It’s no secret that following the regulatory shutdown or organic collapse of several “revenue-sharing” MLM companies over the past year, those left in the niche are doing everything they can do distance themselves from the “Ponzi points” model.

That is, everything short of abandoning the re-worked Ponzi scheme model itself.

Just days after GoFunRewards shutdown operations in the US after “being advised” by their lawyers that their revenue-sharing model was “illegal”, JubiRev Video Manager T. LeMont Silver hosted a JubiRev webinar, titled “Why I believe Jubi will pass the regulatory test when it comes”.


Clocking in at one hour and twenty-four minutes in length and with JubiRev running a near identical business model and compensation plan to Zeek Rewards (shut down by the SEC for being a $600M Ponzi scheme), I was curious to hear how Silver was going to distance JubiRev from a Ponzi scheme.


Silver (right) opens the webinar by informing the audience that it’s aimed at those “building the business online”. Specifically, to JubiRev affiliates who aren’t marketing to their “friends and family”.

Or in other words, people who are likely to do their own due diligence and won’t just blindly follow JubiRev affiliates into the company (‘some people will join you from your warm market because you say “hey you need to join”‘ [00:47]).

To his credit, Silver acknowledges that in running a business model that has already come under regulatory scrutiny and found to be a Ponzi scheme in the US, that a regulatory test isn’t a matter or “if” but “when” [1:36].

As with a lot of the comments we get from supporters of Ponzi schemes here on BehindMLM, Silver then launches into a lengthy “history lesson” on Amway’s legal troubles in the 1970s [3:25].

Amway doesn’t use a revenue-sharing compensation plan so I’m not going to waste any timegoing over it, suffice to say that reasoning other companies with completely different business models winning in court has nothing to do with the resurrection of “revenue-sharing” Ponzi schemes 33 years later (Zeek Rewards launched in 2011).

Next up is the MLM binary compensation plan and regulatory troubles it ran into in the 1990s [6:45]. Again, the idea here is that Ponzi schemes in 2013 are also new, and thus are going to face similar regulatory scrutiny before being vindicated.

Like the Amway comparison, the binary comparison is irrelevant because Ponzi schemes (which all “points” style revenue-sharing MLM models are built on) first appeared on the US regulatory radar back in the 1920s.

Structuring the affiliate-funded model around points and attaching products distributed via an MLM company might be new, but the core mechanics of investors being rewarded with other investors money, proportionate to what they initially invest in themselves and continue to re-invest, remain the same.

You’re welcome to listen to the next fourteen minutes of the webinar, in which Silver talks about MLM attorneys, consultants, how much they charge and how binary flushing works – none of which has anything to do with JubiRev or why it’s not a Ponzi scheme.

Entering the realm of the bizarre, at [21:30] Silver introduces Zeek Rewards and Fortune Hi-Tech Marketing (whom the FTC recently busted for being a pyramid scheme) into the discussion:

[20:45] (Zeek Rewards) ran into some regulatory headwinds… the company abruptly stopped doing business.

(Ozedit: They were shut down by the SEC for being a $600M Ponzi scheme, but go on…)

[21:03] What some of the detractors of the revenue-sharing model would say is “see, see, see, they’re no longer around, that means that model’s no good.”

Well, if that is what you’re going to say, then what do you say about Fortune Hi-Tech?

Uh… what?

Given that Fortune Hi-Tech Marketing (FHTM) didn’t use a Ponzi points revenue-sharing compensation plan, I’d probably say  “stop wasting my time”.

Silver then mentions “YTB” (another busted pyramid scheme), also acknowledging it “doesn’t have a revenue-sharing model”.

Sitting here watching the minutes of my life I’m never going to get back go by as Silver waffles on and continues to fail to address why JubiRev is not a Ponzi scheme…

[22:18] We could go through a litany of companies that were here in the network marketing space that are not here because of some type of regulatory issue.

But, those bloggers aren’t saying the industry’s no good, are they?

No, we’re not. And I’d have thought that was obviously due to the fact that not every MLM company is a pyramid or Ponzi scheme. T. LeMont Silver has his own theory:

[22:37] Maybe that’s because 90% of the folks in the traditional MLM space don’t make money.

Whilst I can’t speak for “those bloggers”, I can tell you that here at BehindMLM we don’t care if you make money or not. All reviews, analysis, commentary and discussion is based on the mechanics and structure of an MLM company’s business model and compensation plan.

Coming up next on BehindMLM, we ask those bloggers “why is chocolate milk brown?” and “why are some books taller than others?”

Almost twenty-five minutes into the webinar, and we’re still no clearer on why JubiRev isn’t a Ponzi scheme – or why it would pass an SEC unregistered securities investigation.

