Manchu WOK litigation history

The franchisor and its predecessor

Concluded (1)

• Purav Enterprises, L.L.C., