Last month, U.S. District Court for the District of Arizona in U.S. v. Noland, found that Success by Health was an illegal pyramid scheme based on its inability to reliably prove retail sales, among other reasons. Meanwhile, the industry awaits the decision in  FTC v. Neora, which involves pyramiding allegations as well as allegations of  unsupported earnings and product performance claims. This Panel discussed what Noland means to the industry, what we might expect in Neora, and what it all means for the future of the direct selling.