Continuing to ignore JubiRev’s Ponzi points business model and compensation plan, Silver then launches into a lengthy rant about affiliates “not making money” in the industry [22:46-29:00].

The cliff-notes are essentially “the whole MLM industry is against us because people make money with Ponzi points revenue-sharing compensation plans”.

MLM attorneys (Silver singles out Kevin Thompson as a hypocrite at [57:35]), consultants, “those bloggers”, other MLM companies… Silver appears to believe the entire industry and everyone in it has it personally in for him and the revenue-sharing business model.

[26:38] There’s an element in this industry that wants this model to fail because if there is a company or two that is successful with this model and are successful from a regulatory standpoint, there will be a lot of leaders and a lot of folks from other companies that say “hey, let me come over to Jubi”.

[27:05] Then what they may have to do is either change their model.

[27:37] Understand, ladies and gentlemen, that this model is not readily accepted in our industry. And it reminds me of a company called A.L. Williams.

A.L. Williams, which is now Primerica Financial Services (Ozedit: yet another irrelevant non revenue-sharing MLM company), when they got into this industry they were not accepted in the insurance world. They were looked at as a major threat to how the traditional insurance world did business.

[28:19] A.L. Williams, now Primerica, changed the face of the life-insurance industry in the US. [28:30] There was a group of people, a small group of folks, Art Williams, tremendous leader, and a small group of seventy part-time folks that eventually changed the entire industry.

I submit to you that you and I have the opportunity to link arms with J. Joshua Beistle and change the face of the industry.

Painting a somewhat dire vision of what he believes will be  the future of the MLM industry, T. LeMont Silver apparently sees it densely populated by Ponzi schemes using the revenue-sharing business model.

I didn’t think it was possible to derail your own webinar (the insurance world…?), but once again I’ll simply point out that making money has nothing to do with analysis of a revenue-sharing Ponzi points compensation plan.

And on the subject of failure, it’s entirely a moot point because the Ponzi points revenue-sharing model has already failed regulatory scrutiny.

The SEC did not shut down Zeek Rewards because it was worried “other companies” were going to lose money or that affiliates would leave them, they shut it down because (primarily) 98% of the revenue generated and subsequently paid out as a ROI to affiliates was affiliate-funded.

Affiliates put in money (invested) and earnt a >100% ROI over a fixed number of days, paid out of new and continued re-investment by existing and newly recruited affiliates.

JubiRev uses this exact same Ponzi points model, replacing Zeek Rewards’ “sample bids” with “JubiBucks” (see BehindMLM’s JubiRev review for a more detailed explanation).

Continuing his “everyone is against us making money” tirade and further derailing the webinar from its original topic of why “JubiRev is not a Ponzi scheme”, Silver then launches into a deceptively light-hearted diatribe against those of us who analyse and report on the MLM industry at large.

Primarily targeting Troy Dooly (MLM HelpDesk) and myself (the “other blogger”), Silver launches into a series of ad-hominem attacks:

[29:17] I had a conversation, those of you who with that company (Zeek Rewards), the Thursday before they abruptly stopped doing business.

We had a webinar and our feature guest that night was Troy Dooly. Troy’s one of the bloggers out there. He’s one of the well known bloggers that talks about our industry.

I actually happen to like Troy. I am very disappointed in how Troy’s reporting certain things now and I’m not telling you anything I did not text to Troy. And if Troy would take my phonecall, I would tell him myself.

But he hasn’t been taking my phonecalls, he says he’s very busy, even though we’ve texted back and forth back and forth, even though we’ve had a couple of appointments that we were supposed to have, that he couldn’t make and he never rescheduled and so on and so forth. I actually like the dude.

Now there’s another blogger out there I don’t like. Now my faith says I gotta love him but that don’t mean I gotta like him (extended laughter).

I don’t like the way he does business, he’s a horrible journalist, he lies, he doesn’t tell the truth or he takes half-truths, uh which if you just tell half of the story you haven’t told the whole story, now it becomes deception – which is still not true.

Okay, but I’ll leave that alone.

Echoing Zeek Rewards’ “acting” COO Greg Caldwell (“All our critics (are) self-appointed with no standing in the professional community (and are) behaving unprofessionally by acting on false information”), Silver of course doesn’t elaborate on any of his claims or how they relate to JubiRev not being a Ponzi scheme.

Instead Silver continues to rant on, attempting to portray Dooly and myself as part of some kind of MLM industry conspiracy against Ponzi schemes:

[30:46] My point is, ladies and gentlemen, that there is a segment that doesn’t want to see this model do well.

