IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

HEATHER LEE MINOR, individually and 

on behalf of all others similarly situated,

Plaintiff,

v.

INSURANCE LINE ONE LLC, a Florida

limited liability company,

Defendant.

Case No.

CLASS ACTION 

DEMAND FOR JURY TRIAL

CLASS ACTION COMPLAINT AND DEMAND FOR JURY TRIAL

Plaintiff Heather Lee Minor (“Plaintiff” or “Minor”) brings this Class Action Complaint 

and Demand for Jury Trial against Defendant Insurance Line One LLC, (“Defendant” or 

“Insurance Line One”) to stop the Defendant from violating the Telephone Consumer Protection 

Act (“TCPA”) and the Florida Telephone Solicitation Act (“FTSA”) by sending telemarketing text 

messages without consent to consumers who registered their phone numbers on the National Do 

Not Call registry (“DNC”). Plaintiff also seeks injunctive and monetary relief for all persons 

injured by Defendant’s conduct. Plaintiff, for this Complaint, alleges as follows upon personal 

knowledge as to herself and her own acts and experiences, and, as to all other matters, upon 

information and belief, including investigation conducted by her attorneys. 

PARTIES

1. Plaintiff Heather Lee Minor is a resident of Tallahassee, Florida. 

2. Defendant Insurance Line One LLC is a Florida limited liability company with its 

principal place of business in Margate, Florida. Defendant Insurance Line One conducts business 

throughout this District, Florida, and the U.S.

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JURISDICTION AND VENUE

3. This Court has federal question subject matter jurisdiction over this action under 28 

U.S.C. § 1331, as the action arises under the Telephone Consumer Protection Act, 47 U.S.C. §227 

(“TCPA”). The Court has supplemental jurisdiction over the Florida Telephone Solicitation Act 

by (“FTSA”) claims, as they arise out of the same telemarketing campaign as the TCPA claim.

4. This Court has personal jurisdiction over the Defendant and the venue is proper 

under 28 U.S.C. § 1391(b) because the Defendant resides in this District. 

INTRODUCTION

5. As the Supreme Court recently explained, “Americans passionately disagree about 

many things. But they are largely united in their disdain for robocalls. The Federal Government 

receives a staggering number of complaints about robocalls—3.7 million complaints in 2019 

alone. The States likewise field a constant barrage of complaints. For nearly 30 years, the people’s 

representatives in Congress have been fighting back.” Barr v. Am. Ass'n of Political Consultants, 

No. 19-631, 2020 U.S. LEXIS 3544, at *5 (U.S. July 6, 2020).

6. The National Do Not Call Registry allows consumers to register their telephone 

numbers and thereby indicate their desire not to receive telephone solicitations at those numbers. 

See 47 C.F.R. § 64.1200(c)(2). 

7. A listing on the Registry “must be honored indefinitely, or until the registration is 

cancelled by the consumer or the telephone number is removed by the database administrator.” Id.

8. Industry data shows that the number of robocalls made each month increased from 

831 million in September 2015 to 4.7 billion in December 2018—a 466% increase in three years.

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9. According to online robocall tracking service “YouMail,” 3.8 billion robocalls were 

placed in July 2022 alone, at a rate of 123.1 million calls per day. www.robocallindex.com (last 

visited August 25, 2022).

10. The FCC also has received an increasing number of complaints about unwanted 

calls, with 150,000 complaints in 2016, 185,000 complaints in 2017, and 232,000 complaints in 

2018. FCC, Consumer Complaint Data Center, www.fcc.gov/consumer-help-center-data. 

11. “Robocalls and telemarketing calls are currently the number one source of 

consumer complaints at the FCC.” Tom Wheeler, Cutting off Robocalls (July 22, 2016), statement 

of FCC chairman.1

12. “The FTC receives more complains about unwanted calls than all other complaints 

combined.” Staff of the Federal Trade Commission’s Bureau of Consumer Protection, In re Rules 

and Regulations Implementing the Telephone Consumer Protection Act of 1991, Notice of 

Proposed Rulemaking, CG Docket No. 02-278, at 2 (2016).2

COMMON ALLEGATIONS

13. Defendant Insurance Line One LLC is a national insurance agency and provides 

insurance options from various carriers to consumers throughout the U.S.3

14. Defendant Insurance Line One gathers personal information from the consumers to 

offer insurance quotes to the consumers.

