LifeWave Review (2026): The FTC Case, the Comp Plan, and What Brand Partners Earn

If you searched "LifeWave lawsuit," you're not alone. It's one of the most searched phrases about the company. And most of what you'll find online is either a sales pitch or an argument about whether the patches work.
This LifeWave review is about the business. I'll cover what the FTC actually did in April 2026, how the comp plan pays, what LifeWave's own disclosure says Brand Partners earned, and what I'd want to know before signing up.
Quick answer: LifeWave is a San Diego company, founded in 2004, that sells patches. In April 2026 the FTC sued two of its top Brand Partners, not the company, over income claims. Joining costs $25, and in 2024, 21% of its registered and active US Brand Partners received a commission in at least one month.
I've been inside 8 network marketing companies since 2004, and I always start with the primary sources. For LifeWave, I read its website, its US compensation plan, its 2024 US Earnings Disclosure, the FTC's complaint and stipulated order, and a BBB National Programs case decision. You can browse every company I've reviewed on one page.
What Is LifeWave?
LifeWave sells wearable patches. The FTC's complaint describes it as "a multi-level marketing company that specializes in 'phototherapy patches.'" Its best-known product is the X39.
| Detail | Info |
|---|---|
| Founded | 2004 |
| Headquarters | San Diego, California |
| Founder and CEO | David Schmidt |
| Products | Patches, led by the X39, plus supplements |
| Sellers | Brand Partners |
| Cost to join | $25, plus $25 a year to renew |
| Status | Active in 2026 |
When I checked on October 14, 2026, LifeWave X39 Patches were $149.95, or $99.95 with Subscribe and Save. You can compare LifeWave with other companies in the full MLM company directory.
What the patches do is LifeWave's claim to make, and it's where most of the online arguments are. I'm not going to settle that here, and I won't make any health claims about them.
Who's Behind LifeWave?
LifeWave's own site lists David Schmidt as Founder and CEO and says "David is the inventor of LifeWave technology." Its executive team includes Colman Dillon as Global President, Mark Lindsay as Chief Financial Officer and Jules Rudick as Executive Vice President.
The company is still drawing a crowd. In November 2025, Direct Selling News reported that LifeWave announced "record-breaking attendance" at its 2025 Global Conference in Anaheim, with brand partners "from more than 35 countries."
The LifeWave "Lawsuit": What the FTC Actually Did
Here's what the court filings say, and what they don't.
On April 27, 2026, the FTC filed FTC v. Steven Merritt and Gina Merritt (Case 9:26-cv-80485) in the US District Court for the Southern District of Florida.
- Who was sued: Steven and Gina Merritt. Per the complaint, each "is a Brand Partner for LifeWave" and holds "the rank of Elite Senior Presidential Director."
- What the FTC charged: deceptive acts "by making false or misleading income representations," under Section 5 of the FTC Act.
- An example from the complaint: "It's like a spigot of water but a spigot full of $100 bills throwing at you, coming at you. You can't stop it."
- How it ended: the Merritts agreed to a stipulated order for permanent injunction. They "neither admit nor deny any of the allegations." The order bars misrepresentations, and requires them to email a notice, with the subject line "Notice to LifeWave Participants," to the Brand Partners in their downline who bought an enrollment kit.
What it doesn't say: LifeWave itself is not a defendant. This was a case about how two people at the top of its field pitched the opportunity.
That still matters to you. When the FTC goes after a company's top earners, it's a sign of how the opportunity was being sold. If someone pitches you LifeWave with lines like that, walk away. I covered a much bigger FTC case in Herbalife's FTC settlement, if you want to see how these cases can go.
How the LifeWave Compensation Plan Works
LifeWave's US plan lists "Nine Ways to Earn":
- Retail Profit
- Customer Premiums
- Product Introduction Bonus
- Level Earnings Bonus
- Binary Bonus
- Mentor Matching Bonus
- Business Launch Bonus
- Breakthrough Incentive
- Quarterly Leadership Pool
Getting started:
- Enrollment is $25, with a $25 annual renewal
- "You do not need to purchase products to become or remain a LifeWave Brand Partner"
- Optional enrollment kits in the plan: Core $295, Advanced $535, Advanced Plus $975 and Premium $1,750
Staying active:
- "Brand Partners must maintain at least 55 PV within a rolling 31-day period"
- Team pay runs through a binary, with left and right legs
LifeWave also says it can change the plan with "a minimum of 30 days' notice." And its disclosure is clear that "you cannot earn commissions by merely sponsoring or recruiting others."
What LifeWave Brand Partners Actually Earn
This is where LifeWave deserves credit: it publishes the numbers. From its 2024 U.S. Earnings Disclosure:
- 21% of registered and active Brand Partners received a commission payment in at least one month of 2024
- The average for all US Brand Partners active at any time in 2024 was $651 before expenses
- 34% of Brand Partners earned nothing during the year because they were not active
- 92.48% of active Brand Partners were at the starting Brand Partner rank, where average annual income was $36 and the median was $0
The company also notes that expenses "can be several hundred or thousand dollars annually."
