To the Texas Attorney General Ken Paxton,

Complaint against:
Family First Life and Integrity Marketing Group
14800 Quorum drive, Suite 170
Addison, Texas 75034

My name is John Helem of Dallas, Texas and I am writing to share a concerning

experience that has deeply affected me and many others and to ask for help in my
legal battle with a life insurance MLM called Family First Life (FFL). FFL and other
subsidiaries that use the MLM model within the parent company Integrity
Marketing Company (IMG) have recruited over 100,000 Americans over the past
few years. A disproportionate percentage of those 100K are Texans. The FFL
scheme is completely dependent on non-compliance with Business Opportunity
Sales Law of Texas.
My up-line/recruiter with FFL told me that he made $6,000-$8,000 weekly. He
expressed through multiple personal statements and ads that there were no risks
associated with joining Family First Life. After I joined Family First Life I learned
this was not true.
Imagine signing up for what seemed like a golden opportunity with Family First
Life (FFL), a life insurance selling business that promised you $20,000 a month,
only to discover that this enticing offer was built on lies and non-compliance with
Texas Business Opportunity Sales Law. This was an emotional rollercoaster of
shattered dreams; it's a cautionary story about the importance of legal safeguards
and the real cost of deceit in the business world.
I was heavily influenced by multiple up-line leaders and persuasive videos from at
least 20 individuals within Family First Life (FFL), all encouraging me to forsake
other legitimate opportunities and dedicate myself solely to building my business
with FFL wasting months of my life. They repeatedly assured me of substantial
financial success, claiming I would earn $20,000 a month. However, these
promises were entirely fabricated, and the reality was that FFL was not compliant
with Texas Business Opportunity Sales Law, leading to significant personal and
financial harm.
FFL went as far as having me join a platform called Slack where I could see other
members boasting about what I would come to find out to be illegitimate policies
placed and monies made that day to aid in keeping me invested solely in FFL.
Even encouraged me to break the law by recruiting two people and one of the
two made sales furthering their scheme to harm others.
I invested $3,000 in leads from Family First Life (FFL) that they call “exclusive”
leads, only to find that they were essentially worthless and led nowhere. In
addition to spending $3,000 on fraudulent leads from Family First Life (FFL), I
incurred substantial out-of-pocket expenses, $4,000 on merchandise, work attire,
and commuting to and from the office. These investments, combined with the
lack of real income, pushed me into over $12,000 of debt.
Despite these significant investments, the promised returns by my recruiters
never materialized. The policies I managed to secure were overpriced and sold
primarily to supportive family and friends who wanted to help me in my new
business. Despite my efforts and the significant financial outlay, the leads were
dead ends, highlighting the deceptive nature of FFL’s promises and practices.
When I discovered that Family First Life (FFL) was built on lies and false promises,
I wanted to leave immediately. Contrary to their assurance of, "you can come and
go as you please; you are building your business," (I heard this exact phrase from
multiple up-line) FFL refused to release me, leaving me trapped in their system.
To make matters worse, my direct up-line, while profiting off my efforts,
sabotaged me by manipulating the commissions I was able to earn, all while still
benefiting from the policies I was writing to supportive friends and family. Despite
their promises of autonomy, I found myself stuck unable to break free without
sacrificing my career and or keeping me stuck in a financial rut couch surfing not
being able to make ends meet.
My experience and many others with Family First Life (FFL) has been an emotional
roller coaster that severely impacted my finances and life for months. The initial
excitement and hope of earning $20,000 a month quickly turned into frustration
and despair as I realized the leads I had purchased for $3,000 were fraudulent. My
financial situation deteriorated further due to out-of-pocket expenses for
merchandise, work attire, and commuting, pushing me into more debt than
before this “opportunity”.
The most disheartening was the betrayal by my direct up-line, who sabotaged my
earnings while profiting from my efforts and lying to me about potential income
while withholding an income disclosure statement showing what the actual
average income of recruits was, in percentiles. Otherwise, I could have made an
educated decision on this “opportunity” and not been manipulated by false
promises and lies.
When I uncovered the truth and tried to leave, FFL's refusal to release me left me
feeling trapped, powerless and added insult to injury. Their non-compliance with
Texas Business Opportunity Sales Law exacerbated the situation, highlighting their
deceptive practices.

