In Fairbanks v. Superior Court, 2009 WL 1035264 (2009), the California Supreme Court held that life insurance is neither a “good” nor a “service” subject to the CLRA.  The Supreme Court explained: 


The Consumers Legal Remedies Act defines “goods” as “tangible chattels bought or leased for use primarily for personal, family, or household purposes, including certificates or coupons exchangeable for these goods, and including goods that, at the time of the sale or subsequently, are to be so affixed to real property as to become a part of real property, whether or not severable from the real property.” (Civ.Code, § 1761, subd. (a).) It defines “services” as “work, labor, and services for other than a commercial or business use, including services furnished in connection with the sale or repair of goods.” ( Id., § 1761, subd. (b).)    Life insurance is a contract of indemnity under which, in exchange for the payment of premiums, the insurer promises to pay a sum of money to the designated beneficiary upon the death of the named insured. (Estate of Barr (1951) 104 Cal.App.2d 506, 508, 231 P.2d 876; see Ins.Code, §§ 22, 101.) Because life insurance is not a “tangible chattel,” it is not a “good” as that term is defined in the Consumers Legal Remedies Act. (Civ.Code, § 1761, subd. (a).) Neither is life insurance a “service” under the act. An insurer’s contractual obligation to pay money under a life insurance policy is not work or labor, nor is it related to the sale or repair of any tangible chattel. Accordingly, we agree with the Court of Appeal that the life insurance policies at issue here are not services as defined in the Consumers Legal Remedies Act.