Read that last bullet twice. For more than nine in ten active Brand Partners, the average for the whole year was $36, less than half the $99.95 subscribe price of one X39 order. That's not a scandal on its own. But it's a long way from a spigot full of $100 bills.
Is LifeWave a Pyramid Scheme?
On its structure, no. There's a product people buy, sign-up costs $25 with no required purchase, the disclosure says you can't earn just from recruiting, and there's a 90-day money-back guarantee on a new Brand Partner's first order.
The problem the FTC pointed to wasn't the structure. It was how the opportunity was being sold by some of the people at the top.
What LifeWave's Social Media Shows
These are the accounts linked from LifeWave's website, read on October 14, 2026.
| Platform | Handle | Followers | Posts / videos | Newest |
|---|---|---|---|---|
| YouTube | @LifeWaveHealth | 85.1K subscribers | 176 videos | October 14, 2026 |
| @lifewavecorporate | 64K | 1,158 posts | ||
| TikTok | none linked from its site |
LifeWave has a real YouTube following, with an upload the same day I checked. That's useful company content to share. There's no TikTok account linked from its website.
The Good: What LifeWave Gets Right
- Cheap to start. $25, and no product purchase required.
- It publishes its earnings. The 2024 disclosure is specific and honest about how few people earn much.
- A refund path. 90 days on a new Brand Partner's first order, per the disclosure.
- Active company content. 85,100 YouTube subscribers and fresh uploads.
- It acts on bad claims, at least when asked. In a 2025 case, it got all seven flagged earnings posts taken down.
The Concerns: What You Need to Know
- The FTC case. Two Elite Senior Presidential Directors settled income-claim charges in 2026. That's the top of the field.
- Most people earn little. Over 92% of active Brand Partners were at the starting rank, with a $0 median.
- Self-regulation history. In 2025, BBB National Programs' Direct Selling Self-Regulatory Council (DSSRC) flagged seven earnings claims and two product claims made by salesforce members. LifeWave got them removed, but "did not attempt to substantiate the claims," and "did not provide testing data." It also suspended one repeat offender for three months (Case #199, closed March 3, 2025).
- The product debate. McGill University's Office for Science and Society published an article in July 2025 titled "Patchy Science on LifeWave's Mysterious Patches". Expect to hear about it from skeptical prospects.
- Binary math. Team pay depends on keeping two legs growing.
Product Alternatives
LifeWave's patches don't have a true off-the-shelf equivalent, so I'm not going to point you to a cheaper "copy." Amazon search does show X39 listings, but I couldn't confirm any of them are sold by LifeWave itself, so I wouldn't send you there. And if you want to compare business models, my Zinzino review covers another wellness company that sells a test-and-subscribe program.
If you want the product without the business, here's how to buy it straight from the company. Prices are from LifeWave's X39 page on October 14, 2026:
| What You Want | LifeWave Option | Price | Why Consider It |
|---|---|---|---|
| To try the X39 once | One-time purchase | $149.95 | No subscription |
| To use it every month | Subscribe and Save | $99.95 | About a third off |
| Wholesale prices without selling | Preferred Customer program | see LifeWave's site | No Brand Partner sign-up |
I haven't tested the patches, and I'm not telling you whether they work. This is a buying guide, not a product test.
My Verdict: Is LifeWave Worth Joining in 2026?
One More Thing...
The Merritts got in trouble for selling the money instead of the product. That's the trap in this whole industry: when your friends list runs out, the income pitch is the easiest thing to reach for.
The better path is to learn how to reach people online who already want what you have, and talk to them honestly. That works without a single income claim, and it works with any company.
That's what The Sponsoring System teaches. It's a free email series where I share the digital marketing that actually works for networkers. If you want it, start the free series here.
Frequently Asked Questions
Is there a LifeWave lawsuit?
The case people usually mean is FTC v. Steven Merritt and Gina Merritt, filed April 27, 2026 in federal court in Florida. The FTC charged the two top Brand Partners with false or misleading income claims, and they agreed to a stipulated order without admitting or denying the allegations. LifeWave itself is not a defendant in that case.
Is LifeWave an MLM?
Yes. LifeWave sells through Brand Partners who earn retail profit and commissions on their own sales and on the sales of their team, and the FTC's complaint describes LifeWave as a multi-level marketing company.
How much does it cost to join LifeWave?
LifeWave's 2024 US earnings disclosure says the enrollment fee is $25, with a $25 annual renewal, and that you don't need to buy products to become a Brand Partner. Optional enrollment kits run from $295 to $1,750 in its US compensation plan.
How much do LifeWave Brand Partners make?
In LifeWave's 2024 US earnings disclosure, 21% of registered and active Brand Partners received a commission in at least one month of 2024, and the average for Brand Partners who were active that year was $651 before expenses. Read the full document before you join.
Is LifeWave a scam?
LifeWave has been in business since 2004, publishes an earnings disclosure, and has a 90-day money-back guarantee on a new Brand Partner's first order. The concerns are real but specific: income claims made by people in its field, and product claims that critics dispute.




