Minnesota Life contends that Williams’s other claims for violations of the Texas Insurance Code and DTPA must be dismissed because Williams’s allegations are conclusory. The court agrees. For example, Williams alleges that Minnesota Life violated the DTPA by:
a. Causing confusion or misunderstanding as to the approval or certification of goods or services;
b. Representing goods or services have benefits which they do not have; c. Advertising goods or services with intent not to sell them as advertised;
d. Representing an agreement confers or involves rights and benefits which it does not have or involve or which are prohibited by law;
e. Failing to disclose information concerning goods or services which was known at the time of the transaction and such failure to disclose such information was intended to induce the consumer into a transaction into which the consumer would not have entered had the information been disclosed; and
f. Engaging in an unconscionable course of conduct.
The claims for non-fraud-based violations of the Texas Insurance Code and DTPA are dismissed, without prejudice.