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Comment 43 Proposed Rules Chapter 815 Marketplace From: David Goldweitz Sent: Thursday, January 17, 2019 12:16 PM To: — TWCPolicyComments Subject: Glamsquad’s Support for Amendment to 40 TAC § 815.134 Attachments: Glamsquad Support for Amendment to 40 TAC § 815.134.pdf CAUTION: Email not from TWC System. Use care when clicking links and ‘opening attachments. Please see attached letter of Support for Amendment to 40 TAC § 815.134 David Goldweitz Co-Founder & Chief Strategy Officer Glamsquad 54 West 21st Street, Suite 301 New York, NY 10010 646-795-6470 (work) 917-566-2303 (mobile) www.glamsquad.com Download Our App ‘Try Glamsquad - Use Promo Code WELCOME15 Instagram | Twitter | Facebook January 11, 2019 Via c-mail to TWCPoticyComments@twestate.tx.us TWC Policy Comments Workforce Program Policy Attn: Workforce Editing 101 East 15" Street, Room 459T Austin, TX 78778 Re: Glamsquad’s Support for Amendment to 40 TAC § 815.134 1am writing on behalf of Glamsquad, an on-demand beauty service-booking platform, in support of the Texas Workforce Commission's consideration of the proposed amendment to 40 TAC § 815.134. Glamsquad’s on-demand platform connects independent beauty service professionals with individuals looking to book hair, makeup, and nail services, where they choose — including their homes, hotels, or even offices. Whether helping arrange a makeup artist for a wedding or scheduling an in-home manicure for an elderly parent, Glamsqued makes booking special beauty services easy and convenient. That is why customers in Los Angeles, the San Francisco Bay area, New York City, South Florida, Boston, and Washington DC, have booked over 500,000 beauty appointments with more than 1,700 beauty professionals, The beauty professionals who offer services on Glamsquad’s platform are independent contractors. Some have their own independent businesses and are looking to grow their customer base, others work full-time in a salon, at a makeup counter, or at a nail salon and use Glamsquad to supplement their income or save for a big expense. Other beauty professionals raise families, care for loved ones, ot are full-time students looking to earn money to cover their bills. While our beauty professionals appreciate the money they cam on the platform, the flexibility and freedom that an on-demand arrangement provides them are equally important. Working with Glamsquad allows these professionals to choose when and how much to work-so that they don’t have to sacrifice important personal obligations to earn a living. The flexible working arrangements that companies like Glamsquad provide workers, however, are under attack from plaintiffs’ lawyers exploiting the uncertainty created by subjective, vague, and outdated labor laws that were written long before on-demand work arrangements existed. This legal uncertainty threatens the growth and innovation of this important and blossoming part of our economy. The rule currently being considered by the TWC goes a long way to mitigate this legal uncertainty by providing on-demand companies and the independent workers who use platforms an objective roadmap to determine the independent contractor status of platform workers. We appreciate the TWC’s leadership on this issue and urge the Commission to adopt the rule as written, especially as Glamsquad looks to expand its operations to Texas, including a planned expansion to Austin in 2019. Resy ted, vid Gotvbeitz Co-Founder & Chief Strategy Officer GLAMSQUAD, Ine,