Document 245 - Aaron Levy Telling Judge That Family First Life Is Criminal Organization

Case 9:22-cv-80243-AMC Document 245 Entered on FLSD Docket 09/06/2024 Page 1 of 39
c_::, - 5 2024
IN THE UNITED STATES DISTRICT COURT FOR THE SOU1H-ERN1- --.1

DISTRICT OF FLORIDA
FAMILY FIRST LIFE , LLC ,
Plaintiff,
V. Case No. 9:22-cv-80243-AMC
David Rutstein , NATIONAL ASSOCIATION OF ACCREDITED
INSURANCE PROFESSIONALS, et al
Defendants.
NONPARTY RESPONDENT Aaron Levy Additional OBJECTION TO
PLAINTIFF FAMILY First Life's proposed order to court
Important information has been known to me recently that should provide

clarity to the court as to the facts of this case.
On August 20 th Family First Life (FFL) was invited to request a hearing by

the Oklahoma Department of Securities. TinyUrl link here:
https://tinyurl.com/ok-securities
Or
https://www.securities.ok.gov/Enforcement/Orders/PDF/AffofCompNoticeof
HrgRecommCertofSvc FamilyLifeFirst 24-020.pdf
or Exhibit 1.
FFL can request a hearing within 15 days of August 20 th to show why a
cease and desist to FFL doing business in Oklahoma based on FFL
violating the Oklahoma Business Opportunity Sales Act should not be
enacted .
My office has had extensive conversations with Oklahoma Department of

Securities Investigator Phillip Cole. Investigator Cole is the Retired Police
Chief at City of Bethany , Oklahoma and is aware that crimes that FFL is
committing in violating the Oklahoma Business Opportunity Sales Act are
systemic in the new insurance agent recruiting industry. FFL's arent
company , Integrity Marl<•~ting Group, owns numerous i,.... b$· ~rari Equis
SrP - 6 2024
A ,... ~A E 'JO LE
Financial, PHP Agency , North American Senior Benefits, National Agents

Alliance , and dozens of other Integrity Marketing Group companies) that
are doing the identical law violation . You can see the list of over 200
Integrity Marketing Group Companies at https://integrity.com/partner/.
Over a dozen of the 200+ plus subsidiaries of Integrity Marketing Group are
direct downlines of FFL and its CEO Shawn Meaike.
It is my belief that FFL/lntegrity will not dispute their cease and desist in
Oklahoma but will continue to violate the law with their numerous other
subsidiaries.
We will see in the coming months how this Oklahoma cease and desist of
Oklahoma plays out. And I will be working my tail off that the 49 states
know and understand the Oklahoma action and the FFL/lntegrity Scam.
The reason that FFL will not dispute their Oklahoma cease and desist is
simple . Oklahoma has the evidence to prosecute and convict in a criminal
proceeding.
Read Oklahoma's statute governing Business Opportunity Sales

Law. https://www.securitr~5:..ok.gov/Act-Rules/Busopp.asp
A§ 823 . Vio/ations--Penalties--Criminal prosecutions describe the penalty

as "upon conviction be fined not more than Ten Thousand Dollars
($10,000.00) or imprisoned not more than ten (10) years or both for each
offense."
I have noticed that FFL attorneys have never refuted my claims that "it is
obvious that FFL is in violation of the various states 'Business Opportunity
Sales Laws. "
In the coming months, I will be lobbying Oklahoma and the other states to
take firm action on the civil and criminal side against FFL and the states
should understand tha~ it is not just FFL, but the whole Integrity Marketing
Group that is engaged in a premeditated criminal scheme.
With this new information that is public, I beg the court to reverse its
previous erred decision it . ordering the shutdown of my website domain
www.naaip.org and the other shutdown orders that punished me.
I feel bad that I caused Mr. Rutstein to be slapped with a huge financial
judgement. Certainly it 1:1oull.l be correct of the court to reverse that
financial judgement order against Mr. Rutstein .
The court should consider that Family First Life has virtually no value as a
company considering that Oklahoma gave FFL a cease and desist which
will probably cause the other 49 states to do similar, and then revoke the
insurance licenses of the FFL leadership. The Oklahoma C & D is most
likely the first step to criminal felony charges and attorneys throughout the
USA filing lawsuits for victims of FFL on a contingency basis. It is safe to
say that that FFL as a business has a minimum of no value and most likely
a negative value to its parent company , Integrity Marketing Group.
The FFL/lntegrity attorneys and expert witnesses must have known the risk
that any of the 50 states could begin criminal and civil proceedings against
FFL, since their business model were in clear violation of Business
Opportunity Sales Law of Oklahoma and other states.
Exhibit 2 - See FFL FTC Cease and Desist here

- https://tinyurl.com/ffl-cease
If you read the FTC cease and desist that FFL received in December 2021
you see that "business opportunit" is repeated 12 times . That is a big hint
that FFL was at severe risk that one of the 50 state Attorney Generals
would initiate legal proceeding against FFL that would eliminate the value
of FFL completely . Blaming Mr. Rutstein for approximately $5 million of lost
value and then trebling the damages is pure lunacy when involving a
company that's core business technique involved violating the law.
The FFL expert witness in valuing damages done by Mr. Rutstein was
dishonest in their "exp~rtise."
The court should be aware that FFL attorneys have attempted at least two
times to transfer lawsuits that FFL was Defendant to your court in Florida.
https://casetext.com/ca~r 'bit ch-v-family-fi rst-life-lk-3

or https://tinyurl.com/no-transfer-court
3
Opinion
22-cv-815-MMA (NLS)
04-13-2023
GREG BIRCH, individually and on behalf of all others similarly situated, et al. ,
Plaintiffs, v. FAMILY FIRST LIFE, LLC, et al. , Defendants.
MICHAEL M. ANELLO, UNITED ST ATES DISTRICT JUDGE
And the Judge's decision: ''As such, the Court finds that the issues in the Florida
Action lack sufficient similarity to the current case to justify invoking the first-to-
file rule and transferring this suit to the Southern District of Florida.
Accordingly, because Defendant FFLfails to establish two out of three prongs, the
Court DENIES its motion to transfer or stay this case based on the first-to-file
rule."
The other instance that FFL tried the similar "d irty trick" of having the lawsuit
transferred to your court is the ongoing case in which Judge Mark Dobronski is
suing FFL for violating Do ,~ot Ca ll laws. That motion was similarly rejected by the
court in Michigan. Case No.2:22-cv-12039-DPH-JJCG.
I know that the court is sensitive that litigants shou ld not waste the court's time.
In reading Judge Anello's opinion, it is obvious that FFL has a history of wasting
various Federal court's valuab le time.
The following evidence that I am presenting should be very disturbing to the

court. FFL filed two t imes against Mr. Rutstein. Eac h filing costs $402.
https://dockets.justia.com/docket/florida/flsdce/9:2022cv80242/608045
or https://tinyurl.com/first-filing
Family First Life, LLC v. Rutstein et al 9:2022cv80242 I Florida Southern District Court
Date Filed: 02/15/2022 Date T~rminated: 02/16/2022. And
And then later on the same day of 02/15/2022 Family First Life, LLC v. Rutstein (9:22-
cv-80243) District Court, S.D. Florida
https://www.courtlistener .C0;1·1/docket/63002125/fam ily-first-life-llc-v-rutstein/

or https ://tinyu rl.com/second-filing .
I do know that as soon as one files a lawsuit that a judge is automatically assigned
and the normal occurrence would be to cancel the first filing if a duplicate lawsuit
filing was made in error . .
I was told that this lawsuit was filed in the relatively small Federal Courthouse of
I
Fort Pierce, Florida .
It appears that FFL did "J.udge Shopping." Especially considering that the lead FFL
attorney was a female attorney in her late 30s who had previous clerked for a
conservative Supreme Court Justice Clarence Thomas, which is similar to this
court's Judge who also clerked for a conservative Judge Steven Colloton and is of
similar age.
"Judge Shopping" is well k11Jv11n as a real problem that the court system is
grappling with. The court does have discretion to sanction plaintiffs that "Judge
Shop ."
https://www.reuters.com/legal/government/alabama-judge-weigh-sanctioning-
lgbtq-lawyers-judge-shopping-2024-06-24/ or https://tinyurl.com/ffl-shopping
"In an unusual move, U.S . District Judge Liles Burke, an appointee of Republican former
President Donald Trump, slated three days of hearings in Montgomery in which the attorneys
must demonstrate why they should not be sanctioned for misconduct for "judge shopping.""
After perusing the court's Judge Wikipedia page, it appears that the most notable
case of the Judge which working as assistant United States attorney is
"In 2019, Cannon was p~rt of the prosecution that won an appellate ca se
involving Scott W. Rothstein, which allowed prosecutors to withdraw support for
reducing his SO-year sentence for a Ponzi scheme."
There is a definite similarit·1 in the name and probable ethnic background of

"David Rutstein " and "Scott Rothstein ." Rutstein and Rothstein are, in fact, the
same name and not very common in the United States. Couple that Mr. Rutstein
was being accused of being a white-collar criminal, while Mr. Rothstein is a
convicted white-collar criminal serving a SO-year sentence .
5
I am not stating that the court is "in cahoots" with FFL and their huge white collar
criminal enterprise, but it is an insult to the court that FFL would entangle the
court with an appearance of impropriety that would lessen the public's trust in
the court system and thip court.
FFL vs Rutstein is not a small case. FFL's parent company, Integrity Marketing
Group, has garnered $4.75 Billion dollars in investment capital in its quest to
dominate the insurance agent recruiting industry.
https://pitch book.com/profiles/ com pa ny/162831-61#ti meli ne or https://tinyu rl .com/integrity-size
• What is the size of Integrity Marketing Group?