Why are you letting these people get away with this, why is this happening? Do
me a favor, stop this criminality by the Attorney General’s office referring me, in
writing, to civilly sue with a list of appropriate attorneys (specializing in franchise
law). This referral to sue, I know has happened in other states and is a tool that
the AG’s can use to cause corporate bad actor’s to stop their criminal behavior as
criminal prosecutions can be years into the future.
This fraud of FFL and IMG has not only drained my finances but also taken a
significant emotional toll, underscoring the devastating effects of dishonest
business practices many Texans have experienced from non-compliance with the
Business Opportunity Sales Law of Texas.
In light of the above, I respectfully request help from the Texas Attorney General's
Office in obtaining an attorney.
This Reddit forum thread has a synopsis of FFL’s lawsuits
https://www.reddit.com/r/antiMLM/comments/15wfzb8/family_first_life_lawsui
ts_thread_portal/
This class action lawsuit article - https://behindmlm.com/companies/family-
first-life-class-action-alleges-selling-of-dud-leads/ and the case
https://www.scribd.com/document/702794468/Family-First-Life-Class-
Action-Lawsuit-Lead-Fraud-Shawn-Meaike-first-filing
Describes the specific Texas law that FFL is breaking regarding lead fraud and
holding agents captive after being told FFL’s fake promises
This citing of Texas law is from the Class Action case against Family First Life that I
found on the reddit FFL lawsuits thread.
COUNT 4
VIOLATION OF TEXAS BUSINESS & COMMERCE CODE § 17.46
(By Birch and all Texas Class members against Defendants)
67. According to Texas Bus. & Com. Code § 17.46, “false, misleading, or deceptive
acts or practices in the conduct of any trade or commerce are hereby declared
unlawful ..." The term "false, misleading, or deceptive acts or practices" includes,
but is not limited to the following: "representing that goods or services have.
characteristics ... which they do not have . . ."; "representing that goods are
original or new if they are ... reconditioned, reclaimed, used, or secondhand";
"representing that goods or services are of a particular standard, quality, or
grade ... if they are of another;"
and "failing to disclose information concerning goods or services which was
known at the time of the transaction if such failure to disclose such information
was intended to induce the consumer into a transaction into which the consumer
would not have entered had the information been disclosed."
68. Defendant committed false, misleading and deceptive acts by misrepresenting
the quality of the leads to its agents in order to obtain a premium price.
Furthermore, Defendant violated Section 17.46 by falsely representing to
prospective Agents that FFL does not require contracts and does not restrict its
Agents from moving to one IMO to another when, in reality, it does such
behavior.
69. As a result of Defendants action, Texas Class members have been injured. If
Defendant’s conduct is allowed to continue without a permanent injunction,
additional Texans will continue to be harmed.
Count 5 Breach of Oral Contract
71. Plaintiffs entered into an oral agreement with FFL related to the purchase of
leads. According to the terms of the oral agreement, FFL promised to provide
leads that were described as “exclusive,” “fresh,” etc. In exchange, Plaintiff agreed
to pay a premium price for the leads.
73. FFL breached the agreement by providing Plaintiffs with leads that were
recycled and used many times over. In fact, the leads were not leads at all
because …..
PRAYER FOR RELIEF
b. That all maximum penalties be assessed against FFL in accordance with Texas
Bus. & Com. Code §17.46. d. That Texas victims be entitled to recovery of
attorney fees and costs pursuant to Texas Bus. & Com. § 17.46(d).
Now I will be cite the evidence of FFL’s non-compliance with the Business
Opportunity Sales Law of Texas.