15. Defendant uses automated systems to send outbound telephonic sales calls, 

including solicitation text messages, to hundreds if not thousands of consumers across the U.S., 

1 https://www.fcc.gov/news-events/blog/2016/07/22/cutting-robocalls 2 https://www.ftc.gov/system/files/documents/advocacy_documents/comment-staff-ftc-bureau-consumer-protectionfederal-communications-commission-rules-regulations/160616robocallscomment.pdf 3 https://www.insurancelineone.com/about-us/insurance-companies/

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including to consumers whose phone numbers are registered on the National Do Not Call list, 

seeking information to solicit insurance quotes to consumers.

16. Defendant uses autodialing tools, like Convoso’s Power Dialer, to automate the 

process of sending solicitation text messages and cold calls to consumers en masse. 

17. In 2020, Convoso published a success story on how Defendant Insurance Line One 

increased their telemarketing capacity by using Convoso’s power dialer. 4 This report highlights 

several aspects of Defendant’s use of automated dialers for conducting telemarketing campaigns, 

for instance:

• The report summary shows that Defendant operates call centers using automated 

dialing software placing hundreds of calls each day, including spam calls which the 

Defendant had knowledge of:

• Since before the publication of this report in 2020, Defendant Insurance Line One has 

been placing a lot of spam or unwanted calls to consumers, and that Defendant has been 

categorically aware of their calls being reported as spam by multiple consumers each 

day.

4 https://3zx1kt3r5oppyef2847a39ns-wpengine.netdna-ssl.com/wp-content/uploads/2021/01/NEW_Insurance-LineOne_Customer-Success-Story.pdf

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• Marlon Johnson, Defendant Insurance Line One’s Marketing Director acknowledges

using Convoso’s Power Dialer to automate their telemarketing operations. Defendant 

uses the Power Dialer to automate placing outbound calls, emails and text messages to 

lists of potential consumers, automatically as soon as their leads are added to the 

software, and then to send telemarketing calls, texts and/or emails to those consumers 

on a recurring basis to follow up with those who haven’t responded to the solicitations. 

• Defendant has been growing their telemarketing operations since 2019, and the amount 

of telemarketing spam they send out has also increased proportionally, if not more.

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• Mike Kelly, Defendant Insurance Line One’s Sales Manager acknowledges using 

Convoso’s Power Dialer to automate Defendant’s telemarketing operations.

18. Multiple consumers have posted complaints online about receiving unwanted 

solicitation calls from Defendant Insurance Line One, for instance:

• 5

5 https://www.bbb.org/us/fl/margate/profile/insurance-companies/insurance-line-one-llc-0633-90043296/customerreviews

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• 6

• 7

• 8

6 https://directory.youmail.com/phone?phoneNumber=8006061671 7 https://www.google.com/search?q=insurance+line+one#lrd=0x88d904bb9a11e9f7:0x4d517cb512b95085,1

8 Id.

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• 9

• 10

• 11

9 Id.

10 Id. 11 Id.

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• 12

• 13

• 14

12 Id. 13 Id. 14 https://www.shouldianswer.com/phone-number/8006061671

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19. In response to these calls, Plaintiff Minor brings forward this case seeking 

injunctive relief requiring the Defendant to cease from violating the Telephone Consumer 

Protection Act and the Florida Telephone Solicitation Act, as well as an award of statutory 

damages to the members of the Classes and costs.

PLAINTIFF MINOR’S ALLEGATIONS

20. Plaintiff Minor is the subscriber and the sole user of the cell phone number ending 

with xxx-xxx-0419.

21. Plaintiff Minor registered her cell phone number on the National Do Not Call 

Registry on March 4, 2022.

22. In May 2022, Plaintiff Minor started receiving unsolicited telemarketing

solicitation text messages to her cell phone from Defendant Insurance Line One using the phone 

number 954-833-0234 seeking information to offer health insurance quotesto her, using automated 

systems to send recurring text messages, using multiple scripts to pick from.

23. Plaintiff received unsolicited telemarketing text messages from Defendant 

Insurance Line One’s employee Lauren, addressed to someone named Melvin Johnson, on:

• Sunday, May 22, 2022, at 2:25, 

• May 23, 2022, at 2:40 PM, and again on

• Sunday May 29, 2022, at 3:40 PM.

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24. Plaintiff Minor did not request health insurance quotes or information from the 

Defendant, and never consented to receiving telemarketing text messages from or on behalf of the 

Defendant.