Integrity Marketing Group has 5,000 total employees.
How much funding has lnteg dy Marketing Group raised over time?
Integrity Marketing Group has raised $4.57B.
And https://tinyurl.com/450k-agents
"Integrity's nearly 6,000 employees work with more than 450,000 agents
and advisors who serve over 10 million clients annually ."
My experience and knowledge of the insurance agent recruiting industry has

taught me that that the huge percentage of new insurance agents are wasting
their time and effort as they enter the profession .
Here is the statistics that explain the harm that is done to the American
people , especially thos~ in their early 20s and of immigrant status.
https://www.agentmethods.com/insurance-agent-trends-and-statistics or
https://tinyurl .com/agent-stats
In 2022, 382,913 people ·rdtionwide took licensing exams for the first time. Of
these, 221,568 passed. Thirty percent of new agents leave in their first 90 days.
(Podium , 2023) More than 90% of new agents quit the business within the first
year. The rate inc reases to greater than 95% when extended to five years.
(lnvestopedia , 2023).
FFL and its sister Integrity Marketing Group companies have implemented an
incredibly successful technique to harm these new insurance agents which is
completely dependent on violating state Business Opportunity Sales Laws, The
FTC Franchise Rule and state Deceptive Business Practice Law.
I
Over the years FFL/lntegrity Marketing Group has sent out well over 1,000 lawsuit
threats to agents/victims that have complained about FFL on social media. And
because the involvement of Mr. Rutstein. Him being disabled, broke, overseas,
etc. it seemed like the easiest task to get Mr. Rutstein a huge monetary
judgement which FFL/lntegrity attorneys could add to their scary cease and desist
lawsuit threat which FFL attorneys regular ly send to those agents who sµeak out
on social media.
In addition to reversing th(: cc,:irt's ruling against Mr. Rutstein and my online
properties. I urge the court to order FFL/lntegrity to give over to me or to the
court the contact information of the list of insurance agents lawsuit threatened
over the years so I can personally inform those FFL/lntegrity victims of that
www.naaip.org is not shut down by the court and tell those who were lawsuit
threatened the legal ramifications of Oklahoma's actions against FFL.
Ordering my suggestion would certainly return honor to this court which has been
harmed by America's most successful white collar criminal enterprise.
The court understands the resources that the government spent and continues to
spend because of the crimes of Scott Rothstein are worthwhile because punishing
criminals deters crimes and is necessary for an orderly society.
This court has the opportunity to reverse an erred decision and take steps to
hasten the downfall of the FFL/lntegrity Marketing Group scam.
The difference between V :e S(ott Rothstein Scam and the FFL/lntegrity Scam is
the magnitude of the crime and that FFL's victims are primarily young adults and
already broke.
Thank you for your time.

DECLARATION OF Aaron Levy does declare as follows : 1. I am of

the age of majority and have personal knowledge as to the information
written in this filin g to the court.
Aaron Levy: Sept 2nd, 2024 111 Agripas Street Jerusalem, Israel 9451311
Telephone: 1-561-Ll '.f0-9245 Nonparty Respondent in Propria Persona
IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF

FLORIDA
V. Case No. 9:22-cv-80243-AMC

David Rutstein, NATIONAL ASSOCIATION OF ACCREDITED INSURANCE
PROFESSIONALS, et al Defendants,
CERTIFICATE of SERVICE
I hereby certify that on Sept 2nd, 2024, I caused copies of NON PARTY
RESPONDENT Aaron Levy OBJECTION TO PLAINTIFF FAMILY First
Life's proposed orfr~r to court to be served upon all parties of record to
the above captioned cause herein by sending the same by via email to the
following parties. Drew Thompson Bell, Esq. King & Spalding LLP 500 West
Second Street, Suite 1800 Austin, Texas 78701 Attorney for Plaintiff Family
First Life. [email protected].
David Rutstein [email protected]. Defendant Pro Se I declare under

the penalty of perjury that this Certificate of Service has been examined by
me and that its contents are true to the best of my information, knowledge,
and belief.
Aaron Levy aaron levywebsites@gma il.com Sept 2nd , 2024
U.S. Courthouse
701 Clematis Street, Clerk of Court
West Palm Beach , FL 33401
(561) 803-3400
9
IO
STATE OF OKLAHOMA
DEPARTMENT OF S.ECURITIES
204 NORTH ROBINSON AVENUE, SUITE 400
OKLAHOMA CITY, OKLAHOMA 73102 .i
FILED
In the Matter of:
AUG 2 a2024
With Ill,·
Family First Life, LLC, Adminlstr ...
Respondent. ODS File No. 24-02
AFFIDAVIT OF COIVIPLIANCE
AND
NOTICE OF SERVICE ON THE ADMINISTRATOR
STATE OF OKLAHOMA )
) SS.
COUNTY OF OKLAHOMA )
The undersigned affiant, oflav,,ful age, being first duly sworn upon oath deposes and states:
1. That she is the Administrator of the Oklahoma Department of Securities

("Administrator").
2. That a copy of the Enforcement Division Recommendation and Notice of

Opportunity for Hearing ("Order and Notice"), attached hereto was delivered to Affiant in the
office of the Administrator pursuant to Section 818 of the Oklahoma Business Opportunity Sales
Act ("Act"), Okla. Stat. tit. 71, §§ 801 through 829 (2024).
3. That the Administrator has received service of process on behalf of Respondent,

pursuant to Section 818 of the Act.
4. That a copy of the Order and Notice and a copy of this Affldavit ofCompliance and
Notice of Service on the Administrator are being sent this ~~ay of August, 2024, by certified
mail, return receipt requested, delivery restricted, to the last known address of Respondent, in
compliance with Section 818 of the Act.
5. That this Affidavit of Compliance and Notice of Service on the Administrator is

decJared filed of record as of the date set forth below in compliance with Section 818 of the Act.
II
FURTHER AFFIANT SAYETH NOT.
Dated this )./; ~~ay of August, 2024.
(SEAL)
MELANIE HALL, ADMINISTRATOR OF THE

OK.LAHOMA DEPARTMENT OF SECURITIES
Subscribed and sworn to before me this~y of August, 2024.
(SEAL)
Notary Public
,' I
2
OKLAHOMA DEPARTMENT OF SECURITIES

204 North Robinson, Suite 400
Oklahoma City, Oklahoma 73102
11 Il Urn~ 1
Family First Life, LLC
c/o Shawn Meaike, CEO .
Return Receipt nd 1
80 Norwich New Lo on Turnpike, Su 1Rf!sTRfCTED DELIVERY
Requested Uncasvi lle, CT 06382 ·
3TATE OF OKLAHOMA
DEPARTMENT OF SECURITIES
204 NORTH ROBINSON A VENUE, SUITE 400 i-=tLED
OKLAHOMA CITY, OKLAHOMA 73102
UG 2 0 2024
wilhthe
Administrator
In the Matter of:
Family First Life, LLC,
NOTICE OF OI>PORTUNITY FOR HEARING
1. Pursuant to Section 813 of the Oklahoma Business Opportunity Sales Act ("Act"),
Okla. Stat. tit. 71, §§ 801-829 (2024), the Oklahoma Department of Securities ("Department")
conducted an investigation into the activities of Family First Life, LLC ("Respondent") in
connection with the offer and/or sale of a business opportunity in and/or from the state of
Oklahoma.
2. On the 0£l~ay of August, 2024, the attached E,?forcement Division

Recommendation ("Recommendation") was filed with the Administrator of the Oklahoma
Department of Securities ("Administrator").
3. Pursuant to Section 814.B of the Act, the Administrator hereby gives notice to
Respondent of its right to request a hearing to show why an order based on the Recommendation
should not be issued.
4. The request for a hearing on the Recommendation must be received by the