1. Below is the FTC cease and desist to FFL in Dec, 2021

https://www.ftc.gov/system/files/warning-letters/cease_and_desist_letter_to_family_first_life_ll
c-_12.27.2021.pdf - The FTC starts their warning to FFL “We have determined that Family First
life is unlawfully misrepresenting that consumers who become Family First Life business
opportunity participants are likely to earn substantial income.” This language of “business
opportunity participants” is repeated multiple times in the FTC letter to FFL. Obviously, the FTC
has determined that FFL should comply with the Business Opportunity Sales Law of Texas.
2. Christopher Coyle who has sued FFL for harming him by way of violating Business Opportunity
Sales Law of Oklahoma published https://www.gofundme.com/f/qv63hy-court-fees writes “In
their motion to dismiss in Suescum vs Family First Life,
their (FFL) legal counsel tried to dismiss claims of the
TCPA and FTCA violations by stating that text messages
used in recruiting for a business opportunity did not
violate those statutes.” In 6:21-cv-01769-WWB-EJK Suescum v. Family
 First Life, LLC Document 11, FFL attorney is requesting that the court dismiss this “Do
Not Call”, TCPA lawsuit based on FFL not trying to sell something, but they are
contacting insurance agents as part of their “business opportunity” campaign.

Here are some quotes from Document 11, which is FFL’s attempt to dismiss the
lawsuit.
Here is the copy of the filing
https://www.scribd.com/document/739969813/Family-First-Life-Business-
Opportunity-Admission-Proof-Document-11-Suescum-vs-FFL
a. “A communication to a state-licensed insurance agent related to a business
opportunity or affiliation with insurance carriers is not property (real or
personal). For those reasons as well as others explained below, Plaintiff has
not and cannot state a claim under the Florida Telephone Solicitations Act.”
b. “Specifically, courts have held that communications offering employment or
business opportunities, rather than offering goods or services that
consumers would pay money for, do not constitute telemarketing.”
c. “(concluding that calls offering the plaintiff a “business opportunity
promoting the commercial availability of insurance, goods, intangibles and
services” were not advertising or telemarketing because the messages did
not explicitly ……”
d. “The Friedman and Dolemba decisions are of specific import to this analysis
because the messages at issue in both cases relate to business
opportunities in the insurance industry – ….”
e. And more….
3 On the YouTube Playlist there are examples of recruiter telling the job
applicant “The average FFL agent earns 20K per month and you would
invest $1,000 a week in leads to achieve that”
Here are the videos from the playlist
a. https://youtu.be/48UBICixhnc?si=UP7820V1xks6HVWM
b. https://youtu.be/zfloBxU0nk8?si=zkG217zYl6XUxc7I
c. https://youtu.be/EehWlzKCGP8?si=C1-pGJfmEbxBh9bb
d. https://youtu.be/-iwYVKclk6A?si=5DMqoKl9_yhNQ1oa
e. https://youtu.be/HkVJK8mzPUQ?si=b1HioVbFrzM6idHX
f. And now sister companies of FFL, subsidiaries of IMG making these
wild promises
 g. The Alliance - https://youtu.be/4VM_Jh8WZh4?
si=9P_d9MBMS3_bzyhG
h. North American Senior Benefits https://youtu.be/3i6Xr7AiOqU?
si=Doh7ix71f4_nd-dG
i. PHP Agency https://youtu.be/Ci-ZQHjsaUo?si=pU9gC0nOPvBcMHBi
j. Equis Financial - https://youtu.be/LJZ5uJKiP7k?
si=F0Ldd6NhgRoZqhXE - this is with an agent who describes his
experience

4.Videos that are posted on FFL or FFL websites that I found in

the last week.
20 year old depositing over $20,000 a month with FFL
https://www.youtube.com/watch?v=FMB6FknAip0
19 year old goes from living in a van to depositing over $25,000 per month
https://www.youtube.com/watch?v=8oKxhjlYD_E
I now realize that Family First Life should have registered and complied with the
Texas Business Opportunity Sales Act.
https://www.findlaw.com/smallbusiness/starting-a-business/state-guide-
business-opportunity-disclosure-laws.html – I could not find the TX Business
Opportunity Sales Act (Oklahoma and Texas laws are supposedly identical, and
inspired by an FTC recommended law from 13 years ago.) I am sure you can find
the exact text of the Texas law, but I see information on Reddit that describes a
lawsuit citing the Oklahoma law.

