Holiday Magic was a multi-level marketing organization, founded in 1964, by William Penn Patrick (1930–1973) in the United States. They are the "top of the pyramid" in a traditional pyramid scheme and are. Pyramid Scheme Logistics Account Executive Former Employee, more than 1 year Chicago, IL Recommend CEO Approval Business Outlook Pros The people are cool. The inherent flaw of pyramid schemes is that they must always suck in new converts to avoid collapse. Cutco is NOT a Cold War weapons manufacturer (well… that we know of). This is important because it means that Optavia is not a type of business that is illegal called a pyramid scheme. See All Reviews See All . 😀. They are all either specific to. 1. Pyramid schemes are an especially notorious form of "get rich" scams perpetrated by a. The company was founded in January 2001. The lawsuit suggests ACN is a pyramid scheme, a description the company rejects. While the KKK was, in most respects, a “non-profit” dedicated to championing a political and social “cause” (racism and. The management is an atrocity to the word management, and if after training, if you don’t meet your sales quota, the accounts you developed will go to the next person who’s account you were working. The company denies it. So calling an MLM a pyramid scheme might be “inaccurate,” depending on how you look at it, but it’s really just semantics. Although pyramid schemes promise large, quick returns, they inevitably fail, causing most members to lose their. Cons. Ponzi schemes are usually presented as investment management services, where participants believe that the return they will gain is a result of a legitimate investment. C. Pyramid scheme organizers may pitch the scheme as a business opportunity such as a multi-level marketing (MLM) program. The actual. A four level pyramid model of different types of Information Systems based on the different levels of hierarchy in an organization. S 35939. Ponzi schemes are similar to pyramid. MLM focuses. With a pyramid scheme, there doesn’t need to be a specific product for sale. Buy in required. Like any other MLM company, Atomy promotes and sells its products through sales agents. Under this business model, the company’s sales staff is encouraged to purchase the products and then sell them to their customers. However, in a Ponzi scheme, there is no product to sell. Because the prosperity gospel is strikingly similar to a pyramid scheme in at least three ways. Sub for Freight Brokers to discuss the industry. It may be a drag on investment: earning interest from your bank is an easier return than opening a factory. Multi-level Marketing (MLM) is a marketing strategy designed to promote their product by through distributors, offering multiple levels of compensation. A pyramid scheme is a business model that relies on perpetual and unsustainable growth. The answer to the question raised in the title of this chapter is straightforward: Yes. The no-cost affiliate option, which offers a 5% order discount, restricts retail, which is still feasible. Pyramid schemes are based on network marketing and require participants to recruit new members in order to earn money. Base pay is standard for recent college grads. TQL is a brick and mortar pyramid scheme disguised by and fueled by palpable toxic masculinity and a lot of fake interest in diversity and inclusion. 3. The Trumps have been accused of fraud and false advertising by promoting ACN’s “get-rich-quick scheme” that conned victims. It has a pyramid structure: Pyramid schemes may be illegal, but that doesn’t mean they don’t exist. One is the aspect of the chain or line of distributors whose income depends primarily not on their own sales of Amway products but on sales made by others whom they've recruited. Learning the in's and out's of presenting recommendations for potential clients. But instead of your money being the only thing climbing the pyramid, you are climbing it also and is given money instead of having to give money for each new. A pyramid scheme is a business model in which payment is made primarily for enrolling other people into the scheme. Learn what to avoid and identify red flags by working this jobIt's a job. 3 Avon. The pyramid is an attempt—however unethical—to creatively look like a legitimate MLM opportunity. The early participants further recruit new entrants and get a commission to do so. Read employee reviews and ratings on Glassdoor to decide if Total Quality Logistics is right for you. The people at the top of the pyramid earn the most money, while the people at the bottom earn very little or nothing. TQL employees are most likely to be members of the republican party. It’s based on the deceptive success of the guy at the top. 1, 2022 —. Bernard Madoff, or “Bernie Madoff”, was an American financier who executed the largest Ponzi scheme in history. 