Administrator within fifteen (15) days after service of this Notice. Pursuant to Section 814.B of
the Act, failure to request a hearing as provided for herein shall result in the issuance of a final
order directing Family First Life, LLC to cease and desist from the offer and sale of business
opportunities ju violation of Section 806 of the Act.
5. The request for hearing shall be in writing and Respondent shall specifr::ally admit
or deny each allegation made in the Recommendation as required by 660:2-9-2(a) of the Rules of
the Oklahoma Securities Commission and the Administrator of the Department of Securities
("Rules").
6. Upon receipt of a written request, pursuant to 660:2-9-2 of the Rules, a hearing

shall be promptly set or a written order denying hearing shall be issued.
7. Notice of the date, time, and location of the hearing shall be given to Respondent
not less than forty-five (45) days in advance thereof pursuant to 660:2-9-2(c) of the Rules.
Additionally, the notice of hearing may contain information specified by 660:2-9-2(d) of the Rules.
) L/-
2. Section 806 of the Act provides:
It is unlawful for any person to offer or sell any business opportunity, as defined
in Section 802 of this title, in this state unless the business oppo1iunity is
registered under the provisions of the Oklahoma Business Opportunity Sales
Act or is exempt under Section 803 of this title.
3. Section 814 of the Act provides in pertinent part:
A. Whenever it appears to the Administrator that any person has engaged in

or is about to engage in any act or practice constituting a violation of any
provision of the Oklahoma Business Opportunity Sales Act or any rule or order
hereunder, the Administrator may:
1. Issue an order directing each person to cease and desist from

continuing the act or practice and/or issue an order imposing a civil
penalty up to a maximum of Five Thousand Dollars ($5,000.00) for a
single violation or transaction or of Fifty Thousand Dollars
($50,000.00~ for multiple violations or transactions in a single
proceeding or a series of related proceedings[.]
Co11clusio11s o{Law
1. The Agreement is a business opportunity.
2. Respondent offered and sold a business opportunity in and/or from the state of
Oklahoma.
3. The offer and sale of the business opportunity by Respondent in and/or from this state
without registration under the Act is a violation of Section 806 of the Act.
WHEREFORE, it is recommended that the Administrator issue an order against

Respondent to cease and desist the offer and sale of business opportunities in and/or from this state
in violation of Section 806 of the Act.
Dated this~ay of August, 2024.
, !!:illy Suo/'{tted,
\~~~~✓
1
Amanda Cornmesser
Enforcement Attorney
Oklahoma Department of Securities
204 North Robinson Avenue, Suite 400
Oklahoma City, OK 73102
(405) 280-7725
STATE OF OKLAHOMA
DEPARTMENT OF SECURITIES
204 NORTH ROBINSON AVENUE, SUITE 400 FILED
.
OKLAHOMA CITY, OKLAHOMA 73102
AUG 2 0 Z02~
In the Matter of: with the
Admlnlstrotor
Family First Life, LLC,
ENFORCEMENT DIVISION RECOMMENDATION
Pursuant to the Oklahoma Business Opportunity Sales Act ("Act"), Okla. Stat. tit. 71, §§
801-829 (2024), the Oklahoma Department of Securities ("Department") conducted an
investigation into the activities of Family First Life, LLC ("Respondent"), in connection with the
offer and/or sale of a business opportunity in and/or from the state of Oklahoma. Based thereon,
the Findings of Fact, Authorities, and Conclusions of Law set forth herein are submitted to the
Administrator of the DcpartmePt ("Administrator") to support the issuance of a cease and desist
order against the Respondent.
Fi11di11gs of Fact
1. Respondent is a Connecticut limited liability company established in 2013, with a

principal place of business in Connecticut. Respondent also has an independent office located in
Seminole, Oklahoma. At all times material hereto, Respondent maintained a website at
https://www.familyfirstlife.com.
2. An Oklahoma resident (Oklahoma Resident), a former esthetician, lost his job

during the pandemic and while off work, saw advertising materials distributed by the Respondent
on Twitter, Instagram, and Facebook. The advertising materials contained testimonials on financial
success with the Respondent.
3. The Oklahoma Resident contacted Respondent to inquire about the services the
company offered to provide assistance in opening an insurance business, including, but not limited
to, providing sales training and insurance sales leads that would help the Oklahoma Re,sident start
his business. The Oklahoma Resident entered into a verbal agreement ("Agreement") to purchase
services from Respondent on December 15, 2020.
4. Respondent advvrtised that the insurance leads would produce upwards of $30,000
a month in profit.
5. From May 2021 to June of 2022, the Oklahoma Resident purchased sales leads
from ResJJondent at a cost of $17,865. The Ok lahoma Resident was advised that he could
discontinue the purchase of sales leads at any time.
6. Initially, the Ok.ahoma Resident paid Respondent $1000 a week for sales leads to
only break even. In time, the Oklahoma Resident expressed his concerns about falling short of the
monthly income potential advertised by Respondent. Respondent's solution was to encourage the
Oklahoma Resident to purchase larger quantities of sales leads to reach the full potential income
advertised.
7. Respondent provided a "marketing plan" as defined by § 802(6) of the Act.

Respondent furnished the Oklahoma Resident with promotional materials and videos of current
participants who were making upwards of $40,000 per month using their leads and training.
8. The Agreement offered and sold by Respondent is not and has not been registered
under the Act.
9. In December of 2021, the Federal Trade Commission issued a cease and desist
order against Family First Life after reviewing social media posts and determining that the
company was "unlawfully misrepresenting that consumers who become Family First Life business
opportunity participants are likely to earn substantial income."
Authorities
1. Section 802 of the Act provides in pertinent part:
* * *
3 .a. "Business opportunity" means a contract or agreement, betv,1een a seller

and purchaser, express or implied, orally or in vvriting, wherein it is agreed that
the seller or a person recommended by the seller shall provide to the purchaser
any products, equipment, supplies or service enabling the purchaser to start a
business and the seller represents directly or indirectly, orally or in writing,
that:
(6) The seller v,,ill provide a marketing plan.
6. "1\1arketi11g plan'' means advice or training, provided to the purchaser by the

seller or a person ' recommended by the seller, pertaining to the sale of any
products, equipment, supplies or services and the advice or training includes, but
is not limited to, preparing or providing:
a. Promotional literature, brochures, pamphlets or advertising

materials;
b. Training regarding the promotion, operation or management of

the business opportunity; or
c. Operational, managerial, technical or financial guidelines or

assistance.
)1
C) ~tness my Hand and the Official Seal of the Oklahoma Department of Securities this
_ __ day of August, 2024.
_'7)
(SEAL)
MELANIE HALL, ADMINISTRATOR OF THE
2
CERTIFICATE OF SERVICE
I hereby certify that on the~y of ./)oL{)'u,A- 2024, a trne and correct copy of
the above and foregoing instrument was deliv--;:~mail, certified, return receipt,
and restricted delivery with t)ostage fully prepaid thereon, to:

c/o Shawn Meaike, CEO
80 Norwich New London Turnpike
Uncasville, CT 061382
Michelle L. Staim

204 North Robinson, Suite 400
Oklahoma City, Oklahoma 73102
7016 0750 DODO

Return Receipt c/o Shawn Meaike, CEO
• Requested 80 Norwich New London Turnpike, Su ite 1B
RESTRICTED DELIVERY
United States of America

• FEDERAL TRADE COMMISSION
Washington, D.C. 20580
December 27, 2021
CEASE AND DESIST DEMAND
VIA EMA IL TO shawn.meaike@ fam ilvfirstlife.com

c/o Shawn Meaike, CEO
80 Norwich New London Turnpike
Re: Earnings Claims R P- i..iLd to Coronavirus Disease 20 l 9 (COVID-19)
Dear Mr. Meaike,
This is to advise you that FTC staff has reviewed social media posts made by Family
First Life's business opportunity participants or representatives in December 202 1. We have
determined that Family First life is unlawfully misrepresenting that consumers who become
Family First Life business opportunity participants are likely to earn substanti al income.
Some examples of earnings claims made by your business opportunity participants or

representatives include:
• "Make your WEEKLY salary in ONE DAY as an Agent w ith Family First Life ....
What was your biggest paycheck in a month? -- Last month I checked on mine and it
was like $40k in a month .... -- What attracted yo u to the insurance business? -- I
think it was like a combination of multiple things. I was really burned out with covid
stuff, working at a hospital. And , my upline ... I met him and ... he was making
some money , really good money. And, I just didn ' t really have anything to lose at
that point. So, I kind of just was like, let's do it." [Posted to TikTok by @ winw ithffl
on July 14, 2021].
• "I've been with Famiiy First Life for 3 full months, okay, before joining Family First
Life, I was a nurse for 7 years. Okay, um , covid hit. I have a 5-year-old son with
cystic :fibrosis, his pulmonologist took me away from patient care, so I was kind of
home all the time, and it just wasn ' t th e sa me. So, I found Family First Life, jumped
on board ... Since jumping on board, it 's changed my life, my family ' s :financial
situation. Last month I did $46,000 issue pay. One month, y'all. That' s insane. So, if
you are a hard worker, if you ' re yo ung, if you' re energetic, if yo u' re looking for a
change and want :financial freedom , let me know [.] . . . #:financi alfreedom ." [Posted to
TikTok by @ meighanadams on June 5, 202 1].
• "Hi there, my name is Lelah. If you ' re like me, which many of you I' m sure are,
you' ve been significantly impacted by the pandemi c. I had lost my j ob, my career. I
had no pri or life insuran ce experience. I started w ith Family F irst in Ja nuary. Thi s
last weekend I had made - just in one weekend - what would have taken me l 0
months at my prior job. I'm a single mom w ith three kids, and ifl can do this,
anybody could do it. Click the link below to learn more." [Posted to Y ouTube by
FFL U.S.A. on April 13, 202 1].
Representations about a business opportunity, including earnings claims, violate Section