Texas has a site, linked below, you can search for companies that file for
registration and exemption under the Business Opportunity Sales Act and
Family First Life is not registered or exempt. FFL is not registered, even
though they should be.

https://direct.sos.state.tx.us/businessopportunity/BusOpSearch.asp

And link to the Oklahoma criminal and civil actual law

here. https://www.securities.ok.gov/Act-Rules/Busopp.asp
 I believe that this is the Texas Law
https://statutes.capitol.texas.gov/Docs/BC/htm/BC.51.htm
Business Opportunity Act, Chapter 51

The offering or sale of business opportunities in Texas is governed by

the Business Opportunity Act, Chapter 51, Texas Business &
Commerce Code, and the secretary of state’s administrative rules, title 1,
Chapter 97 of the Texas Administrative Code.

Here is me asking Bing AI If Texas requires registration for a business

opportunity

Certainly! In Texas, the sale or lease of business opportunities is governed by

the Business Opportunity Act, which falls under Chapter 51 of the Texas Business &
Commerce Code. Here are some key points:
1. Definition of Business Opportunity:
o A business opportunity refers to the sale or lease of products, equipment,
supplies, or services for an initial consideration of more than $500.
o The seller represents that these items will be used by or for the purchaser
to start a business.
o The seller may provide marketing programs, advice, or training related to
the business opportunity1.
2. General Definitions:
o Business opportunity contract: An agreement obligating a purchaser to a
seller.
o Buy-back or secured investment: A representation implying payment
protection for the purchaser.
o Marketing program: Advice or training related to selling products,
equipment, supplies, or services.
o Purchaser: The person obligated under a business opportunity contract.
o Seller: The principal or agent selling or offering to sell a business
opportunity1.
3. Registration Requirement:
o Before selling or offering a business opportunity, the principal seller must
register it with the Office of the Secretary of State.
o Registration includes filing a disclosure statement (except as provided by
Section 51.053)2.

Link to the FTC recommended law here that was implemented by 23 states
10 years ago. Other states go by the FTC franchise law, which is virtually the
same thing, minus the need to register. https://www.ecfr.gov/current/title-
16/chapter-I/subchapter-D/part-437

Here is the Reddit Thread that describes lots of FFL legal issues
https://www.reddit.com/r/antiMLM/comments/15wfzb8/family_first_life_lawsui
ts_thread_portal/

Here are the court documents of the ongoing Christopher Coyle’s counter lawsuit
against FFL in Oklahoma -
https://www.oscn.net/applications/oscn/GetCaseInformation.asp?
submitted=true&viewtype=caseGeneral&casemasterID=3597373&db=Tulsa

https://www.scribd.com/document/670813958/Family-First-Life-Counter-
Lawsuit-Claiming-Business-Opportunity-Fraud- is the direct link to the critical
filing that describes the Business Opportunity Sales Law, which supposedly TX has
the identical law.

Here is Christopher Coyle’s (Mr. Coyle sued FFL for violation of Business
Opportunity Sales Law of OK) GoFundMe Plea.
https://www.gofundme.com/f/qv63hy-court-fees/- My case and over ten
thousand Texans have similar stories (there is a YouTube video in which the FFL
CEO states he has 60,000 agents, and the parent company, which is Integrity
Marketing Group (IMG) owns several other similar companies doing a similar
fraud – PHP Agency, The Alliance, Equis Financial, North American Senior Benefits
and others.)
FFL did get an FTC cease and desist ordering them to stop lying to new business
opportunity participants in December 2021.
https://www.ftc.gov/system/files/warning-letters/cease_and_desist_letter_to_fa
mily_first_life_llc-_12.27.2021.pdf - Unfortunately for me, I was not aware of this
public letter when I was being scammed by FFL.

