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Three exclusive state agreements do not become one
A fictional European brand proposes a Texas licence to Company A, a California licence to Company B and an Illinois licence to Company C. Each calls its local company the sole licensee. The overall plan still has three proposed licensees.
Conversely, one licensee may run several outlets. That distinction does not itself establish eligibility. Existing grants and intended later grants belong in the same analysis, not just the first signed contract.
What the historical material supports
The May 2008 FTC Compliance Guide describes a narrow single-trademark-license exclusion. Staff opinion 05-1 of January 5, 2005, concerning a particular salon arrangement under an earlier rule citation, distinguished licensees from outlets and noted that intended future licences would change the analysis.
The staff view was expressly nonbinding on the Commission. Similarity to that salon or starting with one contract does not give your plan a ruling. Independent state rules also remain.
Scope
- This explains the narrow distinction; it decides no actual eligibility, future-grant effect or comparable state treatment.
Next step
Count current and planned legal licensees separately from their outlets before relying on single-license shorthand.
Sources & review notes
Federal Trade Commission
Passage, dates and research notes
official-guidance · pp. 2–4, 16, 113–115
overall method of operation
Published May 2008 (day not asserted). Read relevant full-PDF sections. Dated guidance contains obsolete monetary thresholds and dated accounting discussion: current CFR controls; auditor must verify current SEC-permitted treatment.
FTC staff
Passage, dates and research notes
official-guidance · Single trademark license; final paragraph and footnote
not binding on the Commission
Historical, fact-specific staff opinion under the prior rule citation. Read with the current rule and 2008 Compliance Guide; no state conclusion.
Federal Trade Commission
Passage, dates and research notes
primary · section-436.10
equal or greater protection
Current eCFR displayed through 2026-11-09; eCFR is authoritative but not the official legal edition.
Detailed rule records (1)
The FTC Compliance Guide describes a narrow single-trademark-license exclusion. Historical staff opinion 05-1 was fact-specific and nonbinding and discusses number of licensees rather than outlets. It is not one free franchise or one exempt license per state.
FTC Franchise Rule Compliance Guide Informal Staff Advisory Opinion 05-1Keep this reading in your learning library.
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