1. Investors are encouraged and rewarded for recruiting new investors into scheme, often getting a cut of their investment. A chain-mail solicitation by any other name, ‘blessing loom’ or ‘sou-sou,’ is against the law, officials say. It was founded in 1997 by Ken Oaks in Cincinnati, and is headquartered in nearby. Work Saturdays for 6 month. It is a kind of chain letter with a product. Each of those 25 recruits get 5 recruits and so on, multiplying into a large number of. No pyramid scheme was bigger than TelexFree, which conned 1. Everything. Each time a new member is recruited, their investment is divided up among all of the people above them in the. Pyramid scheme compensation models. Essentially a pyramid scheme making other people money. However, some MLM plans are fraudulent pyramid schemes, defrauding participants of millions of dollars. 4. the solid base salary for a sales positionSalary Satisfaction. Total Quality Logistics Company Profile. 4. Although pyramid schemes promise large, quick returns, they inevitably fail, causing most members to lose their investments. pyramid schemes do not sell a product, but it is important to take a better look at each MLM and learn how the money is being made within that organization. No value to work life balance, 10 PTO days after you've worked for a year or so. Generally speaking. A gripping new documentary miniseries is bringing attention to multilevel marketing platforms. Cons. Pyramid schemes are not only illegal; they are a waste of money and time. If the goal of any particular cryptocurrency is to serve purely as an investment vehicle without any actual productive use of the capital, then, yes, it meets the strict definition of a pyramid scheme. Legal pyramid scheme. “The system is perfect. Eliza Briscoe was told that all she had to do was put up $500 and bring in two. , the currency of the scheme) can be money or other purchased goods such as books or wine but the structure remains the same: pay, recruit, and receive payment when a sufficient number are. Cons. 0 Feb 14, 2015 Pyramid scheme Logistics Account Executive Former Employee, more than 1 year. They set you up so that you have to bring in a senior advisor for every case that you do this also requires you to give up 50% of the compensation. A discovery hearing in a long-running lawsuit accusing former President Donald Trump and two of his adult children of promoting a multi-level marketing scheme resulted in a series of small victories for the plaintiffs on Wednesday–even as the Trumps’ attorneys repeatedly protested the sweeping nature of those requests. When I put in my two week notice, he called legal. Often, the buy-in involves purchasing a certain number of products that the pyramid scheme is based around. , many pyramid. There’s no secret to our success, it’s. They are all either specific to the logistics industry or specific to any other job that gives you an opportunity to make a lot of money. However, these new recruits must buy expensive packages or training material,. This article provides guidance for consumers who are considering joining an MLM plan by. I was bamboozled by the prosperity pastor’s ploy in the same way people are fooled by pyramid schemes. A pyramid scheme is an unsustainable business model where participants profit from recruiting other members. The main characteristic of a pyramid scheme is that is that people only make money by recruiting other members. Every call is recorded*** If you believe someone has treated you unfairly or lied to you then let them. 5 BillionConsumers are protected by Is Forex a Pyramid Scheme regulation, critical to preventing inadequate services and potential financial harm. For over 15 years, we've specialized in arranging the transportation of full truckload shipments for thousands of companies across the country and various industry segments. With the information that is publicly available (from the Q-2’11 10Q filing to the SEC) Pyramid Scheme Alert calculates: “…an average of just $144 a month of purchases per salesperson. The remaining 19% were constructive reviews with the goal of helping Total Quality Logistics improve their work culture. Dieting supplement sales company Herbalife dodged the “pyramid scheme” designation on Friday as it agreed to pay the US Federal Trade Commission a. Pyramid schemes are illegal multilevel marketing programs that promise consumers or investors large profits based primarily on recruiting others to join their program, not based on profits from any real investment or. MLM systems require a buyback guarantee for any products that the sales representatives are not able to sell, whereas a pyramid. Informal environment. There are three real methods to getting customers at TQL: be lucky. If someone promises huge returns or pressures you to act quickly. Lack of empathy from other coworkers or teams leads/managers if having a difficult time with cold calls. A pyramid scheme is a business model that recruits members via a promise of payments or services for enrolling others into the scheme, rather than supplying investments or. Pyramid Schemes are broken into two categories: product based schemes and non-product based schemes. MLMs or "pyramid schemes" by nature are companies that build revenue through representative fees in addition to actual product sales. 