FFL is now up to its 7th Do Not Call lawsuit as described on the

https://www.behindmlm.com articles that is documented at the head of the
Reddit thread that I mentioned a few paragraphs above.

https://behindmlm.com/companies/family-first-life/fifth-family-first-life-robocall-
fraud-lawsuit-filed-in-ct/and a court filing
https://www.scribd.com/document/702799114/Family-First-Life-Lawsuit-Do-Not-
Call-Lawsuit-for-694-000
https://behindmlm.com/companies/fourth-family-first-life-robocall-fraud-lawsuit-
filed-in-indiana/
https://behindmlm.com/companies/second-family-first-life-robocall-fraud-
lawsuit-filed-in-michigan/ and a court filing
- https://www.scribd.com/document/702799114/Family-First-Life-Lawsuit-Do-
Not-Call-Lawsuit-for-694-000
These are recruiting videos FFL use where they state that they are not a captive
agency and that you can come and go as you please which is false
misrepresentation and deceiving the public. My up-line sent me this video before
I signed up and I have text message proof.
https://www.youtube.com/watch?v=UVgksTmlAXY – this is the welcome video
that all agents receive when they indicate an interest in joining FFL
https://www.youtube.com/watch?v=LslC_kRTyFE – This video that was sent to
me personally by my recruiter and I saved on my channel so that I will have proof
of FFL’s criminality.
A decent explanation of the power of State RICO laws – FFL and IMG are using
multiple entities that “attack” the victims from multiple directions, therefor FFL
and IMG are violating the Texas RICO statute.
https://bjs.ojp.gov/content/pub/pdf/lpocusricos.pdf
https://www.troutman.com/a/web/338679/82Hje7/rico_report_s02e03_state_ri
co_statutes_transcript.pdf

If you go to the Reddit thread listed on page one, you will see direct links to a few
more of their lawsuits.

There is a YouTube playlist of over 100 videos that interviews victims of FFL and
also has “job interviews” with FFL recruiters who you can hear are “promising the
moon.” Telling the potential recruit exactly what I was told. Invest money in leads,
10 times your money, average income is 20K per month, “it is easy and anyone
can do it”, etc. These videos give over different aspect of the fraud, which involve
“elder abuse”, “churning”, “do not call violations”, “business opportunity law
fraud”, “general fraud selling fake leads to new agents like me”, “targeting
protected classes / minorities / immigrants for fraud”, “RICO violations”

On Family First Life Lawsuit Playlist of over 100 videos describing the FFL scam
https://www.youtube.com/playlist?list=PLJVKYiW2lCj5oHUZkuMJJEIQAZzhWQisX

Here is Steve Young, Chairman of Integrity Marketing Group and NFL Hall of
Famer touting FFL
https://www.facebook.com/watch/?v=486544389005266

Here is my brief video describing what happened to me.

https://youtu.be/Rs7WvC2klFg?si=8dyc8DEXA3e34Z3N
Here is another Texas agent that has a similar story as me.
https://m.youtube.com/watch?feature=shared&v=NtnOA260UUQ

Another victim from Texas

https://youtu.be/PlCmyka1yuQ?si=q7c787nN3ONLbHHO
Another victim from Texas
https://youtu.be/DJCpkNDbIDo?si=GiU7M2q-aJoy8ftF
Another victim from Texas
https://www.youtube.com/live/DDuZEjMYXRE?si=XG47WLomrCVbOMsN
Another victim from Texas
https://www.youtube.com/live/6tifH_C6mP8?si=tMeKMNmHXLp88Y2O
Another victim from Texas
https://youtu.be/BKC7WoGOyIs?si=QGKx7FyqeBoIXZmM

Another victim from Texas

https://youtu.be/sItgpZ41yaA?si=qduXRwePO3qbxcFO
Another victim from Texas
https://youtu.be/--ZlH336VWU?si=CjlSe0q8VfvTsRXi
Here is a recent unedited conversation with a FFL recruited “promising the moon”
https://youtu.be/HkVJK8mzPUQ?si=jQlNAJByGtz3uApZ
Here is a recent unedited conversation with a FFL recruited “promising the moon”
https://youtu.be/48UBICixhnc?si=RXvaSAO1fL2j0Gd