Now Troy came onto a webinar that we had for our team on Thursday, previous to the Friday that the company (Zeek Rewards) ah, uh, uh, ah… (Ozedit: I believe the words you are looking for are “was shut down for being a Ponzi scheme”), closed its doors.

(a brief indecipherable interruption from Silver’s co-host occurs at this point)

[31:22] Troy had been doing some post about that company (Zeek Rewards) and they had been fairly negative once upon a time. And then he started doing more and more posts that were more in the accepting position. Almost kind of promoting it if you will.

Alright, and I couldn’t figure out why, I had a conversation with him, and it turns out that with some of these bloggers what happens is, and I don’t know what the details of the arrangement was, but it turns out that with some of these bloggers what happens is they’re making posts, they’re making posts and then a company contacts them and says “hey you’ve been talking junk about us, you’ve been talking bad about us, hey we’re not a bad company why don’t you come over here and check us out.

And then that starts a conversation and in many cases, the blogger or the consultant (Ozedit: not the subtle transitional change there) who is talking bad about a particular company, might pick up a consulting gig.

And ladies and gentlemen, that’s how that works.

T. Lemont Silver only barely stops short of accusing Dooly of “extortion” and “bribery” [33:04].

This style of corporate leadership appears to be common throughout JubiRev, with President J. Joshua Beistle having this to say about GoFunRewards’ recent announcement on their pulling out of the US due to legal concerns about their revenue-sharing business model:

Let me first extend my condolences to those left standing in the cold last week when their company, without regard to those that BUILT them (their distributers), terminated all US distributers- SHAME ON THEM.

First of all the other company was not SHUT DOWN, and if they had been SHUT DOWN it wouldn’t have been for their comp plan.

The other company simply decided to keep the money and TERMINATE the distributers who worked so hard to help them grow.

In the rant Biestle labels Troy Dooly a “hired pitchman”, following an MLM Helpdesk video he published confirming GoFunRewards terminated their US business due to concerns about the legality of their compensation plan. A view directly at odds with Beistle’s claims above.

T. LeMont Silver echoes Beistle’s rant, branding GoFunRewards’ closure a “money grab” by management [48:28].

So far removed from the initial topic of the webinar that we’re now on another planet entirely, it should be noted that Dooly’s involvement in Zeek Rewards as a consultant was heavily criticised here on BehindMLM.

The most infamous example being when, on live radio, Dooly prevented Zeek Rewards’ then COO Dawn Wright-Olivares from answering whether or not Zeek’s daily ROI mostly consisted of affiliate money (it did).

It’s worth noting that, unlike Silver who, let’s call a spade a spade, is trashing Troy Dooly to serve his own purposes (somehow that it proves JubiRev is not a Ponzi scheme… yeah I know, like I said – we’re not even on the same planet we started on at this point), our coverage was purely based on objectivity and extended no further than to analyse and deconstruct events surrounding one of the most damaging and far-reaching Ponzi scheme hybrids the MLM industry has ever seen.

A company Silver hopes to see many more of and in whose footsteps JubiRev proudly follows.

In the aftermath of the shutdown of Zeek Rewards, Troy Dooly has apologised on multiple occasions and by all accounts moved on and learnt from the experience, wholly acknowledging the mountain of issues that were raised during the months he was an official consultant there.

Mistakes are made in this industry and the analysis and commentary of it (myself included) and whilst some people learn from them, others don’t.

Of course none of that matters though when you’re trying to discredit individuals rather then the analysis they put forth.

As someone wishing to know why JubiRev is not a Ponzi scheme, I’d have given up on Silver’s webinar a long-time ago (probably when he started talking about Amway in the first five minutes). As a researcher though, even though we’re almost forty minutes in and I’ve written nearly 2300 words, I’ll press on.

Lest I be accused of “not telling the whole story”.

Silver continues on, resurrecting many of the silly arguments we saw shortly after the SEC shut Zeek down. You know the ones, “Paul Burks’ didn’t know he was doing”, “if Burks fought the SEC he would have won”, “the SEC threatened Burks so he had no choice” etc. We’ve all heard the post-Ponzi scheme nonsense that flies around when Ponzi participants lose their investments.

Again, the SEC shutdown Zeek Rewards because (primarily) 98% of the revenue generated and subsequently paid out as a ROI to affiliates was affiliate-funded.

And that pretty much shuts down every argument Silver makes between [33:40] to [39:45], most of which revolves around a “social uprising” somehow refuting the fact that 98% of the ROI revenue paid out was affiliate-sourced.

Finally, at forty minutes into the webinar Silver finally gets to what he should have opened with. A direct comparison of Zeek Rewards and JubiRev.