25. On calling the phone number, 954-833-0234, from which the Defendant sent the 

solicitation text messages to the Plaintiff’s cell phone, it is answered by an automated voice 

message which states, “Your call is important to us. Please wait and we’ll connect you to the next 

available agent.” The call is put on hold for some time and it eventually disconnects without any 

answer.

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26. On texting the phone number, 954-833-0234, using keywords like, HELP and 

CALL, instant predefined responses are received, showing that this phone number has been setup 

to use as an automated texting phone number by Defendant.

27. Defendant, and/or the telephone solicitor who sent the telemarketing text messages 

to Plaintiff Minor’s cell phone failed to identify the company name in two of the text messages, 

and she also failed to identify her full name in all the text messages.

28. Defendant provided a callback number, 833-258-6257, in two of the telemarketing 

text messages sent to the Plaintiff. On calling this phone number, it is answered by the same 

automated voice message as the previous phone number.

29. The unauthorized telephonic sales calls that Plaintiff received from Defendant, as 

alleged herein, have harmed the Plaintiff in the form of annoyance, nuisance, and invasion of 

privacy, and disturbed the use and enjoyment of her phone, in addition to the wear and tear on the 

phone’s hardware (including the phone’s battery) and the consumption of memory on the phone.

30. Seeking redress for these injuries, Plaintiff Minor, on behalf of herself and Classes

of similarly situated individuals, brings suit under the Telephone Consumer Protection Act, 47 

U.S.C. § 227, et seq. and the Florida Telephone Solicitation Act, Fla. Stat. 501.059, which prohibit 

sending unsolicited telemarketing calls and text messages to cell phone numbers that are registered 

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on the DNC, and without identifying the full name of the telephone solicitor and the name of the 

company on whose behalf the solicitation was sent.

CLASS ALLEGATIONS

31. Plaintiff Minor brings this action pursuant to Federal Rules of Civil Procedure 

23(b)(2) and 23(b)(3) and seeks certification of the following Classes:

Do Not Call Registry Class: All persons in the United States who from four years prior to 

the filing of this action through class certification (1) Defendant Insurance Line One or an 

agent acting on Defendant’s behalf, texted more than one time, (2) within any 12-month 

period, (3) where the person’s phone number had been listed on the National Do Not Call 

Registry for at least thirty days (4) for the same purpose Defendant texted the Plaintiff.

Autodial Class: All persons in the United States, who, on or after July 1, 2021, (1) received 

a telephonic sales call regarding Defendant’s goods and/or services, (2) to and/or from 

Florida, (3) using the same equipment or type of equipment utilized to call Plaintiff.

Unidentified Telephone Solicitor Class: All persons in the United States, who, on or after 

July 1, 2021, (1) received an unsolicited telephonic sales call from or on behalf of the 

Defendant, (2) to and/or from Florida, (3) in which the solicitor failed to identify their own 

first and last names, and/or the name of the business on whose behalf the solicitation call 

was placed.

32. The following individuals are excluded from the Classes: (1) any Judge or 

Magistrate presiding over this action and members of their families; (2) Defendant, their 

subsidiaries, parents, successors, predecessors, and any entity in which either Defendant or their 

parents have a controlling interest and their current or former employees, officers and directors; 

(3) Plaintiff’s attorneys; (4) persons who properly execute and file a timely request for exclusion 

from the Classes; (5) the legal representatives, successors or assigns of any such excluded persons; 

and (6) persons whose claims against the Defendant has been fully and finally adjudicated and/or 

released. Plaintiff Minor anticipates the need to amend the Class definitions following appropriate 

discovery.

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33. Numerosity: On information and belief, there are hundreds, if not thousands of 

members of the Classes such that joinder of all members is impracticable. 

34. Commonality and Predominance: There are many questions of law and fact 

common to the claims of the Plaintiff and the Classes, and those questions predominate over any 

questions that may affect individual members of the Class. Common questions for the Classes

include, but are not necessarily limited to the following:

(a) whether Defendant placed multiple text messages to Plaintiff and members of the 

Do Not Call Registry class without first obtaining consent to send the text 

messages;

(b) whether Defendant used automatic dialing software to send the solicitation text 

messages to Plaintiff and members of the Autodial class;

(c) whether Defendant sent telemarketing text messages, to Plaintiff and members of 

the Unidentified Telephone Solicitor Class, without identifying the first and last 

names of the solicitor who sent the text, and/or the name of Defendant’s business;

(d) whether Defendant’s conduct violated the TCPA and/or FTSA; and

(e) whether members of the Classes are entitled to treble damages based on the 

willfulness of Defendant’s conduct.