Here is a recent video of a conversation with the FFL lead system promising
exclusive leads for $11, which is not true. https://youtu.be/zOXb6uFG_yQ?
si=kqJMuKnDYEbJkLKI

I describe in my video about me speaking out about sexual harassment in the FFL
office. As you can see in my video testimonial, I appear as somewhat of a “tough”
guy who is not afraid to speak up. The vast majority of FFL recruits/victims are in
much younger than me. I am 32 years old.
FFL kicked me out the office after I signed all their contracts, which unbeknownst
to me, locked me in to their selling systems. I feel that FFL was afraid that I would
speak my mind and influence FFL’s other recruits in the office about the FFL
frauds and non-compliance with Texas law. FFL office manager their told me that I
was causing a disruption in the office and that I can’t come in the office anymore
and that I can work from home.
It recently discovered that my FFL/IMG highest upline, whose name is Marc
Meade has caused IMG to be sued for sexual harassment. Here is a link to the
BehindMLM article
https://behindmlm.com/companies/family-first-life/former-employee-sues-
family-first-life-for-sexual-harassment - FFL / Integrity Marketing Group
partner is being law suited for sexual harassment. Link to lawsuit
- https://www.scribd.com/document/739612965/Integrity-Marketing-
Group-Family-First-Life-Marc-Meade-Sexual-Harrassment-Lawsuit
New news, after posting my testimonial video on my YouTube channel
https://www.youtube.com/watch?v=LslC_kRTyFE which was 13 minutes and 21
seconds. Subsequently The GusFox.com YouTube channel edited my video to be
11 minutes and 8 seconds. The video flows faster and is easier to watch. And that
“improved” video is on playlist which includes 114 videos of FFL victims.
https://www.youtube.com/watch?
v=Rs7WvC2klFg&list=PLJVKYiW2lCj5oHUZkuMJJEIQAZzhWQisX&index=2
Now I received a cease and desist letter from FFL attorney Thomas Sisco who
threatens lawsuit for defamation and conspiracy for speaking out on YouTube and
supposed involvement with a man named David who I have no idea who he is.

Attorney Sisco is wanting me to not complain to “state and federal regulators”

and threatening contempt of court. My statement to YouTube and your Attorney
General’s office is true, not defamatory.
The defamation laws of the USA are based on New York Times Co. v.
Sullivan, 376 U.S. 254 (1964) which defines defamation as
being malicious, lying and know your lying.
This lawsuit threat by FFL attorney Sisco, I am fairly certain
is part of FFL’s pattern of intimidating victims and I believe
that Mr. Sisco has sent out more than 1,000 of these threats
through the years.

To give you an idea of the technique of MLMs and the psychology of their scam
works, this is a brilliant 29 minute video by James Jani:
https://youtu.be/He1bgJ0sqtw?si=KjG1-WliJmobkZUm .

I suppose the ease of which victims can be victims caused the FTC to recommend
to Texas and other states to enact the Business Opportunity Sales Law. The big
issue now is that the Attorney Generals are not prosecuting and for the most part,
MLM victims are penniless, completely broke. MLM victims, generally, do not
have the financial means to access the court system.
To cut to the chase, FFL and IMG are the owner/operators of
the largest and most profitable MLM scam in America today.
FFL is obviously in non-compliance with the Business
Opportunity Act of Texas and it is in the citizens of Texas best
interest if the Attorney General office give me a written
referral to civilly lawsuit Family First Life. This action by the
AG will certainly be a huge step in causing there to be less
victims in the state of Texas.

Up-lines who influenced me:

Marc Meade, Freddie Damper, Mark Washum, Rob Richman, Ashley Savoie, Jesse
Parley, Bridget (FFL Corporate), Shawn Meaike, Steve Young
Thank You,

John Helem