The number of filed civil robocall fraud lawsuits against Family First Life’s parent company has climbed to eight.

Family First Life is an MLM company that makes money selling purported insurance leads to its promoters.

The opaqueness of the scheme has lead to multiple lawsuits alleging violations of the Telephone Consumer Protection Act (TCPA).

Plaintiff Steve Noviello filed suit against Integrity LLC (fka Integrity Marketing Group), in the Northern District of Texas (Dallas) on October 14th, 2024.

In his filed Complaint Noviello alleges, despite his cell phone being on the Do Not Call registry, he was

plagued by calls from companies who call themselves American Benefit, American Senior Benefit, “NAA”, Senior Benefits and others often the call centers will use a pre-recorded AI message as well.

Based on our investigation, it is clear that the calls Plaintiff has been receiving from Defendant are connected with these other calls all from Integrity marketing group and/or its partner affiliates.

Nonetheless, Defendant and their affiliates have placed repeated harassing calls/texts to solicit its services to Plaintiff for years despite his many requests for them to stop.

[Family First Life] has purportedly settled a previous TCPA disputes with Plaintiff and promised never to call again but that has not happened.

In connection to that is another series of calls each from the same 214-440 exchange. 74 of them.

The calls are (almost) always automated AI calls always from “Kevin Foster from Senior Benefits” selling final expense insurance. They are nonstop.

When they are not AI calls they are live calls from someone also calling himself Kevin Foster as far as my client remembers.

After months of these calls Plaintiff FINALLY got a call back … from a local sales agent, (Francis) Mike Lillis out of San Antonio.

He left a message and Plaintiff called him back- the call is below. He informed Plaintiff that he is independent but supported by NAA (National Agents Alliance) which is where he buys his leads.

He insisted he has no idea where the leads come from but does confirm they use call centers (my Client has never filled out any form or answered an ad for final expense insurance).

He gives Plaintiff a number … to call them in Burlington NC. After doing some research it was clear that they are linked to Integrity Marketing Group.

Noviello believes Family First Life obtained his contact data through “a series of shadowy data transfers” he had no part in.

It is highly problematic that in a time when consumer privacy is eroding and citizens’ data is regularly bought and sold with wanton disregard for privacy rights or even accuracy, that Defendant do not even attempt to obtain express written consent before telemarketing and cannot even say how it got Plaintiff’s contact information before inundating him with telemarketing calls and texts.

Not to mention, the Defendant’s inability to explain how it was not aware that the Defendant is on the “Do Not Call List.”

However Family First Life got his data, Noviello alleges a promoter contacting him with said data violates the TCPA.

Defendant initiated multiple text messages to Plaintiff using an automatic telephone dialing system.

The dialing system used by Defendant to call Plaintiff has the present and/or Suture capacity to dial numbers in a random and/or sequential fashion.

Specifically, Defendant uses algorithms to select the sequence of calls/texts to be dialed from a stored list of telephone numbers.

Defendant used a dialing system that dials or stores numbers using a random or sequential number generator.

Defendant dialing system used to text Plaintiff is therefore an “automatic telephone dialing system” as defined by the TCPA.

Defendant’s calls were not made for “emergency purposes.”

Defendant’s texts to Plaintiffs cellular telephone using an ATDS were without any prior express consent.

Defendant contacted Plaintiff despite the fact that Plaintiff’s numbers was on the Do Not Call Registry since 2016.

Accordingly, Defendant’s acts as described above were done with malicious, intentional, willful, reckless, wanton and negligent disregard for Plaintiff’s rights under the law and with the purpose of harassing Plaintiff.

The acts and/or omissions of Defendant were done unfairly, unlawfully, intentionally, deceptively and fraudulently and absent bona fide error, lawful right, legal defense, legal justification or legal excuse.

As a result of the above violations of the TCPA, Plaintiff has suffered the losses and damages as set forth above entitling Plaintiff to an award of statutory, actual and trebles damages.

In addition to three counts of TCPA violations, Noviello also alleged Integrity negligent in training, hiring and supervision of Family First Life promoters.

Defendant knew at all times it is required to obtain express written consent from consumers before telemarketing, yet did not even attempt to do so.

Defendant retains vendors and agents to place calls on its behalf without any method of monitoring those vendors or assuring they are engaging in proper practices and procedures.

Defendant knew that Plaintiff wanted the calls to stop.

Because Defendant lacks protocols, supervision, and proper training of employees, vendors, and agents, Defendant lacked the ability to even implement its internal Do Not Call procedure.

Plaintiff suffered damages, losses and harm as a result of Defendant’s negligent training, hiring and supervision.

Defendant’s violations were reckless and outrageous, entitling Plaintiff to punitive damages.

Finally, Noviello alleged “invasion of privacy by intrusion upon seclusion”.

All up, Noviello sought $5000 per TCPA violation plus unspecified actual, compensatory and punitive damages.

On January 27th, 2025, in a filed Joint Status Report, Integrity claimed Noviello’s allegations lacked supporting facts and were “meritless”.

Nonetheless,  Integrity acknowledged Noviello had

made an offer of settlement to Integrity, and that offer is under consideration by Integrity.

It appears  a settlement was reached shortly thereafter, leading to a Joint Stipulation of Dismissal filed on February 17th, 2025. The court terminated Noviello’s case on February 18th.

BehindMLM is aware of eight civil TCPA fraud lawsuits filed against Integrity, pertaining to unsolicited Family First Life marketing calls:

  1. Plaintiffs Francisco Baserva and Francisco Suescum filed suit against Family First Life LLC in October 2021 (case settled May 2023)
  2. Plaintiff Mark Dobronski filed suit against Family First Life in August 2022 (case settled January 2025)
  3. Plaintiff Don Campbell filed suit against Integrity Marketing Group in September 2022 (case settled in April 2023)
  4. Plaintiff Robert Salomon filed suit against Family First Life in March 2023 (case settled October 2023)
  5. Plaintiff Aaron Rapp filed suit against IMG (dba Family First Life) in June 2023 (case settled July 2024)
  6. Plaintiff Terri Nichols filed suit against Integrity Marketing Group in September 2023 (case settled December 2023)
  7. Plaintiff Wes Newman filed suit against Integrity Marketing Group (see Nichols link above) in April 2024 (case settled April 2026)
  8. Plaintiff Steve Noviello filed suit against Integrity LLC in October 2024 (case settled February 2025)

Given at least eight TCPA lawsuits have been filed against Integrity and/or Family First Life, clearly this is an ongoing issue for the company.

TCPA is regulated federally by the Federal Communication Commission (FCC). Whether the FCC has opened an investigation into Integrity and Family First Life is unclear.