Or at least that’s what it started off as…

[39:47] Let’s talk about what was problematic, and then let’s talk about what Jubi has done to address what we know was problematic.

This comes from the SEC:

[40:03] 1. They said that one fourth of one percent of all of the bids, they said only one fourt of one percent excuse me, only, only, only one fourth of one percent of all of the bids that were purchased were ever used.

(Ozedit: if you thought travelling to another planet was far enough from the original topic of the webinar as we were going to get, brace yourself as Silver takes us to another solar system…)

Now, I’m going to tell you and you’ve probably figured this out by now, I love, I’m proud to be an American… I can’t say the rest of it I used to, I was going to say at least I know I’m free but uh, I don’t think I can say that anymore unfortunately.

[41:08] Please understand that I’m not being non-patriotic, okay. I am eternally grateful for all that men and women of them have made for all of us to have the opportunities that we have here in the US.

But I think that our government here in the US has proven itself to not be trustworthy. Uh, weapons of mass destruction, you ever heard of that?

Did we find them? Oh okay.

Okay, oh, okay. Alright, so I don’t necessarily believe that just because they said that these were numbers that these were the numbers. But I have no way to contradict their numbers.

If these numbers were true or anywhere close, this is problematic. If only one quarter of one percent of the bids were ever used that’s problematic, because the product the company had was bids.

I think it’s worth pointing out that the SEC only revealed the above figures after

a “period of cooperation” resulted in the production of “hundreds of thousands of documents, including financial records, e-mails, and all manner of electronic files

passed between Zeek Rewards and the SEC, as filed by Zeek Rewards CEO Paul Burks’ attorney, Noel Tinn, in a US court of law. Furthermore after the figures were presented to a judge by the SEC, they were then signed off on.

Hundreds of thousands of documents, including financial records, emails and electronic files? Pssh what do they know. I’m T. LeMont Silver and I’m proud to be an American.

In any case, Silver’s reponse to this “problem”?

[42:19] With that particular we had a monthly subscription. With our monthly subscription we got bids. We were able to give those bids away, to generate more points in the revenue pool.

So what did you do with your bids? I can tell you what I did with mine (laughter), I gave them away. I gave them away so I could get more points,I didn’t use them.

The distinction Silver tries to make here is that JubiRev pays out affiliates MaxBucks with affiliate’s monthly subscriptions. MaxBucks cannot be given away and have to be spent by an affiliate on products.

The problem is that the vast majority of bids in Zeek Rewards were directly purchased by affiliates. Bids might have been given away with monthly membership but as an investment vehicle what affiliates initially invested into the scheme was far more important.

The sample bids invested in via initial investment and ongoing re-investment in bids dwarfed whatever piddly sum of bids Zeek gave to affiliates with their monthly subscriptions.

When you consider the point balances someone paying the top-tier monthly membership fee in JubiRev (or Zeek Rewards has), is a few hundred a month in the face of hundreds, if not thousands of JubiBucks (not MaxBucks) being generated via re-investment a day going to matter?

“What?! What do you mean I invested money in JubiBucks? So what if I generated thousands of points a month, didn’t you see the 200 MaxBucks the company gave me each month with my subscription?”

In the above quote I’ve highlighted what is probably paramount in significance when it comes to establishing affiliate participation in both Zeek Rewards and JubiRev. That is, the motivation behind affiliates pumping money into these schemes.

Wink wink, nudge nudge compliance would have you believe that ultimately it it is to attract retail customers to the scheme (be it Zeek Rewards or JubiRev or any other revenue-sharing Ponzi points company out there).

But there, right there in T. LeMont Silver’s own words is the real reason:

They do it to generate points, so as to receive a greater share of the money all the other affiliates are spending to generate more points.

In Zeek Rewards affiliates invest in bids, in JubiRev they invest in JubiBucks. If you follow the money, whatever else happens after that, whatever products are attached mechanically the flow of money is the same.

It is sourced from affiliates on the expectation of increasing their share in a daily ROI pool and paid out to affiliates from invested affiliate money.

This point, fundamental to why points based revenue-sharing companies are nothing more than disguised Ponzi schemes,  is entirely ignored by Silver.

Well, not entirely:

[53:22] What they (the SEC) said, and again I don’t necessarily believe their numbers but I have nothing to contradict their numbers, they said 95% of all the revenues that came into that company’s coffers (Zeek Rewards), came from internal purchases.

For the record, the SEC complaint stated that

Approximately 98% of ZeekRewards’ total revenues, and correspondingly the purported share of “net profits” paid to current investors, are comprised of funds received from new investors.