042013. "LuLaRich," available on Amazon Prime, chronicles the story of LuLaRoe, a clothing empire famous for. Bernie Madoff’s pyramid scheme, or Ponzi scheme, is one of the most notorious pyramid schemes, as it follows the same principle. New recruits make up the base of the pyramid and provide the funding, or so-called returns, the. ”. Financial freedom, extensive training, team environment, team building exercises, promote from within. 2. Enterprise Mobility. The job of a Logistics Account Executive at TQL requires a lot of commitment. A pyramid scheme is an illegal, fraudulent plan that relies on continually recruiting new members, instead of depending on retail sales, to make money. Everyone above you in the pyramid gets a cut of that money. 2) CONSTANT motivational speeches, to ensure the job ISNT a scam. Such an offer would be an example of a pyramid scheme, which is illegal in most countries. At the ninth level of a pyramid scheme in which each member must recruit only nine new members, 387 million or more people must be members to sustain the business, surpassing the population of the US, according to the Cornell Legal Information Institute. 2: Data credits are generated which requires the burning of HNT. Even if you have the ideal conversation with customers you’re not going to get commissions unless you are handed the clients from mgmt. Pyramid schemes have taken many forms over the years—and will undoubtedly continue to adapt and grow over time. Travel agent pyramid schemes are illegal and unethical business practices. 1. ClickFunnels also makes heavy use of its solid affiliate program, from which some of the concerns and. The “5. Before we go further in this Savvi review, I will define two terms first: MLM and pyramid scheme. The FTC issued $149 million in refunds to individuals affected by an alleged AdvoCare pyramid scheme in May 2022. C. I had an incredible time working with Opus Business Consulting because of the skills I learned during my time there. A typical pyramid scheme combines a plausible business opportunity (such as a. Social media users are being targeted by a scam which is leaving participants hundreds of pounds out of pocket. In this article, we will discuss the 9 famous pyramid scheme companies in US history. Not all, but some multilevel marketing businesses turn out to be pyramid schemes. And MLMs operate in a curiously triangular manner. Whatever it is, though, it isn't a currency. The project relied on its own internal servers to run the ploy and lacked a blockchain system. 3. com /about-us. A pyramid scheme, like a Ponzi Scheme, is a “get-rich-quick” swindle that benefits those who sit at the top of the organization. 100% a pyramid scheme. TQL is a brick and mortar pyramid scheme disguised by and fueled by palpable toxic masculinity and a lot of fake interest in diversity and inclusion. They, in turn, recruit additional distributors. Modern pyramid schemes are sometimes framed as gifting schemes, promoted as systems of empowerment or generosity. Fortune Hi-Tech Marketing (FHTM) was a Lexington, Kentucky based company which used multi-level marketing to sell consumer goods and services. this job will take over your life completely expecting over 12 hrs a day of work along with Saturday shifts unpaid also 6 months before applicable for commision. 2. . A federal lawsuit accusing former President Donald Trump and his family of promoting a pyramid scheme will finally go to trial on Jan. Compare. Total Quality Logistics (TQL) is a North American freight brokerage and third-party logistics firm. You can get your feet wet by making close to over 1,000 cold calls a week and even then thats not enough. For over 15 years, we’ve specialized in arranging the. Not a place for industry education. Total Quality Logistics is supposed to be based on truth and up front honesty. Pyramid schemes, on the. There are no TQL - specific cons. The word pyramid reflects the model’s. Ponzi schemes vs pyramid schemes. Actually that is what determines pyramid scheme. Agent (Former Employee) - Charlotte, NC - May 20, 2022. Claim your Free Employer Profile to start telling your employer brand story to reach top talent. Many have wondered if Mary Kay, a company that sells cosmetics and other beauty products, is a pyramid scheme. In affiliate marketing, the sale of a good or service is prioritized over the acquisition of new customers. Regulation of Is Forex a Pyramid Scheme is necessary to prevent fraud. A free inside look at company reviews and salaries posted. Total Quality Logistics (TQL) 3. Benefits Specialist (Current Employee) - Columbia, MD - March 5, 2019. The Scheme. The remaining 19% were constructive reviews with the goal of helping Total Quality Logistics improve their work culture. The model enables us to calculate the probability distri- bution of the number of people each par- ticipant will recruit and realize how strongly the probability of recouping one's initial investment depends on when the participant enters the pyramid scheme. TQL may also be known as or be related to TQL, Total Quality Logisitcs, Total Quality Logistics, Total Quality Logistics Inc and Total Quality Logistics LLC. Base pay is standard for recent college grads. But there are a few common types of pyramid schemes: Investment Companies/MLM Companies. The themes were