UNITED STATES OF AMERICA 

Federal Trade Commission 

WASHINGTON, D.C. 20580 

April 24, 2020 

Via Electronic Mail 

IDLife, LLC 

c/o Mark Bennett, COO, General Counsel 

10825 John W. Elliot Dr. #100 

Frisco, Texas 75033 

Warning Regarding Earnings Claims Related to Coronavirus 

Disease 2019 (COVID-19) 

Dear Mr. Bennett, 

FTC staff has reviewed social media posts made by IDLife, LLC (“IDLife”) business 

opportunity participants or representatives that unlawfully misrepresent that consumers who 

become IDLife business opportunity participants are likely to earn substantial income. This letter 

is to provide you with information about laws and regulations enforced by the Federal Trade 

Commission (“FTC”) that may bear upon your business activities, including the activities of your 

business opportunity participants and representatives. 

Some examples of earnings claims made by your business opportunity participants or 

representatives include: 

 “Stimulus check=$1200 I used to think thats alot of money but now I know ways 

that amount can be made rather quickly.” Statement made on the social media 

page of person who lists their work as “IDLife Corporate National Presidential 

Director.” 

 In a video titled “What did [] & [] do when she lost her job in May and how could 

this help you now with what is going on?”, the statements: “I love going to bed at 

night and waking up in the morning to see I’ve earned more income when I was 

sleeping than when I was awake....” [nine minutes later] “Is it gonna help you 

rebuild that savings . . . that three month, six month savings that you’re depleting 

right now?” 

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 false, misleading, or unsubstantiated and 

material to consumers. Express and implied earnings claims must be truthful and non-misleading 

to avoid being deceptive, which means that claims about the potential to achieve a wealthy 

lifestyle, career-level income, or significant income are false or misleading if business 

opportunity participants generally do not achieve such results. Even truthful testimonials from 

participants who do earn significant income or more will likely be misleading unless the 

advertising also makes clear the amount earned or lost by most participants. Your business 
 

opportunity participants and representatives must immediately cease making all express and 

implied earnings claims that would be false or misleading to current or prospective participants. 

You are responsible for the claims of your business opportunity participants and 

representatives. As the FTC stated in the January 2019 Business Guidance Concerning MultiLevel Marketing, the compensation structure of a Multi-Level Marketing entity (“MLM”) may 

create incentives for its participants to make certain representations to current or prospective 

participants. “As a consequence, an MLM should (i) direct its participants not to make false, 

misleading, or unsubstantiated representations and (ii) monitor its participants so they don’t 

make false, misleading, or unsubstantiated representations.” 

You are advised to review all claims relating to your business opportunity and 

immediately cease, and require your business opportunity participants and representatives to 

cease, making claims that are not supported by the evidence or substantiation described above. 

Within 48 hours, please send reply via email to COVID-19-Task-Force@ftc.gov 

describing the specific actions you have taken to address the FTC’s concerns. If you have any 

questions regarding compliance with the FTC Act, please contact us at COVID-19-TaskForce@ftc.gov. 

 Sincerely,

 Federal Trade Commission Staff 

2