A class-action filed back in June accuses Family First Life of selling dud leads.

Class Plaintiffs in a June 3rd California class-action complaint are Greg Birch and David Doehring.

Named Defendants are Family First Life and President Shawn Meaike.

A Second Amended Complaint, filed on August 9th, added class Plaintiff Michael Borish to proceedings.

  • Birch joined Family First Life in October 2018
  • Doehring joined Family First Life in May 2021
  • Michael Boris joined Family First Life in November 2020

The Second Amended Complaint also adds Family First Life Board Member Andrew Taylor as a Defendant.

As detailed in BehindMLM’s published Family First Life review, the company’s business model revolves around selling insurance leads to “Agent” distributors.

Family First Life’s basic business model is sign up, purchase leads and sell life insurance policies.

The leads are purportedly provided through third-parties, with Meaike claiming Family First Life doesn’t get involved.

As previously stated, the Class Complaint alleges these leads are duds.

The following is quoted from the Class Complaint (emphasis mine);

FFL markets itself as a superior IMO (Insurance Marketing Organization) over others because it has access to, and can provide its Agents with “exclusive,” “instant” leads that are “newly generated” and have “never been used”.

FFL would also sometime(s) characterize these leads as being “fresh”.

FFL characterizes and represents to its Agents that the leads are of high quality because they compromise of consumers who need insurance products, and who have yet to be solicited by anybody else to purchase such products.

Thus, Agents purchasing these leads are led to believe they are the first person to be contacting a consumer who has requested insurance products, like the products sold by FFL.

FFL sells these “exclusive,” “instant,” and “newly generated” leads to its Agents at a premium price. FFL even offers discounts on these leads to induce Agents to purchase them.

Based on FFL’ s representations, Agents will spend hundreds, if not thousands of dollars purchasing the leads, believing them to be people in dire need of insurance who have yet to be contacted.

On information and belief, FFL earns approximately three (3) to four ( 4) million dollars a week on selling these leads.

However, the representations made by FFL are false. In truth, the leads are not “newly generated,” nor are they “instant.” Nor are the leads “exclusive,” “never been used,” or even “fresh.”

Instead, the leads have been recycled several times over. For instance, the same leads would be resold to Agents in the same downline or crossline.

Most often than not, the prospective customer’s contact information provided by the leads are incorrect because the phone numbers are out of service, or the email addresses are invalid.

And when the Agent happen to have valid contact information from these so-called “instant” leads, the alleged prospective customer would often ask the Agent to not call anymore because they were already called by another FFL agent and were not looking to purchase insurance.

Even worse, the leads are not leads at all because the list is comprised of people who are not looking for insurance, or they were looking for insurance years ago.

All three Class Plaintiffs claim they bought dud leads from Family First Life.

Plaintiffs later learned the leads were not as represented.

Instead the leads were recycled many times over by other Agents in the company, had invalid contact information, and included names of people who were not interested in purchasing insurance products.

The leads were of inferior quality. Thus, Plaintiffs were induced into paying a premium for the leads when, in fact, they were not of the qualify at represented.

Accordingly, Plaintiffs have been damaged.

Class Plaintiffs seek to represent similarly damaged Family First distributors, through four classes grouped by state; a National class and three smaller California, Texas and Florida classes.

If approved, Class Plaintiffs put forth their class-action will seek to answer

Whether the leads sold by FFL were not of the quality as represented, and if not, whether recession/restitution should be afforded to the Agents who purchased such leads?

Eight alleged violations of Californian and Florida law are cited across eight counts.

One interesting difference between the Second Amended Complaint and the original Class Complaint, is the omission of problems with leaving Family First Life.

Bearing in mind that this is no longer part of the general allegations against Family First Life, at least as of the Second Amended Complaint, I’m going to cover the allegations as it makes for interesting reading.

It’s also a potential due-diligence eye-opener for prospective Family First Life Agent distributors.

In addition to its leads, one of Family First’s other major selling points is that Agent distributors are free to leave at any time. Crucially, this sees Agent Distributors able to take their business with them.

Unlike other IMOs, FFL does not require its Agents to directly contract with its company.

Instead, to make itself more attractive and competitive, FFL represents that its Agents are independent contractors, and because of their status, they shouldn’t be obligated to contract with any IMO including FFL.

