World Financial Group Insurance Agency, LLC v. Olson

CourtDistrict Court, N.D. California
DecidedFebruary 22, 2024
Docket5:24-cv-00480
StatusUnknown

This text of World Financial Group Insurance Agency, LLC v. Olson (World Financial Group Insurance Agency, LLC v. Olson) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
World Financial Group Insurance Agency, LLC v. Olson, (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 WORLD FINANCIAL GROUP Case No. 24-cv-00480-EJD INSURANCE AGENCY, 8 ORDER ON MOTION FOR Plaintiff, TEMPORARY RESTRAINING ORDER 9 AND MOTION FOR EXPEDITED v. DISCOVERY 10 ERIC OLSON, et al., Re: ECF Nos. 16, 17 11 Defendants.

12 13 Plaintiff World Financial Group Insurance Agency (“WFG”) brings this suit against 14 Defendants Eric Olson (“Mr. Olson”) and Sandra Olson (“Ms. Olson”) (collectively, “the Olsons” 15 or “Defendants”) alleging Mr. Olson breached his contract with WFG and misappropriated 16 confidential business information. The complaint, originally filed in Santa Clara Superior Court 17 on January 25, 2024, includes seven causes of action for (1) breach of contract, (2) tortious 18 interference, (3) civil conspiracy, (4) fraud, (5) unjust enrichment, (6) conversion, and (7) unfair 19 competition in violation of California Business and Professions Code Section 17200. ECF No. 1- 20 2.1 WFG seeks injunctive relief, monetary damages, and attorneys’ fees and costs. Id. 21 On January 26, 2024, Mr. Olson removed the case to this Court. 22 On January 25, 2024, Ms. Olson and her company, Global Financial Impact, LLC (“GFI”) 23 filed a complaint against WFG in this District seeking injunctive and declaratory relief, attorneys’ 24 fees, and costs. Sandra Olson v. World Fin. Group Ins. Agency, No. 24-cv-00477-EJD (N.D. 25 Cal.), ECF No. 1. The next day, on January 26, 2024, Mr. Olson filed a separate complaint 26 against WFG pleading claims for (1) unfair competition in violation of California Business and 27 1 Professions Code Section 17200, (2) tortious interference, (3) conversion, (4) breach of 2 contract/covenant of good faith and fair dealing, and (5) declaratory relief. Eric Olson v. World 3 Fin. Group Ins. Agency, No. 24-cv-00481-EJD (N.D. Cal.), ECF No. 1. 4 On January 29, 2024, WFG filed the present motion for temporary restraining order 5 (ECF No. 16 (“TRO”)) and motion for expedited discovery (ECF No. 17). Both Mr. Olson and 6 Ms. Olson filed oppositions to the TRO on January 31, 2023 (ECF No. 26 (“Opp.”), 27 (“Ms. 7 Olson Opp.”)), and WFG filed a reply on February 4, 2024 (“Reply”). On February 5, 2024, Mr. 8 Olson filed an opposition to the motion for expedited discovery. ECF No. 43. WFG filed a reply 9 in support of its motion for expedited discovery on February 14, 2024 (ECF No. 60), and Ms. 10 Olson filed a reply regarding the TRO on the same day (ECF No. 61). 11 On February 7, 2024, the Court held a hearing on the TRO and the motion for expedited 12 discovery and ordered supplemental briefing. ECF No. 52. Both parties submitted the requested 13 briefing on February 14, 2024. ECF Nos. 58 (“Olson Suppl.”), 59 (“WFG Suppl.”). 14 The Court related the three actions involving WFG, Mr. Olson, and Ms. Olson on 15 February 5, 2024. ECF No. 46. 16 I. BACKGROUND 17 A. WFG 18 WFG is a multi-level marketing (“MLM”) company that sells insurance products through a 19 network of insurance agents. ECF No. 16-1, Decl. of Todd Buchanan (“Buchanan Decl.”) ¶ 2. 20 In addition to offering insurance products to customers, the agents recruit other insurance 21 agents to work under them, known as “downline agents,” who can then recruit more agents to their 22 downline. Id. ¶ 4; see also ECF No. 29, Decl. of Eric Olson (“Mr. Olson Decl.”) ¶ 3. This 23 structure, an agent’s downline of recruits and their successive recruits collectively, is commonly 24 referred to as a “hierarchy.” Buchanan Decl. ¶ 4; see also Mr. Olson Decl. ¶ 4. Under the 25 hierarchy structure, insurance agents receive an override, which is a percentage of each of their 26 respective hierarchy agents’ commissions. Buchanan Decl. ¶ 4. In other words, the original agent 27 is compensated for sales by their downline recruits and any sales from those agents’ downline 1 hierarchy, the more compensation they are entitled to receive—and the more money WFG makes 2 from the agent’s business.” Id. ¶ 4. And “[a]n agent’s ability to obtain bonuses and capacity to 3 elevate to higher tiers is through recruiting agents.” Id. 4 The insurance agents directly solicit the public to become customers of WFG and the 5 product providers, and the agents can inherit customers from other agents in their hierarchy. 