First, it is uncertain whether it is a pyramid scheme. MLM refers to the behavior that organizers or managers develop personnel, calculate and pay remuneration to the developed personnel based on the number of personnel directly or indirectly developed by them, or require the developed personnel to obtain the qualification to join on the condition of paying a certain fee, in order to seek illegal interests, disrupt economic order and affect social stability.

2. According to Article 7 of the MLM Regulations on Prohibiting MLM, the following acts belong to MLM:

(1) The organizer or operator, through the development of personnel, requires the developed personnel to develop other personnel to join, and calculates and pays remuneration (including material rewards and other economic benefits, the same below) to the developed personnel based on the number of personnel directly or indirectly developed, so as to seek illegal benefits;

(2) Organizers or business operators demand the developed personnel to pay the fees or change the fees by means of purchasing commodities through the development personnel, so as to obtain the qualification to join or develop other personnel to join and seek illegal benefits;

(3) Organizers or business operators, through the development of personnel, require the developed personnel to develop other personnel to join, forming a subordinate relationship, and calculating and paying online rewards based on the sales performance of the offline line to seek illegal benefits.