5 of the FTC Act, 15 U.S.C. § 41 et seq. , if they are fa lse, misleading, or unsubstantiated and
materi al to consumers. Express and implied earnings claims must be truthful and non-mislead ing
to avoid being deceptive, which means that claims about the potential to achi eve a wealthy
lifes tyle, career-level income, or significant income are fa lse or misleading if business
opportunity pa1iicipants generally do not achieve such results. Even truthfu l testimonials from
participants who do earn significant income or more will likely be mi sleading unl ess the
adverti sing also makes clear thf. 1111ount earned or lost by most participants. Yo ur business
opportunity participants and rtpresentati ves must immediately cease making all express and
implied earnings claims that would be fa lse or misleading to current or prospective participants.
You are responsible fo r the claims of yo ur business opportuni ty parti cipants and
represe ntatives. As the FTC stated in the January 201 9 Business Guidance Concerning Mu lti-
Level Marketing, the compensation structure of a Multi-Level Marketing entity ("MLM") may
create incentives fo r its participants to make ce1iain representations to current or prospective
participants. " As a consequence, an MLM should (i) direct its participants not to make fa lse,
misleading, or unsubstantiated representati ons and (ii) monitor its participants so they don' t
make fa lse, misleading, or unsubstantiated representations."
Please also note that, as outlined in the Notices of Penalty Offenses Concerning Money-
Making Opportunities and E1~dorsements and Testimoni als that was sent to you in October and
November 202 1, the Commission has determined, among other things, that it is an unfair or
decepti ve trade practi ce to make false, misleading or deceptive representati ons concerning the
profits or earnings that may be anticipated by a parti cipant in your business opportunity.
(Another copy of the Notices and the associated cover letter is attached hereto). Engaging in the
conduct described in the Notices could subj ect yo u to civil penalties of up to $43 ,792 per
violation.
Within 48 hours, please send a message to Kati Daffa n (Assistant Director) via electronic
mai l at [email protected] certify ing that you and your parti cipants and representati ves have
ceased making express and implied earnings claims that wo uld be fa lse or mi sleading to curren t
or prospective participants. If you have any questions regarding compliance with the FTC Act,
please contact Suzanne Barth at 202-3 26-33 17 or Meli ssa Dickey at 202-326-2662.
Very trul y yo urs,
/s/ Lo is C. Greisman
Lo is C. Greisman
Associate Director
Division of Marketing Practices
cc: YouTube via email to [email protected];

TikTok via email to [email protected]
UN IT ED STA T ES O F AMERICA
Federal Trade Commission
Was hin gton, D.C. 20580
Division or Ma rketi ng Practices
October 26. 202 I
Via Federal Express

Fami ly First L ife
c/o Shawn Meaike
2 Chapman Lane
Unit 5
Gales Ferry. CT 06335 -1222
Re: Penalty Offenses Concernin g Money-Making Opportunities
Dear Sir or Madam:
I am enclosing a copy of the Federal Tracie Co mmi ss ion's Notices of Penalty Offenses
Concerning Money-Making Opportunities and Endorsements and Testimonial s. We recommend
that yo u carefully review the notices and take any steps necessary to ensure that your company 's
practices do not vio late the law.
The notices summarize Commi ssion determinati ons in prior litigated cases that paiiicular
acts or practices are penalty offenses-i.e., that they are deceptive or unfa ir, unlawful under
Section 5 of the Federal Trade Commi ssion Act, and prohi bited by a fi nal cease and desist order.
More detail s about the Commi ssion determinati ons are contained at pages 2-8 of this lette r
below.
Receipt of these notices of penalty offenses puts your company on notice that
engagin g in the conduct described therein could subject you to civil penalties of up to
$43,792 per v iolation. 1
Staff is not singlin g out yo ur company or suggesting that yo u have engaged in deceptive
or unfair conduct. We are widely di stributing simil ar letters and the notices to business
opportunities, fra nchi ses, multi-level marketing co mpanies. coaching companies. gig companies,
and others. Cop ies of the case decisions di scussed in th e sy nopsis are avail ab le on the
Commi ss ion' s we bsite at ftc. gov/MMO-n otice and ft:c.gov/endorsement-noticc-pe nalty-offcnses.
We request that you distribute copies of the noti ces of penalty offenses and this letter to
each of yo ur subsidiaries that sell s or markets products or services to consLm1ers in the United
States.
Please note that nothing in this letter or the attached notices alters, modifies, or
impacts your obli gations, if any, under the Business Opportunity Rule, the Franchise Rule,
1
See 15 U.S.C. § 45(m)( l )(B); 16 C.F. R. § l.98(e).
or any other federal rule or statute. This letter and the notices do not purport to list all of the
deceptive or unfair practices that violate the Federal Trade Commi ss ion Ac t (''FTC Act") or all
the federal court cases address ing when an earnin gs claim is unfair or deceptive in vio lation of
the FTC Act. The Commission's website (ftc.gov) has other important resources concerning the
Federal Trade Commission Act, the Business Opportunity Rule, and the Franchise Rule,
including the Endorsement Guides, Bogus Business Opportunities. Business Guidance
Concerning Mu lti-Level Marketing, Amended Franchise Rule FAQ's, Franchise Rule
Compliance Guide, and .com Disclosures: How lo Make Effective Disclosures in Digital
Advertising.
The Notices
I. Notice Concerning Money-Making Opportunities
The notice outlines determinations made by the Commission in liti gated decisions in
which the Commi ssion also issued a final cease and desist order. These determinations are
consistent with well-settled federal court and Commission precedent.
A. Earnings Cla~m Determinations

•,
1. Legal Overview
The Commission has determined that it is an unfair or deceptive trade practice to make
false, misleading or deceptive representations concerning the profits or earnings that may be
anticipated by a participant in a money-making opportunity (i.e., a person who has been accepted
or hired for, has purchased, o~· otherwise is engaging in the money-making opportunity). 2
Numerous courts have confirmed this determinatio n. 3
In determining whether an earnings representation is like ly to mislead consumers, courts