6 Buchanan Decl. ¶ 5. 7 When first signing up with WFG, agents are required to sign an “Associate Membership 8 Agreement” to act as independent contractors for WFG. Mr. Olson Decl. ¶ 5. 9 B. Mr. and Ms. Olson 10 In 2003, Mr. Olson entered into a contract with WFG to work as an agent (the 11 “Agreement”) selling insurance. Mr. Olson Decl., Ex. 1. He has signed an annual renewal of 12 WFG’s Agreement each year since 2023. Id. ¶ 6. During his 20 years with WFG, Mr. Olson was 13 successful recruiting agents to work under him and sell financial products available on the WFG 14 platform, such as life insurance. Id. ¶ 8; see also TRO 3. Mr. Olson owns and operates Pinnacle 15 Leadership Financial Agency (“Pinnacle”), which is a co-brand “reviewed and approved by 16 WFGIA” and through which he operates his downline. TRO 3. Mr. Olson grew the company to 17 over 20,000 agents. Opp. 3. 18 Ms. Olson joined WFG as an insurance agent in 2013, where she met Mr. Olson––her now 19 spouse. Ms. Olson Decl. ¶¶ 3–4. In 2014, Ms. Olson “decided [she] would transition from selling 20 insurance products as an agent to managing and running” Mr. Olson’s company, Pinnacle. Id. ¶ 5. 21 In 2020, Ms. Olson alleges that WFG “stopped recognizing the supporting spouse’s role on its 22 website and promotional materials” and “stopped permitting the supporting spouse, like [her], to 23 present speeches at various WFG conferences.” Id. ¶ 8. It was these changes, she explains, that 24 “made [her] want to play a more active role in selling insurance products and creating [her] own 25 source of income.” Id. 26 In 2022, Mr. Olson decided he wanted to leave WFG for various reasons, including 27 because WFG allegedly “routinely changed its compensation structure to disadvantage its agents.” 1 him to commission from his downline agents––to his wife, Ms. Olson. Id. at 4. But when he was 2 allegedly blocked from doing so because of a sudden change in policy enabling spousal transfers, 3 Mr. Olson then tried to sell his code. Id. Mr. Olson claims, and WFG does not appear to dispute, 4 that WFG changed its policy to prevent that transfer, too. Id. Mr. Olson was thus “left with no 5 ability to leave WFG and receive any compensation for the value of his business.” Id. 6 C. Global Financial Impact, LLC 7 In October 2023, Ms. Olson resigned from WFG and started a new company “to sell 8 insurance products,” called Global Financial Impact, LLC (“GFI”), which is incorporated in 9 Wyoming, registered to do business in Texas, and has an office in San Jose. Id. at 5; TRO 3–4. 10 Ms. Olson hired Matthew Welsh, “an industry expert who had left WFG over two years prior,” to 11 join her. Opp. 5. Together, Ms. Olson and Mr. Welsh developed the structure of GFI, created the 12 curriculum, materials, presentations and training schedules. Id. She recruited four other agents–– 13 one who was unaffiliated with WFG, and three whom had left WFG over two years ago. Id. 14 The initial team of five agents, including Ms. Olson, “brought in other agents, who in turn, 15 brought in other agents.” Id. While Ms. Olson claims she “had not knowingly solicited any 16 agents she understood to be under contract with WFG nor had she instructed any GFI agents to 17 solicit WFG agents,” WFG strongly disputes this. Id.; see generally TRO. According to WFG, 18 Ms. Olson, with the help of Mr. Olson, used her access to WFG’s confidential information “to 19 determine which high-performing insurance agents to target and what leverage to assemble before 20 approaching them.” TRO 4. 21 D.

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World Financial Group Insurance Agency, LLC v. Olson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/world-financial-group-insurance-agency-llc-v-olson-cand-2024.