35. Adequate Representation: Plaintiff will fairly and adequately represent and 

protect the interests of the Classes, and has retained counsel competent and experienced in class 

actions. The Plaintiff has no interests antagonistic to those of the Classes, and Defendant have no 

defenses unique to the Plaintiff. The Plaintiff and her counsel are committed to vigorously 

prosecuting this action on behalf of the members of the Classes and have the financial resources 

to do so. Neither the Plaintiff nor her counsel have any interest adverse to the Classes.

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36. Appropriateness: This class action is also appropriate for certification because the 

Defendant have acted or refused to act on grounds generally applicable to the Classes and as 

wholes, thereby requiring the Court’s imposition of uniform relief to ensure compatible standards 

of conduct toward the members of the Classes and making final class-wide injunctive relief 

appropriate. Defendant’s business practices apply to and affect the members of the Classes

uniformly, and Plaintiff’s challenge of those practices hinges on Defendant’s conduct with respect 

to the Classes as wholes, not on facts or law applicable only to Plaintiff Minor. Additionally, the 

damages suffered by individual members of the Classes will likely be small relative to the burden 

and expense of individual prosecution of the complex litigation necessitated by Defendant’s

actions. Thus, it would be virtually impossible for the members of the Classes to obtain effective 

relief from Defendant’s misconduct on an individual basis. A class action provides the benefits of 

single adjudication, economies of scale, and comprehensive supervision by a single court.

FIRST CAUSE OF ACTION

Telephone Consumer Protection Act

(Violations of 47 U.S.C. § 227)

(On Behalf of Plaintiff Minor and the Do Not Call Registry Class)

37. Plaintiff repeats and realleges the prior paragraphs of this Complaint and 

incorporates them by reference.

38. The TCPA’s implementing regulation, 47 C.F.R. § 64.1200(c), provides that “[n]o 

person or entity shall initiate any telephone solicitation” to “[a] residential telephone subscriber 

who has registered her or her telephone number on the national do-not-call registry of persons who 

do not wish to receive telephone solicitations that is maintained by the federal government.”

39. Any “person who has received more than one telephone call within any 12-month 

period by or on behalf of the same entity in violation of the regulations prescribed under this 

subsection may” may bring a private action based on a violation of said regulations, which were 

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promulgated to protect telephone subscribers’ privacy rights to avoid receiving telephone 

solicitations to which they object. 47 U.S.C. § 227(c).

40. Defendant violated 47 C.F.R. § 64.1200(c) by initiating, or causing to be initiated, 

telephone solicitations to telephone subscribers such as the Plaintiff and the Do Not Call Registry 

Class members who registered their respective telephone numbers on the National Do Not Call 

Registry, a listing of persons who do not wish to receive telephone solicitations that is maintained 

by the federal government. 

41. Defendant violated 47 U.S.C. § 227(c)(5) because Plaintiff and the Do Not Call 

Registry Class received more than one telephone call in a 12-month period made by or on behalf 

of Defendant in violation of 47 C.F.R. § 64.1200, as described above. As a result of Defendant’s 

conduct as alleged herein, Plaintiff and the Do Not Call Registry Class suffered actual damages 

and, under section 47 U.S.C. § 227(c), are entitled, inter alia, to receive up to $500 in damages for 

such violations of 47 C.F.R. § 64.1200.

42. To the extent Defendant’s misconduct is determined to be willful and knowing, the 

Court should, pursuant to 47 U.S.C. § 227(c)(5), treble the amount of statutory damages 

recoverable by the members of the Do Not Call Registry Class.

SECOND CAUSE OF ACTION

Telephone Consumer Protection Act

(Violations of Fla. Stat. § 501.059)

(On Behalf of Plaintiff Minor and the Autodial Class)

43. Plaintiff repeats and realleges paragraphs 1 through 36 of this Complaint and 

incorporates them by reference.

44. Plaintiff brings this claim individually and on behalf of the Autodial Class Members 

against the Defendant. 