consider the overall "net impression'" it creates. 4 Claims of "potential" earnings imply that such
2
Nalionul Dynamics Corp., 82 FTC 488, 5 12- l 3. 543-44, 568 ( 1973). as modifi ed at 85 FTC I 052, I 059-60 (1975):
Universal Credit Acceptance Co,p., 82 FTC 570, 59 1-600, 633 (1973): Universal £lee. Corp., 78 FTC 265, 271-74
(197 1); Windsor Distrib. Co., 77 FTC 204, 2 12- 17, 220 (1970): Waltham Watch Co., 60 FTC 1692, 1710. 1724
( 1962); Washington /11/11shroo111 Indus., Inc., 53 FTC 368, 370, 376. 379-80, 383 -84, 386 ( 1956); Von Schrader A1((g
Co., 33 FTC 58, 63-65 ( 1941 ); Macmillan, Inc., et al., 96 FTC 208. 232, 30 1-02, 326-29 ( l 980); Holiday Magic, 84
FTC 748, 948, I032-1033 ( 1974), as modified at 85 FTC 90 ( 1975): Abel Allan Goodman Trndi11g As Weavers
Guild, 52 FTC 982, 988 ( 1956), order affi rmed 244 F.2d 584 (9th Cir. 1957); Encyclopaedia Britannica, Inc., et al..
87 FTC 42 1, 450, 486-88, 53 1-32 ( 1976); Ger-Ro-Mar, Inc., 84 FTC 95, I 13- 14, I 17-1 19, 123-125 , 132-135, 138,
149-1 50, 160-162 (1974), affirmed in relevant part at 518 F.2d 33 (2d C ir. 1975), as modified at 86 FTC 84 1 ( 1975).
3 See. e.g., FTC v. Vemma Nutrition Co. , No. 2: I 5-CY-1578, 20 15 WL I 11181 11, *5 (D. Ariz. Sept. I 8, 2015); FTC
v. Kit co of Nevada. Inc.. 612 F. Supp. 1282, 1292 (D. Minn. 1985); FTC v. Sage Seminars, No. 95-CY-2854, 1995
WL 798938, *3-5 (N .O. Cal. Nov. 2, 1995); FTC v. Network Servs. Depot, Inc., 6 l 7 F.3d 11 27, 1139-40 (9th Cir.
20 IO); FTC v. Tashman, 3 18 F.3d ,1273, 1277- 78 ( I Ith C ir. 2003); FTC v. Freecom Comm ·s, Inc., 40 I F.3d I 192,
1203- 04 ( I0th Cir. 2005).
4
FTC v. Stefanchik, 559 F.3d 924, 928 (9th C ir. 2009).
. '
2
earnings are representative of what the typical participant achieves. 5 Before making such a claim
regarding potential earnings (e.g. , via a testimonial of a well-paid member), the advert iser must
possess adequate substantiation that the experience described is representative of what
participants will generally achieve. 6 If the claim is not representative, the advertisement must
avoid giving that impression. It is important to bear in mind that disclaimers are not always
effective 7 and are not a defense if the net impression is still misleading. 8 Compan ies should
ensure that any independent salespeople also steer clear of deceptive earnings claims. 9
2. Federal Trade Commission Litigated Determinations
National Dynamics: 10 Respondents' ads for franc hises to sell a battery additive attributed
earnings to named distributors in the amounts of "$ 1554 one week ; $ 148 one clay; $23 16. 96 one
5
See FTC v. Five-Star Auto Club, Inc., 97 F. Supp. 2d 502, 528-529 (S.D.N.Y. 2000); see also FTC Gu ides
Concernin g th e Use of Endorsements an d Testimoni als in A dvertis ing 16 C.F.R. § 255 .2(b).
6
FTC v. Direct Mktg. Concepts, inc., 624 F.3d I , 8 ( I st Cir.2010); FTC v. John Beck Anrn:ing Pro.fits. LLC, 865 F.
Supp. 2d I 052, I 067 (C. D. Ca l. 20 12) (advertiser needs "some recogni za ble substanti ati on for the representati on
prior to maki ng it'') (q uoting FTC, ,_ Direct Mktg. Concepts. Inc., 569 F. Supp. 2d 285,298 (D. Mass. 2008)); FTC
v. Johnson, 96 F. Supp. 3d 11 I 0, I :120 (D. Nev.2015).
7
Indeed, research by the Commission has found th at even clear and prominent di sc losures of ' Results not typica l ' or
the stronger ' Th ese test imonia ls are based on th e experi ences ofa few peopl e and yo u are not likely to have simi lar
results,' are not suffici ent to di spel the impli cation that a testimoni al depicts typi ca l res ults. ·'A lthough the
Commission would have the burden of proof in a law enforcement action , the Comm iss ion notes th at an advertiser
possess ing re l iab le emp iri cal testing demonstrating that the net impress ion of its adverti sement with such a
di sclaim er is non-decepti ve wi ll avoid th e ri sk of th e initi ation of such an action in the first in sta nce.'' FTC Guides
Concerning the Use of Endorsemer-1 ts and Testimoni als in A dverti sing 16 C.F. R. § 255.2(b) n. I 05.
8
FTC v. Cyberspace. com. LLC, 453 F.3d I 196, 1200 (9th Cir. 2006) (fi ne print disclaimer no defen se if net
impress ion is still mi slead ing); FTC v. Con11elly, No. 6-CV-70 I , 2006 WL 626733 7 at* IO (C.D. Cal. Dec. 20,
2006) (disc laimers are particu larly inadeq uate when they appear in a different context than the claims they purpo1t to
repud iate); FTC v. QT. Inc., 448 F. Supp. 2d 908, 924 n. I 5 (N. D. 111. 2006), aff'd, 5 12 F.3d 858 (7th Cir. 2008)
(" Defendants' in conspicuous small:-fo .1~statement appea ring just six times during the 30-minute infomercial th at
·this product is not intended to di agr JSe, treat, cure or prevent di sease' is whol ly in adequ ate to change the net
impress ion of th e pain relief claims made in th e in fo merc ial. "). Di sc laim ers must be "pro minent and un amb iguous
to change the apparent meanin g and leave an accurate impression ... [a] nythin g less is on ly likely to cause confusion
by crea ting contradi ctory double meanings." Re11101,atro11 i11t 'l Corp. v. FTC, 884 F.2cl 1489, 1497 (1st Cir. 1989).
No disclosure can cure a fa lse claim- it "ca n only qua lify or limit a clai m to avo id a mislead ing im press ion." FTC
.com Disclosures, p. 5 (March 201 3); see also FTC Policy Statement on Deception (October 23, 1984) (appended to
Cl{ffdale Assocs. inc., I 03 FTC I I 0, 180-81 ( 1984). If a disclosure ·'contradicts a materia l claim, the di sc losure wi l I
not be sufficient," rather, " the claim itself mu st be modifi ed.'' FTC .com Di sc losures, p. 5. And qual ifi cations that
clarify otherw ise deceptive statements must be likely to come to th e attention of the person who sees the basic cla im ;
for that reaso n, small print or its eq ui va lent are unlikely to be effective. FTC v. Grant Connect, LLC, 827 F. Supp.
2d 1199, 1214, 1220- 122 1 (D. Nev. 20 11), vacated in part on other grounds, 763 F.3cl 1094 (20 14); Deception
Pol icy Statement, I 03 FTC at 180-81.
9
Companies may be l iable for decept ive claims made by such sa lespeop le. See e.g., Abel Allan Goodman Trading
As Wea1'ers Guild, 52 FTC 982, 988 ( 1956), ord er affirmed 244 F.2d 584, 592-593 (9th Cir. 1957): Holiday Magic,
84 FTC 748, 948, I 032-1033 ( 1974), as modified at 85 FTC 90 ( 1975); Waltham Watch Co., 60 FTC 1692, 1710,
1724 ( 1962); Five- Star Auto, 97 F. Supp. 2d at 527; FTC v. Partners In Health Care Ass 'n. Inc., 189 F. Supp. 3d
1356, 1365- 66 (S.D. Fla. 20 16); F.TC v. Skybi:.com, Inc., No. 0I-CV-396-K(E), 200 1 WL 1673645 , at *9 (N.D.
Okla. Aug. 3 1, 200 l ), aff'd, 57 F. App'x 374 ( I 0th Cir. 2003); FTC v. /lemma Nu trition Co., No. CV - I 5-1578, 20 I 5
WL 1I1 181 l I , at *7 (D. A ri z. Sepf. 18, 20 15) .
10
National Dvnamics, 82 FTC 488. 5 11-1 3, 543, 564, 568 ( 1973); 85 FTC I 052, I 059-60 ( 1975).
3
week; [and] $1028 one month.'' 11 The Commission held that these adverti sements falsely
communicated to consumers "that a substantial number of distributors" will ''regul arl y earn"
these amo unts. 12 The Commission ordered respondents to stop " [r] epresenting, directly or by
implication, that persons purchasing respondents' products can or will derive any stated amount
of sales profits," barred them from " [m]isrepresenting in any manner the past, present, or future
sales profits or earn ings from the resale of respondents· products,'' and required that testimonials
from atypically successful purchasers include numerous disclosures, including the actual average
of purchasers' earnings or the re1\,;~dage of purchasers earning the stated amount. 13
Holiday Magic: 14 The Commi ssion determined that the respondent, a multi-l evel marketing
company, and its distributors, had used false and decepti ve earnings claims, including
"misleadi ng illustrations of the manner in which an individual ... could build a large sales
organization, with substantial ... volume producing hefty profits," "false representations of the
earning potential of di stributors,'' and " representations concerning the ease with which [they] ...
could recoup their investments by recruiting other[s]." 15 ln truth, most di stribu tors "wo uld not
have a reasonable chance" of earning the represented earnings. 16 The Commi ssion ordered the
respondent to stop " [r] eprese ting. directl y or by implication, or by use of hypothetical examples
that participants in any marketing progra m ... will ea rn or receive. or have the potential or
reasonable expectancy of earning or recei ving, any stated or gross or net amount," and barred
representations of participants' past earn ings unless they "are those of a substantial number of
participants in the community or geographic area in which such representations are made" and
"clearly indicate [] the arnou1~_t of time required" to achieve the earnings. 17
Encyclopedia Britannica: 18 The Commi ssion fo und that respondents deceptively advertised a
substantial "guaranteed income'· to job-seekers. but those who accepted a position "seldom, if
ever, receive the guaranteed income," in part due to undisclosed limitations and cond itions. 19
The Commission ordered respo'1dents to stop misrepresentin g "the amount of income to be
earned by any person or that n.ay be earned by any person, the method of payment. or any
condition or limitatio n imposed upon the compensation of any person."'20
Von Schrader: 2 1 The Commiss ion determined that representations by a sell er of rug-cleaning
machines ·'with respect to amo unts earned by operators of their machines, including those
specifically set out in the complaint-' $200 to $400 a month is an easy average· and '$200 my
11
Id. at 511 -1 2.
12
Id. at 511- 13, 543 , 564 .
13
85 FTC I05 2, I059-61 ( 1975). The order included num erous oth er related prohi bitions.
14
Holiday !vlagic, 84 FTC 748, 948 , 980-984, I 032- 1034, I 06 5, I 069-71 ( 1974), as modified at 85 FTC 90 ( 1975).
15
Id. at 980-984, I 032-33 ; I 065.
16
Id. at 981.
17
Id. at 1069. The order included additiona l related prohi biti ons.
18
Enq1c/opaedia Brita1111ica. Inc., et al., 87 FTC 42 1, 445-50, 486-87, 505, 5 10, 532 ( 1976).
19
Id. at 445-50, 486-87, 505,5 10. •
20
Id. at 532.
21
Von Schrader Mfg. Co., 33 FTC 58, 63-66 (194 1).
4
first week'-are false and misleading in that respondents have no knowledge of what the actual
average profits or earnings of purchasers of their machines may be, and such knowledge as they
do have with respect thereto is limited to verba l and written statements made to them or their
representatives by a limited number of purchasers of the machines so ld by them. " 22 The
Commission ordered respondents to stop representing that profits made by operators of its
machines ·'average $200 or $40 -~ p::r month. or any other sum in excess of the actual average net
profits of such operators," and barred representations of atyp ical earnings " in a manner wh ich
imports or implies that ... [they] represent the usual and ordinary course of business."23
Washington Mushroom: 24 Respondents represented that their mushroom spawn wo uld

