The Original Complaint
The plaintiffs alleged in the 29-page original complaint that they had been victimized by a "classic pyramid scheme." The first paragraph of the "Introduction to the Case" section of the original complaint reads:
The Defendants are operating a classic pyramid scheme. What makes this scam particularly egregious is that the Defendants have never marketed or sold insurance policies to any retail customers, but instead derive 100% of the scheme's revenue from chain recruitment. These practices have been prohibited by the Federal Trade Commission, and violate State and Federal Laws. Plaintiffs and tens of thousands have joined PFA and have become "Associates." Plaintiffs did not make money as promised. The Associates failed because they were doomed from the start by a PFA marketing plan that systematically rewards recruiting Associates over the sale of overpriced insurance product or service to retail customers.
The original complaint does not describe the targets of the pyramid scheme. Other case documents, however, indicate that the program was aimed at Chinese, Vietnamese, and other immigrants who may have limited fluency in the English language.
Subsequent to the filing of the original complaint, there have been amended complaints, answers to the complaints, and unsuccessful motions to dismiss. On May 14, 2021, the plaintiffs filed a motion for class certification.