familiar. You would think that in an insurance company they would actually care about helping people but they only care about sales and how big of a sale it is. A pyramid scheme fraud is targeting young people on social media. Not a logical or sustainable career path. Learning the in's and out's of presenting recommendations for potential clients. Spotting a pyramid scheme. Connect with our community. Money Multiplier Schemes. Humanity’s resource overuse is clearly robbing the future to pay for the present. Claim your Free Employer Profile to start telling your employer brand story to reach top talent. “Long hours” “Hard work” “Fired me for being late” It is hard work and there are long hours, much like. First (and to be clear again), as I'm sure you can tell, Cutco Knives (the company) is not a scam. MLMs are legal and pyramid schemes are not. The scheme brought needed liquidity into the financial system. A pyramid scheme is a fraudulent system of making money which requires an endless stream of recruits for success. He also made it sound like a pyramid scheme. And the cycle. A pyramid scheme is a fraudulent investment strategy, deemed illegal in the United States. Enterprise Mobility. The impostor basically robs one to pay the other. 146 Fairchild Street Suite 141 Charleston, SC 29492. Of these top sellers. Affiliate marketers make money solely by promoting or referring others to buy a product. Pyramid Schemes - A scheme through which an organizer builds a structure of a pyramid which initiates with one person who represents the tip of the pyramid is known as a pyramid scheme in. Business. The Optavia program uses 1:1 coaching sessions in addition to the traditional products offered, making it seem like this program is more personalized. Sometimes fraudsters will give products or services fancy-sounding names in order to make the company appear to be legitimate. ) seconds later they deleted the tweet, so that was sus. It’s a legitimate direct selling company that uses the MLM (Network Marketing) business model to sell its product to a customer through its huge base of Amway. The people at the top of the pyramid earn the most money, while the people at the bottom earn very little or nothing. ; WakeUpNow pyramid scheme failed to provide profit to 95% of its distributors and ceased operations in 2015. All the people who were active were also on FB spamming and recruiting for other MLMs. USHA is a flawed system to say the least. ”. It should be noted that pyramid schemes are illegal in the US and Canada. Recruits (a) give money to recruiters and (b) enlist fresh recruits to give them money. Facebook Twitter Linkedin EmailMulti-level marketing (MLM) is a long-established method of marketing and distributing products and services directly to the general public. Notmiefault • 8. Worst job of my entire career, hands down. For many of the consultants of Mary Kay, the financial returns are often minimal — which is really far away from the huge income that the. Find out what life is like at Total Quality Logistics (TQL), then browse jobs and apply today!Account Manager (Former Employee) - Pittsburgh, PA - January 23, 2023. Helpful. 2. Booking appointments with potential clients, under the guidance of a seasoned Advisor. This agent position does require a self-motivated, persistent, and sales-minded individual to succeed and isn't for everyone. Pyramid schemes, on the other hand, look similar but, as explained in this article, are focused on investment and deposits rather than sales, which (among other factors) makes them illegal in the vast majority of countries. However, that doesn’t mean everyone who works with Transamerica makes a lot of money. Pyramid schemes are often disguised. But it does not hold. Only when you make money by recruiting people would it be considered a pyramid scheme. It was founded in 1997 by Ken Oaks in Cincinnati, and is headquartered in nearby Union Township, Clermont County, Ohio. This is a pyramid scheme. As its name indicates, the pyramid scheme is structured like a pyramid. See Why It Is Not a Pyramid Scheme. Both, after all, operate with the same pyramid. Like diet industry pyramid schemes, participants are still asked to pay money upfront in order to enroll. The management is an. A pyramid scheme is an illegal business model that promises participants high returns through recruiting others to join the scheme, rather than by selling products or services. Pyramid schemes are illegal, and they can be very dangerous to participate in. A Ponzi scheme is an investment. There are no TQL - specific cons. In this article we answer the question “Is Forex a Pyramid or Ponzi Scheme?”, and the short answer is no. Work Saturdays for 6 month. Often in a pyramid scheme, you’ll be encouraged or even required to buy a certain amount of product at regular intervals, even if you already have more inventory than you. One hallmark of a pyramid scheme is that its leaders. To define GIN as a pyramid scheme, the FTC needed to define what exactly a pyramid scheme is. ’. The pyramid schemes were not a product of circumstances unique to Albania. 