" produce large financial returns to purchase rs," that growing mushrooms was easy, and that no
experience was needed to "earn a substan tial income in this field." 25 The Commission
determined these claims were deceptive, and ordered respondents to stop asserting that " the usual
or customary earnings or profi ts ... is any amount in excess of the average amount actuall y
earned by use rs of sa id products ... under usual or normal co nditions.'" 26
Universal Credit: 27 The Commission found that respondents had deceptively represented that
"franchisees selling memberships in respondents· program can expect to receive profitable
earnings," when, in fact, most did not receive a return on their initial investment. 28 The
Commission ordered responde nts to stop representing that franchisees will or can expect to earn
"any stated or gross or net amount of earnings or profits," and barred them from ·'representing. in
any mam1er, the past earnings of franchisees unless in fact the past earnings represented are those
of a substantial number of franchi sees ... and accurately reflect the average earnings of said
franchi sees und er circumstances similar to those of the person to whom the representation is
made." 29
Universal Elcctric: 30 The Commission determined that respondents, sellers of vending machines
(containing TV tube testers) , had deceptively represented that " [p]ersons investing from $ 1,895
up to $3,695 can earn up to $400 per month" and that purchasers are '·assure[ d] exceptional and
profitable income.'' 3 1 The Commission ordered respondents to stop " [r] eprese nting. directly or
by implication, that: ... [p ]ersons investing in respondents· prod ucts. franchises or dealerships
will receive any stated amount of income or gross or net profits,'' and barred representations of
'·past earn ings of investors or purchasers" unless the amounts ''are those of a substantial num ber
22
Id. at 64.
23
Id. at 66.
24
Washington Mushroom Indus., Inc., 53 FTC 368, 370, 376, 379-380, 383-84, 386 ( 1956).
25
Id. at 3 70.
26 Id at 370. 379-80, 383-84, 386.
27
Universal Credit Acceptance Co p., 82 FTC 570, 59 1-600, 63 2-33 , 669-70 ( 1973).
28
Id. at 592-93, 595. 632-33.
29
Id. at 669-70.
30
Universal £lee. Corp. , 78 FTC 265 ~.f7 -69, 273-74, 294-95. 297 ( 197 1).
] I Jc/. at273-74, 297.
5
of purchasers and accurately reflect the average earnings of these purchasers under
circumstances similar to those of the purchaser to whom the representation is made."32
Waltham \Vatch: 33 Respondents sold franch ises for placing display cases of fake branded
watches in retail stores. 34 Their Jdvatising "clearly made two points: (a) that earnings of 25% to
100% could be made without interfering with the distributor·s regular work, and (b) that the
repurchase of inventory and bonus plan protected the investment in the event the distributor
wished to retire," but in fact, neither was true. 35 The Commission determined that this conduct
was deceptive and ordered respondents to stop falsely representing that purchasers' investments
are guaranteed, that " [a]ny percentage wi ll be earned on an in vestment in a franchise, '' and that
"[a]ny designated profit will be earned_'. 36
MacmiJlan, Inc.: 37 Respondent trade school published advertisements that "relied heavily on
endorsements by satisfied LaSalle graduates ... [which] created the impression that such success
was ordinary and typical," and that "graduates could expect to receive high wages or salaries." 38
The Commission determi ned that these representations were deceptive, as the testimonialists '
results were not typical, and ~Esclaimers that the students were "exceptional'· or the "most
successful'' did not dispel the misleading contrary impression. 39 The Commission ordered
respondents to stop misrepresenting " by any means the prospective earnings" of students, ·'or
that persons completing said courses will or may earn a specified amount of money. " 40 The
order required that any earnings claims be accompanied by a detai led breakdown of graduates'
actual earnings, and baned testimonials unless they "reflect[] the experience of the typical and
ordinary LaSalle student" or have a prominent di sc laimer. 41
Windsor Distributing Co.: 42 The Commission determined that respondents, who operated a
vending machine business, false ly claimed that previous purchasers had made substantial
earnings and deceptively represented that purchasing one vending machine ·'will produce a
minimum $35 gross profit during each month of operation'· and that one purchasing 50 machines
"could reasonably expect a return ... of $9,000 net per year" when in fact most purchasers made
" little or no profit..'4 3 The Commission ordered respondents to stop representing that purchasers
"will earn any stated or gross or net amo unt; or representing, in any manner, the past earnings of
said purchasers unless in fact the past earnings represented are those of a substantial number of
32
Id. at 294, 297.
n Waltham Watch, 60 FTC l692, 1704-05 , 1710-11, 17 16, 1724-25, 1727-28, 1730 ( 1962).
34
Id. at 1702-07.
35
Id. at 1710, I 730.
36
Id. at 1724-25, 1728, I 730.
37
Mac111illan, Inc., et al., 96 FTC 208, 232, 235-36, 245-46, 254-55, 301-02. 325-29, 331 ( 1980).
38
Id. at 232, 235-36, 245 -46, 254-55, 30 I.
39
Id. at 301-302.
40
Id. at 326, 33 I.
41
Id. at 326-329, 331 . The order inc' ·.1d eC: a:lditional related prohibition s.
42
Windsor Distrib. Co., 77 FTC 204, 214- 17, 22 I, 223 ( 1970).
43
Id. at214-217, 223.
6
purchasers and accurately refl ect the ave rage earnings of these purchase rs" under circumstances
similar to those of the person to whom the representation is made. 44
Abel Allan Goodman Trading As Weavers Guild: 45 Respondent and its salesmen claimed
that consumers who took respondent's reweaving course could reasonably expect to earn
"$25.00 per week fo r spare time work and fro m $5 0.00 to $200.00 per wee k. " 46 The
Co mmission found such claims deceptive because in practi ce the amoun t consumers could earn
was relative ly small. 47 The Commission ordered respondent to stop representing ''potential
earnings of persons completing respondent' s course and engaging in the reweaving business are
greater than they are in fact. "_48
T he Commi ssion also fo und that Respondent's adverti sing for sales positi ons was deceptive
because it touted earnings foil' the salesmen that we re "exceptional'' and not "typical of the
earnings which might reasonably be expected.''49 The Commi ssion ordered Responde nt to stop
representing that ''the typical earnings of persons se lling respondent's course of in structi on are
greater than they actually are; in fact. " 50
Ger-Ro-Mar, Inc.: 5 1 The Commission found that respondent, a multi-level marketing company.
misrepresented " to all potential participants that it was not difficult for participants in the . ..
program to ascend to hi gher levels of distributi on increas ing their earnings .. . , that every
participant had the reasonable expectancy of large profits or earnings, and that the [MLM]
program was commercially feas- ilJle for all recruits.'' 52 The Commission determined these
representations we re "false, m:,:;lead111g, and deceptive." 53 The Commi ssion ordered the
responde nts to stop misrepresenting, directl y or by impli cati on, "the financial gains reaso nably
achievable by participants:' and to stop representing the amount participants wi ll or can expect
to earn (including by ·'hypothetical examples or representations of past earni ngs of
participants"), unless a majority of participants have made such earnings and the time required to
do so is accurately disclosed.54
44
id. at 22 1,223.
45
Abel Allan Goodman Trading as Weavers Guild, 52 FTC 982, 988 ( 195 6), order affirm ed 244 F.2d 584 (2d Cir.
1957). •
46
Id. at 987.
47
Id. at 988.
48
Id. at 992. 996-97.
49
Id at 984, 99 1.
50
Id. at 992, 996-97.
51
Ger- Ro-Mar. Inc., 84 FTC 95, 11 3- 14, 135, 138, 149- 150, 160 ( 1974).
52
Id. at 134- 135, 149-1 50, 160.
5, Id.
54
i d. at 138.
B. Determinations (:oncerning Other Common Money-Making Opportunity

