I found the issue. so it helps somebody else, here is the issue:
There are some accounts such as alcohol brands that are setup to validate age before you can follow them. If you send a request to “friendships/create” endpoint to such an account without setting your account Date of Birth first, that endpoint will return the following error:
{“errors”:[{“code”:409,“message”:“Birthdate is required”}]}
Hope that helps someone else. Thanks @andypiper