03 EDT. People who are higher. It identifies a pyramid scheme saying, ‘Some schemes may purport to sell a product but they often simply use the product to hide their pyramid structure or disguise the scheme. Pyramid schemes are set up to encourage everyone to keep recruiting people to keep a constant stream of new distributors — and their money — flowing into the business. Former TQL LAE and LC2. Weight Loss Multi-Level Marketing Schemes, pay a commission to distributors when an actual tangible product is sold. ) seconds later they deleted the tweet, so that was sus. In fact, health insurance is more like a legal pyramid scheme. pyramid schemes is that the latter requires people to recruit additional investors—who will recruit other investors, who will recruit other investors—in order to “move up” the. Pyramid schemes are a particularly infamous type of "get rich quick" scam perpetrated by a small group of individuals who stand to profit the most financially. But it’s based on growth, in various forms. It has been speculated. The structure of a pyramid scheme resembles a pyramid because participants recruit new members who then recruit more members, creating multiple levels. Having placed the pyramid scheme in its proper context, let’s move to the question of why it’s. But because I know how loyal and protective TLC reps can be, let me just say that. 7. Financial freedom, extensive training, team environment, team building exercises, promote from within. Cons. The Insurance you sell is sub-par and the company will do everything in its power to not pay medical expenses. MLM. Pyramid schemes are a fraudulent business model that involve recruiting new members to make money by promising them a share of profits for recruiting others. It is tempting . MLMs should be quite straightforward. 1K Salaries Benefits 553 Jobs 230 Q&A Interviews 158 Photos Want to work here?. 3. “We are starting to gain share. It typically starts with one person - the initial recruiter - who is on top at the apex of the pyramid. The management is an atrocity to the word management, and if after training, if you don’t meet your sales quota, the accounts you developed will go to the next person who’s account you were working under. “A pyramid scheme is a sketchy and unsustainable business model, where a few top-level members recruit newer members. , et al. Washington D. A pyramid scheme hooks consumers with promises of big money, but often leaves them holding the bag in the end. If you had a bad experience and have been lied to or mistreated call back and ask to speak to Carrier Services. All pyramid schemes eventually collapse, and most. On December 22, 2020, Ohio’s highest court determined that if there is a written contract between two parties which includes an indemnification provision, the parties’ indemnification. If there’s a program that’s placing a lot emphasis on getting others to join – as opposed to selling a product or service – chances are that it’s illegal. ago. But Oliver believes that these companies’ business models look very similar to pyramid schemes and according to at least one Youngevity saleswoman in a corporate video, it is a “pyramid scheme. Until each one of these baneful traders is weeded out, many will continue to suffer. As of 2021, TQL is the largest private company in greater Cincinnati according to the Cincinnati Enquirer and American City. 600 W Van Buren St Ste 325 Chicago, IL 60607-3739. Cons Realistically, you are not going to earn commission, probably ever. ) is a 1979 ruling by the United States Federal Trade Commission concerning the business practices of Amway, a multi-level marketing (MLM) company. Like many others, they have been embroiled in many scandals about the claims they make about their products. It’s never been legally defined in the US by a statute, but the FTC defines it as whether a. The key difference is that while a legitimate MLM focuses on bringing in people to sell the product, pyramid promoters emphasize the recruitment itself. A pyramid scheme is an illegal business model that relies on recruiting new members to generate revenue rather than selling a legitimate product or service. An MLM will typically charge for training/conferences, offer no benefits, hire only 1099 contractors, and in some cases require representatives to commit to purchasing a certain amount of product. Bitcoin has no one running it, it doesn’t have a hierarchy or mandatory payments, it doesn’t promise profits. They treat their employees horribly. economy. The Securities and Exchange Commission today charged 11 individuals for their roles in creating and promoting Forsage, a fraudulent crypto pyramid and Ponzi scheme that raised more than $300 million from millions of retail investors worldwide, including in the United States. Pyramid Scheme: A pyramid scheme is an illegal investment scam based on a hierarchical setup. Rather, they make money only through commissions collected by recruiting an ever-growing number of paying participants. Just happy I’m not a part of the TQL pyramid scheme anymore where the big brokers get richer by inheriting customers and the small brokers can’t make a dime. So, don’t let these misconceptions steer you away. Information from