Claims
The notice of penalty offenses also includes determinations that the Commission has
made regarding several other types of deceptive representations that have been used by sellers or
marketers of money-making opportunities. These are:
• Misrepresenting that sa les of a money-making opportunity will be made to only a

limited number of prospective participants.55
• Mi srepresenting that prospective participants will be screened or evaluated for

suitability. 56 •
• Misrepresenting that participants do not need experience in order to earn

income.57
• Misrepresenting that a prospective participant must act immediately to purchase

or to be considered for a money-making opportunity.58
• Misrepresenting that purchas ing a money-mak ing opportunity is risk-free or

involves little ri~L 59
• Misrepresenting the position being offered to prospective participants, such as by

fai ling to di sclose that it is a sales position when such is the case. 60
• Misrepresenting the amount or type of training that will be given to participants. 61
II. Notice Concerning Endorsements and Testimonials
Companies use endorsements and testimonials in many forms to advertise and market
their products and services, both in traditional and social media, as well as in the form of online
reviews. As refl ected by the Commission · s enforceme nt actions and other efforts, some
compani es use these adve rtising too ls in a manner that deceives consumers.
55
Washington Mushro om, 53 FTC 368, 370-71 , 379-380, 386 ( 1956); Universal £lee. Corp., 78 FTC 265, 267-69,
274, 295-9 7 ( 197 1); Windsor Distrtb. Co., 77 FTC 204, 2 14- 17, 22 1, 223 ( 1970); Waltham Watch, 60 FTC 1692,
1704-05, 17 10-1 1, 1723, 1725, 1727-28, 1730 ( 1962).
56
Macmillan, 96 FTC 208, 272-73 , 320, 327,3 3 1 (1980); Universal Credit, 82 FTC 570, 608-09, 633 , 637,668,673
(l 973); Windsor Distrib. Co., 77 FTC 204, 2 13, 2 15, 217, 22 1, 223 ( 1970); Waltha111 Watch, 60 FTC 1692, 1704-05,
1710- 11 , 1725, 1727-28, 173 0 ( 1962)
57
Universal £lee. Corp., 78 FTC 26J, 267-69, 273-74, 295-96, 297 ( 197 1); Washington Mushroom, 53 fTC 368,
370-71, 378-80, 386 ( 1956).
58
Un iversal Credit. 82 FTC 570,6 10, 637-38, 668, 673 ( 1973).
59
Universal Credit, 82 FTC 570, 594, 6 11-1 2, 633, 637-38, 668, 673 ( 1973).
60
Encyclopaedia Britannica, Inc.. et al., 87 FTC 42 1, 486-88, 505, 5 10. 53 I ( 1976).
61
Id. at486-88 , 505, 5 10, 532 .
8
As set forth in more detail in the notice, the Commi ssion has determined that the
following acts and practices are deceptive or unfa ir, and unlawful under Secti on 5 of the FTC
Act : falsely claiming an endorsement by a third party; 62 mi srepresenting that an endorser is an
actual user, a current user, or a recent user: 63 continuing to use an end orsement vvithout good
reason to believe that the endorser continues to subscribe to the views presented: 6-1
misrepresenting that an endorsement represents the experience, views, or opi nions of users or
purported users; 65 using an endorsement to make decept ive performance claims; 66 fail ing to
disclose an unexpected material connection with an endorser;67 and misrepresenting that the
experience of endorsers represents consumers ' typical or ordinary experience. 68 Note that
positive consumer reviews are a type of endorsement, so such reviews can be unlawful , e.g ..
when they are fake or w hen a material connection is not adequately disclosed.
If you have any questions about this letter or the enclosed materials, pl ease contact
Andrew Hudson at (202) 326-2213 or [email protected] or Melissa Dickey at (202) 326-2662 or
[email protected].
Very truly yo urs,
Lois C. Greisman
Associate Director
Division of Marketing Practices
62
Mytinger & Cass elh en y, Inc., 57 F'T'C 7 17 ( 1960); Ar-Ex Cosms. , Inc., 48 FTC 800 ( 1952); A. P. W Pap er Co. ,
Inc., 38 FTC 1 ( 1944); Wither! W. H .ase ,:_,·u.. Inc.. 33 FTC 662 ( 1941 ).
6
' R. J. Reynolds Tobacco Co. , 46 FTC 706 (1950) ; Cliffdale Assocs., Inc., 103 FTC 110 ( 1984).
64
Nut 'I Dy namics Corp., 82 FTC 488 ( 1973), as modified at 85 FTC I 052 ( I 975).
65
R. .J. Reynolds Tobacco Co., 46 FTC 706 ( 1950).
66
Clijf dal e Assocs .. Inc., I 03 FTC 11 0 ( 1984); Macmillan, In c., 96 FTC 208 ( 1980); Porter & Diets ch, Inc., 90 FTC
770 ( 1977), a[('d, 605 F.2d 294 (7th Cir. 1979).
67
Cliffda le Assocs .. Inc., I 03 FTC I IO ( 1984).
68
Id. ; Porter & Dietsch, Inc., 90 FTC 770 ( 1977), a.f( d, 605 F.2d 294 (7th Cir. 1979); Nat 'I Dy namics Corp. , 82
FTC 488 ( 1973 ).
9
FEDERAL TRADE COMMISSION

NOTICE OF PENALTY OFFENSES
CONCERNING MONEY-MAKING OPPORTUNITrES
The Federal Trade Commission has determined that the following practices used in the
advertising or promotion of money-making opportunities are deceptive or unfair and are
unlawful under Section 5(a)(l) of the Federal Trade Commission Act.
1. It is an unfair or deceptive trade practice to make false, misleading or deceptive

representations conce1·ning the profits or earnings that may be anticipated by a participant
in a money-making opportunity (i.e., a person who has been accepted or hired for, has
purchased, or otherwise is engaging in the money- making opportunity). 1 For example:
a. It is an unfair or deceptive trade practice to misrepresent, explicitly or implicitly,

that participants will be or are likely to be profitable (i.e., to earn or receive more
income tlu·ough the use of the money-making opportunity than the amount of any
purchase price ,.1d c>..penses). 2
b. It is an unfair or deceptive trade practice to misrepresent, explicitly or implicitly,

that a substantial number of participants have made or can make the represented
profits or earnings. 3
c. It is an unfair or deceptive trade practice to represent, explicitly or implicitly, the

earnings whi ch may be secured by participants, when the representation is made
1
Macmillan, Inc. , el al. , 96 FTC 208,232, 301-02, 325-29, 331 (1980); Encyclopaedia
Britannica, Inc., et al., 87 FTC 421 , 450, 486-88, 505 , 510, 531-32 (1976); National Dynamics
Corp. , 82 FTC 488, 512- 13, 543-44, 568 (1973), as modified at 85 FTC 1052, 1059-61 (1975);
Ger-Ro-Mar, Inc. , 84 FTC 95, 113-14, 117-119, 123-125, 132-135, 138, 149-150, 160-162
(1974) , affirmed in relevant part at 518 F.2d 33 (2d Cir. 1975), as modified at 86 FTC 841
(1975); Holiday Magic, 84 FTC 748, 948, 984, 1032-1034, 1065, 1069 (1974), as modified at 85
FTC 90 (1975); Universal Credit Acceptance Corp., 82 FTC 570, 591-600, 633 , 668-70 (1973);
Universal Elec. Corp., 78 FTC 265, 271-74, 294,297 (1971); Windsor Distrib. Co., 77 FTC 204,
212-17, 220-23 (1970); Waltham WatchCo.,60FTC 1692, 1703-05, 1710, 1724-25, 1727-28,
1730 (1962); Abel Allan Good,,,an 71-ading As Weavers Guild, 52 FTC 982, 984, 987-88, 991-
92, 996-97 (1956), order affirmed 244 F.2d 584 (2d Cir. 1957); Washington Mushroom Indus.,
Inc., 53 FTC 368,370,376, 379-80, 383-84, 386 (1956); Vo n Schrader Mfg. Co., 33 FTC 58, 63-
66 (1941).
2
Encyclopaedia Britannica, 87 FTC 421 , 450, 486-87, 505, 510, 531-32 (l 976); Ger-Ro-Mar,
84FTC95 , 113-14, 117-119, 123-125, 132-135, 138, 149-150, 160-162(1974); Universal
Credit, 82 FTC 570, 592-93, _595, 632-33, 668-70 (1973); Universal Elec., 78 FTC 265, 271-74,
294-95, 297 (1971); Waltham Watch, 60 FTC 1692, 1703-05, 1710-11 , 1716, 1724-25, 1727-28,
1730 ( 1962).
3
National Dynamics, 82 FTC 488, 511-13, 543-44, 564,568 (1973), as modified at 85 FTC
1052, 1059-61 (1975).
without knowledge, or with only limited knowledge, of the actual profits or