But I digress,

[53:43] What they (the SEC) were basically saying is there wasn’t enough revenue coming in from outside sources. And as a result, if those numbers are true, as a result they were saying it wasn’t a real business. It was more of a, of a Ponzi scheme “transferring of money”, more of a money game.

Now I know the owner of the company and that was never his intent. I also know that they did not come out of the gate with a customer-centric focus.

And as a result early on, they built a climate and a culture that was more people looking for a passive income opportunity or a high-yield investment program and what have you.

To quote Silver, Zeek Rewards wasn’t a real company because of its business model and compensation plan. A business model and compensation plan (and I know I’m repeating myself here) that allowed affiliates to invest money and earn a ROI over 90 days, paid out of newly invested and re-invested money by affiliates.

What the intent of the owner was or how “customer-centric” they were is irrelevant as this is how Zeek Rewards functioned. Furthermore a paradox is created in attempting to distance JubiRev from Zeek Rewards culture wise, in that it’s no secret pretty much all of the JubiRev affiliate base came from Zeek Rewards.

And for those ex-Zeek Reward affiliates who joined other reload scams in the aftermath of the SEC action, Silver regularly refers to them as “low-hanging fruit” and regularly appears in self-uploaded videos urging JubiRev affiliates to encourage them to join JubiRev.

At the end of the day, JubiRev affiliates invest in JubiBucks on the expectation of receiving a ROI over 85-105 days. Customers, mostly seen as a regulatory annoyance are usually purchased from third-party vendors, with JubiBucks routinely dumped onto the accounts to generate more Ponzi points.

What the intention of the owner of JubiRev or whether the company is customer-centric has no bearing on affiliates using it as a Zeek Rewards reload scheme.

And that, is solely what will pique the interest of the SEC when they come knocking. If anyone thinks the SEC stopped to ask Paul Burks how he felt about Zeek Rewards and the “culture” of the business, or whether or not the company engaged in *winkwinknudge nudge* “we’re all about customers” psuedo-compliance, they’re delusional.

The SEC simply requested Zeek Rewards financials, followed the money and came to the only conclusion there was.

It was a giant Ponzi scheme paying out affiliates with newly invested affiliate money, based on how much they directly invested themselves.

Singing the praises MLM attorney Gerry Nehra (who has a prolific history of involvement with several Ponzi schemes), Silver also touches on the 125% guaranteed ROI Zeek Rewards initially launched with. This is yet another easily dismissable argument (as it was with Zeek Rewards when they eventually ditched the guarantee), if one simply looks again at the motive behind affiliate’s investing in JubiBucks.

Simply put: Nobody is investing in JubiBucks without the expectation of receiving a >100% ROI over the specified ROI period (dependent in JubiRev on an affiliate’s membership rank).

A concept that these Ponzi points revenue sharing compensation plans would not be able to function without is being able to pay out >100% of the money an affiliate spends on points, over a specified period of time. Without this mechanic affiliate’s point balances would drop and nobody would invest.

Even without an explicit ROI guarantee mentioned, there’s still very much a >100% ROI implied guarantee present, without which the company would be unable to attract new investors into the scheme or retain existing investors.

Whatever you attach to that fundamental core of the revenue-sharing business model, be it a travel portal, rebate portal, grandma’s strawberry jam, a penny auction… the bottom line is it doesn’t matter. You can paint a rotten apple any color you want, underneath it’s still just a rotten apple.

Replace a rotten apple with Ponzi scheme, and T. LeMont Silver would have you believe your biting into the freshest of fresh fruit.

But don’t just take my word for it (and please don’t, review the facts and figures yourself), the following “JubiRev sizzle video” was uploaded by T. LeMont Silver himself less than 24 hours ago:


With JubiRev JubiMax, the more you give the more you get.

JubiRev JubiMax shares up to 50% or even more of its daily commissionable sales volume with all of our qualified promoters.

As you give samples to customers, you earn JubiPoints. The more samples you give away, the more JubiPoints you will earn. The more JubiPoints you earn, the more your daily potential rewards.

After determining the total revenue that will be shared that day, this amount is divided by the total amount of JubiPoints in the system.

We then pay our daily rewards with what we call JubiBucks. You can convert up to 60% of your daily JubiBucks rewards into commissions.

You can use your daily reward of JubiBucks to provide more samples to of our products to your registered customers. This allows you to earn even more JubiPoints, so you can increase your pro-rata share of the Daily Leadership Bonus.

The larger your JubiPoint totals, the larger your potential rewards. Your points can earn for as many as 105 days!

Remember, the more you give the more you get.

The more you give the more you get.


The more you give (to JubiRev), the more you get. Not a Ponzi scheme? Right.