FFL represents that its Agents are free to come and go to another IMO whenever the Agent so chooses without restrictions.

The original Class Complaint cites various examples of this representation from Family First Life’s website and marketing videos.

In one cited Family First Life “business development” video, Meaike states;

You can come and go as you please, go work wherever you want.

This idea that we are going to try and hold people captive or net let them work somewhere else, or bully them around, that seems weird.

In order for a contract to be moved from one IMO to another, insurance companies require a release to be signed.

The problem, as alleged in the original Class Complaint, is that this doesn’t happen.

When an an Agent decides to move to another IMO, FFL restrains the Agent by refusing to sign the Release and instead forces the departing Agent to sign a contract before any Release can be obtained.

What’s worse is the Restricting Contract includes onerous non-compete and non-disclosure clauses that eliminates an Agent’s ability to transfer his/her book of business elsewhere.

Excerpts from the Restricting Contract show Family First Life considers its customer information, including generated business, as “confidential information” – which it bars Agents from using “in any manner”.

These provisions … removes an Agent from the marketplace because the Agent is restricted from using the contact information of his/her customers to purchase products while at a different IMO.

Class Plaintiffs claim Family First Life’s false representations caused “significant damage to departing Agents”.

Either the Agent is forces to sign the Restricting Contract so he/she can continue doing business with his/her preferred carriers, but with no ability but with no ability to contact his/her book of business or downline Agents, or, alternatively, the carrier is forced to stay with FFL so he/she can continue doing business with the preferred carriers with no restrictions whatsoever.

If either choice is unacceptable, the Agent is then left with no option but to wait six (6) months and perform no business with the carrier before he/she can again contract with the carrier with another IMO.

Given the onerous language of the provisions contained in the Restricting Contract, and given that Agents are misled in believing they can “come and go” from FFL without restrictions, some Agents ultimately refuse to sign the Restricting Contract when the agreement is imposed upon them.

Because of this, Agents are then forced to wait six (6) months before they can contract again with their preferred carriers at a
different IMO.

FFL’s practice is considered an unreasonable restraint of trade, which has injured Agents and the entire insurance marketplace.

I’m not sure why these allegations were cut from the Second Amended Complaint.

Looking at the case docket, Family First Life has filed to requests for an extension of time to respond to the Second Amended Complaint.

Defendant has been diligently investigating the allegations in the Second Amended Complaint and has been engaging in discussions regarding retention of attorneys for the individual Defendants.

As per the above, quoted from the second request for an extension, Family First Life might be having trouble securing legal representation.

On September 23rd the court granted FFL’s second request for an extension, giving them until October 11th to file an answer.

It should be noted another class-action complaint was filed against Family First Life earlier this year.

Class Plaintiffs Reynaldo Suescum and Francisco Baserva accused FFL and Agent distributors of robocall fraud. The case was referred to mediation in May.

BehindMLM is tracking both Family First Life class-actions so stay tuned for updates.


Update 22nd February 2023 – The cited Family First Life “business development video” has been marked private on YouTube.

This article originally contained a link to the video, which has now been disabled.


Update 9th May 2023 – Family First Life prevailed on a Motion to Dismiss on April 13th.

The court granted Plaintiffs Birch and Doehring permission to amend their Complaint. To that end a Third Amended Complaint was filed on May 4th.


Update 8th March 2024 – Family First Life filed a motion seeking to dismiss the Third Amended Complaint on May 18th.

The court took Family First’s Motion to Dismiss under submission on July 12th.

On December 14th the court granted Family First Life’s motion.

The Court is dismissing this action for lack of personal jurisdiction over Defendant.

Plaintiffs do not specifically allege where they were injured or when they specifically interacted with any of Defendant’s alleged
California contacts.

Plaintiffs do not dispute this in their opposition. Therefore, the Court cannot find that Plaintiffs have established specific personal jurisdiction.

Given previous motions to dismiss were also granted on jurisdictional issues, the court denied Plaintiffs the opportunity to file a Fourth Amended Complaint.

The Court already put Plaintiffs on notice regarding the Court’s concerns with respect to the lack of specificity surrounding
the test for specific jurisdiction.

Plaintiffs cannot be granted unlimited attempts to amend their complaint.

With the case dismissed and docket terminated, this brings BehindMLM’s coverage of the Family First Life “dud leads” class-action to a close.