earnings usually and ordinarily received by participants. 4
d. It is an unfair or deceptive trade practice to misrepresent, expli citly or implicitl y,

that participants wi ll or are likely to earn any specific amount or percentage. 5
e. It is an unfair or deceptive trade practice to misrepresent, explicitly or implicitly,

that the represented profits or earni ngs are the ordinary, typical, or average profits
or earnings m<\lde by participants.6 This includes by means of the representation
of an earnings'. figure or the attribution of earnings figures to specific participants,
both of which 1impliedly represent that such figures are likely, are earned by a
substantial number of participants, or are the typical , ordinary, or average results,
absent clear and conspicuous disclosure of the relevant context, such as the time
and effort actually expended by participants who made the amount represented,
the percentage of participants making the amount represented , and the amount
typically and cn·,·.ina~ily made by participants. 7
f. It is an unfair or deceptive trade practice to misrepresent the profits or earnings

that may be anticipated by a prospective participant by failing to disclose
conditions or limitations affecting such income, such as expenses to be borne by
the participant. 8
2. It is an unfair or deceptive trade practice to misrepresent, explicitly or implicitly, that

sales of a money-making opportuni ty will be made to only a limited number of
prospective participants (inc luding, for example, that sales will be made to only a limited
number of prospective participants in a geographic region), when sales will be made to
any person who is wil ling and able to pay. 9
4
Von Schrader Mfg. Co., 33 FTC 58, 63-66 (194 1).
5
Encyclopaedia Britannica, 7 FTC 421 , 450 , 486-87, 505 , 510, 531-32 (1976); National
Dynamics, 82 FTC 488 , 511-13 , 543 , 564, 568 (1973), as modified at 85 FTC 1052, 1059-61
(1975); Holiday Magic , 84 FTC 748, 948, 984, 1032-1034, 1065, 1069 (1974) ; Universal Credit,
82 FTC 570, 592, 594-95, 63~-·u , 668-70 (1973); Universal Elec. , 78 FTC 265 , 272-74, 294,
297 (1971) ; Windsor, 77 FTC 204, 2 14-17, 220-2 1, 223 (1970).
6
Macmillan , 96 FTC 208, 232, 235 -36, 245-46, 254-55 , 30 1-02, 325-29, 331 (1980); National
Dynamics, 82 FTC 488 , 511-13, 543-44, 564, 568 (1973) , as modified at 85 FTC 1052 , 1059
(1975); Abel Allan Goodman, 52 FTC 982, 984, 987-88, 99 1-92, 996-97 (1956) , order affirmed
244 F.2d 584 (2d Cir. 1957); Washington Mushroom , 53 FTC 368, 370, 376, 379-380, 383-84,
386 (1956); Von Schrader, 33 FTC 58, 63-66 (194 1).
7
Macmillan, 96 FTC 208,232, 301-02, 326-29, 33 1 (1980); National Dynamics, 82 FTC 488 ,
511-13 , 543-44, 563-64, 568 (1973), as modified at 85 FTC 1052, 1059-61 (1975).
8
Encyclopaedia Britannica, 87 FTC 421, 445-50, 486-87, 505 , 510, 531-32 ( 1976).
9
Universal Elec., 78 FTC 265, 273-74, 295-97 (1971) ; Windsor, 77 FTC 204, 213 , 215-17, 220-
21 , 223 (1970); Waltham Watch , 60 FTC 1692, 1704-05, 1710-11 , 1723 , 1725, 1727-28, 1730
(1962); Washington Mushroom, 53 FTC 368, 370-7 1, 379-380, 386 (1956).

prospective participaq.ts wi ll be screened or evaluated for suitability to use or benefit
from the money-mahng opportu ni ty. 10

participants do not need experience in order to earn income. 11
5. It is an unfair or deceptive trade practice to misrepresent, explicitly or implicitly, that a

prospective participarit must act immediately to purchase or to be considered for a
money-making opportunity. 12

purchasing a money-making opportunity is risk-free or involves little risk. 13
7. It is an unfair or decept: ve Hade practice to misrepresent, exp li citly or implicitly, the

position being offered to prospective participants in a money-making opportunity, such as
by failing to disclose that it is a sales position when such is the case. 14
8. It is an unfair or deceptive trade practice to misrepresent, explicitly or implicitly, the

amount or type of training that will be given to participants in a money-making
opportunity. 15
10
Macmillan , 96 FTC 208 , 272-73 , 320, 327, 331 (1980); Universal Credit , 82 FTC 570, 608-
09, 633 , 637, 668, 673 (1973 ); Windsor, 77 FTC 204, 2 13, 215, 2 17, 220-21 , 223 (1970);
Waltham Watch , 60FTC 1692, 1704-05, 1710-11 , 1725 , 1727-28, 1730(1962).
11
Universal Elec., 78 FTC 265, 272-74, 295 , 297 (1971) ; Washington Mushroom , 53 FTC 368,
370-71 , 378-80, 386 (1956).
12
Universal Credit , 82 FTC 570, 610, 632-33 , 637-38 , 668, 673 (1973).
13
Universal Credit , 82 FTC 570, 594, 611- 12, 633 , 638, 668, 673 (1973).
14
Encyclopaedia Britannica, 87 FTC 421 , 486-88, 505 , 510, 531 (1976).
15
Encyclopaedia Britannica, 87 FTC 421 , 486-88, 505, 509- 10, 531-32 (1976).
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Document 245 - Aaron Levy Telling Judge That Family First Life Is Criminal Organization

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Case 9:22-cv-80243-AMC Document 245 Entered on FLSD Docket 09/06/2024 Page 1 of 39

IN THE UNITED STATES DISTRICT COURT FOR THE SOU1H-ERN1- --.1

Important information has been known to me recently that should provide

On August 20 th Family First Life (FFL) was invited to request a hearing by

My office has had extensive conversations with Oklahoma Department of

Financial, PHP Agency , North American Senior Benefits, National Agents

Read Oklahoma's statute governing Business Opportunity Sales

A§ 823 . Vio/ations--Penalties--Criminal prosecutions describe the penalty

Exhibit 2 - See FFL FTC Cease and Desist here

https://casetext.com/ca~r 'bit ch-v-family-fi rst-life-lk-3

The following evidence that I am presenting should be very disturbing to the

https://www.courtlistener .C0;1·1/docket/63002125/fam ily-first-life-llc-v-rutstein/

Fort Pierce, Florida .

There is a definite similarit·1 in the name and probable ethnic background of

https://pitch book.com/profiles/ com pa ny/162831-61#ti meli ne or https://tinyu rl .com/integrity-size

• What is the size of Integrity Marketing Group?

My experience and knowledge of the insurance agent recruiting industry has

Thank you for your time.

DECLARATION OF Aaron Levy does declare as follows : 1. I am of

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF

V. Case No. 9:22-cv-80243-AMC

David Rutstein [email protected]. Defendant Pro Se I declare under

Aaron Levy aaron levywebsites@gma il.com Sept 2nd , 2024

Respondent. ODS File No. 24-02

1. That she is the Administrator of the Oklahoma Department of Securities

2. That a copy of the Enforcement Division Recommendation and Notice of

3. That the Administrator has received service of process on behalf of Respondent,

5. That this Affidavit of Compliance and Notice of Service on the Administrator is

FURTHER AFFIANT SAYETH NOT.

Dated this )./; ~~ay of August, 2024.

MELANIE HALL, ADMINISTRATOR OF THE

Subscribed and sworn to before me this~y of August, 2024.

OKLAHOMA DEPARTMENT OF SECURITIES

Family First Life, LLC,

Respondent. ODS File No. 24-020

NOTICE OF OI>PORTUNITY FOR HEARING

2. On the 0£l~ay of August, 2024, the attached E,?forcement Division

4. The request for a hearing on the Recommendation must be received by the

6. Upon receipt of a written request, pursuant to 660:2-9-2 of the Rules, a hearing

2. Section 806 of the Act provides:

3. Section 814 of the Act provides in pertinent part:

A. Whenever it appears to the Administrator that any person has engaged in

1. Issue an order directing each person to cease and desist from

1. The Agreement is a business opportunity.

WHEREFORE, it is recommended that the Administrator issue an order against

Dated this~ay of August, 2024.

Family First Life, LLC,

Respondent. ODS File No. 24-020

ENFORCEMENT DIVISION RECOMMENDATION

1. Respondent is a Connecticut limited liability company established in 2013, with a

2. An Oklahoma resident (Oklahoma Resident), a former esthetician, lost his job

7. Respondent provided a "marketing plan" as defined by § 802(6) of the Act.

1. Section 802 of the Act provides in pertinent part:

3 .a. "Business opportunity" means a contract or agreement, betv,1een a seller

6. "1\1arketi11g plan'' means advice or training, provided to the purchaser by the

a. Promotional literature, brochures, pamphlets or advertising

b. Training regarding the promotion, operation or management of

c. Operational, managerial, technical or financial guidelines or

Family First Life, LLC