sector, and property services in the United States, Canada and Puerto Rico. Change to Win is a democratic federation of labor unions that, along with its affiliates, has engaged the Federal Trade Commission on a number of issues, including fair competition in the franchise industry and pharmacy benefit manager sector, toward the goal of eliminating anticompetitive and abusive business practices that harm small businesses, workers and consumers.

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