an expert . They are a form of financial fraud that is based on recruiting new people to make investments that are then used to pay the people who. Read what this employee has to say about working at Total Quality Logistics (TQL): This is most certainly the worst company I’ve ever had the displeasure of working. Past pyramid schemes have cost investors substantial amounts of money. Regulators use a two-pronged test to determine if a company is operating as a pyramid. " You Might Also Like: Crypto. Compare. Total Quality Logistics (TQL) prevailed in a recent Supreme Court of Ohio case that affects both businesses and individuals. The FTC ruled that Amway was not an illegal pyramid scheme according strictly to the statutory definition of. 4. A pyramid scheme is a business model that recruits members via a promise of payments or services for enrolling others into the scheme, rather than supplying investments or sale of products or services. A pyramid scheme is an investment fraud in which new participants’ fees are typically used to pay money to existing participants for recruiting new members. 4 In that case, the Commission characterized aLowkey a Pyramid Scheme. Helpful. 17% of TQL employees are women, while 83% are men. Learn about Total Quality Logistics (TQL) in popular locations. "And although their triangle shaped recruitment business model was clearly a pyramid scheme, somehow they manage to fly under the radar even in countries where pyramid schemes are illegal. The Securities and Exchange Commission today charged 11 individuals for their roles in creating and promoting Forsage, a fraudulent crypto pyramid and Ponzi scheme that raised more than $300 million from millions of retail investors worldwide, including in the United States. This article covers the high-level design of the Pyramid compiler: The compiler’s components and Pyramid’s runtime environment. Pyramid schemes, which are illegal, can look “remarkably like” multi-level marketing companies, according to the Federal Trade Commission (FTC). 9,000+ (March 2023) Website. Total Quality Logistics (TQL) is the nation’s 2nd largest freight brokerage firm. The primary plan at TQL is train for 5 months under a successful broker, learn the trucking industry inside and out, then go into a "Proving Grounds" setting, which is where you have 8 weeks to make a specific revenue (Mine was $2500). Total Quality Logistics on Facebook. Ponzi schemes can be easier to detect while pyramid schemes can be hidden to make them look legitimate. View customer complaints of Total Quality Logistics, LLC, BBB helps resolve disputes with the services or products a business. , direct selling. The entire premise of the company is a complete sham. 1 billion more people for the 13th layer, to sustain the scheme, but this is larger than the population of the world. Of the employees are satisfied about their pay. New recruits make up the base of the pyramid and provide the funding, or so-called returns, the. Not every broker that works there is bad. Each person who enrolls—including you—is required to “buy in. The fast-paced environment fosters teamwork and professional growth through comprehensive training. Having never worked a door to door sales job before, or any sales job for a matter of fact, the management team did an incredible job teaching me the system. Recommend. In a pyramid scheme, the earlier participants recruit newer ones, and they are all ostensibly selling a product. With so many alleged pyramid schemes, Cabo Frio came to be known as the "New Egypt. The Ponzi scheme is simply a masquerade and its practitioners are usually guilty of mail fraud and tax evasion among other criminal violations. Frowned apon when you take PTO days or take a lunch break. Discovery GO Subscribe to NowThis World: con-artist sound like they belong in the pa. S. g. r/FreightBrokers. Pyramid schemes are, however, fraudulent schemes, disguising as an MLM strategy. Multi-level marketing is a strategy that some direct sales companies use to encourage their existing distributors to recruit new distributors by paying the existing distributors a percentage of. The difference between a MLM and a pyramid scheme can be blurry, both legally and practically. It also appeared to TQL that there were significantly more text messages stored on Bosse's phone that had not been produced or included in any of appellants' privilege logs. It has also been accused of cult-like behavior by its former retailers and. The name for a pyramid in Egyptian is myr, written with symbol 𓉴 (O24 in the Gardner Sign List). [4] [5] [6] As of 2021, TQL is the largest. In fact, according to Brooks, victims of pyramid schemes are the least likely of consumers who’ve been defrauded to actually report it. So it might be legal but is still immoral. According to the Federal Trade Commission, pyramid schemes “promise consumers or investors large profits based primarily on recruiting others to join their program, not based on profits from any real investment or real sale of goods to the public. Another difference is in the recruiting strategies. Pyramid schemes, by contrast, have nothing to do with real commercial activity.