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45. It is a violation of the FTSA to “make or knowingly allow a telephonic sales call to 

be made if such call involves an automated system for the selection or dialing of telephone numbers 

or the playing of a recorded message when a connection is completed to a number called without 

the prior express written consent of the called party.” Fla. Stat. § 501.059(8)(a).

46. A “telephonic sales call” is defined as a “telephone call, text message, or voicemail 

transmission to a consumer for the purpose of soliciting a sale of any consumer goods or services, 

soliciting an extension of credit for consumer goods or services, or obtaining information that will 

or may be used for the direct solicitation of a sale of consumer goods or services or an extension 

of credit for such purposes.” Fla. Stat. § 501.059(1)(i).

47. Defendant failed to secure prior express written consent from Plaintiff and members 

of the Autodial Class.

48. In violation of the FTSA, Defendant made and/or knowingly allowed telephonic

sales calls to be made to Plaintiff and the Autodial Class members without Plaintiff’s and the Class 

members’ prior express written consent.

49. Defendant made and/or knowingly allowed the telephonic sales calls to Plaintiff 

and the Class members to be made utilizing an automated system for the selection or dialing of 

telephone numbers.

50. As a result of Defendant’s conduct, and pursuant to § 501.059(10)(a) of the FTSA, 

Plaintiff and Class members were harmed and are each entitled to a minimum of $500.00 in 

damages for each violation. Plaintiff and the Class members are also entitled to an injunction 

against future calls. Id

THIRD CLAIM FOR RELIEF

Violation of the Florida Telephone Solicitation Act,

(Violations of the Fla. Stat. § 501.059)

(On Behalf of Plaintiff Minor and the Unidentified Telephone Solicitor Class)

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51. Plaintiff repeats and realleges paragraphs 1 through 36 of this Complaint and 

incorporates them by reference herein.

52. Plaintiff brings this claim individually and on behalf of the Unidentified Telephone 

Solicitor Class Members against Defendant.

53. The FTSA requires “any telephone solicitor who makes an unsolicited telephonic 

sales call to a residential, mobile, or telephonic paging device telephone number” to mandatorily 

“identify himself or herself by his or her true first and last names and the business on whose behalf 

he or she is soliciting immediately upon making contact by telephone with the person who is the 

object of the telephone solicitation.” Fla. Stat. § 501.059(2)

54. A “telephonic sales call” is defined as a “telephone call, text message, or voicemail 

transmission to a consumer for the purpose of soliciting a sale of any consumer goods or services, 

soliciting an extension of credit for consumer goods or services, or obtaining information that will 

or may be used for the direct solicitation of a sale of consumer goods or services or an extension 

of credit for such purposes.” Fla. Stat. § 501.059(1)(i).

55. In violation of the FTSA, Defendant failed to identify the name of the telephone 

solicitor or the business on whose behalf those unsolicited telephonic sales calls were made and/or 

caused to be made to the Plaintiff, and other members of the Unidentified Telephone Solicitor 

Class.

56. As a result of Defendant’s conduct, and pursuant to § 501.059(10)(a) of the FTSA, 

Plaintiff and Class members were harmed and are each entitled to a minimum of $500.00 in 

damages for each violation. Plaintiff and the Class members are also entitled to an injunction 

against future calls. Id.

PRAYER FOR RELIEF

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WHEREFORE, Plaintiff, individually and on behalf of the Classes, prays for the 

following relief:

a) An order certifying this case as a class action on behalf of the Classes as defined 

above; appointing Plaintiff as the representative of the Classes; and appointing her 

attorneys as Class Counsel;

b) An award of damages and costs;

c) An order declaring that Defendant’s actions, as set out above, violate the TCPA and 

the FTSA;

d) An injunction requiring Defendant to cease all unsolicited calling activity, and to 

otherwise protect the interests of the Classes; and

e) Such further and other relief as the Court deems just and proper. 

JURY DEMAND

Plaintiff Minor requests a jury trial.

HEATHER LEE MINOR, individually and on 

behalf of all others similarly situated,

DATED this 25th day of August, 2022.

By: /s/ Stefan Coleman

Stefan Coleman

law@stefancoleman.com

COLEMAN PLLC

66 West Flagler Street

Suite 900

Miami, FL 33130

(877)333-9427

Avi R. Kaufman

kaufman@kaufmanpa.com

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KAUFMAN P.A.

237 South Dixie Highway, Floor 4

Coral Gables, FL 33133

Telephone: (305) 469-5881

Attorneys for Plaintiff and the putative Classes

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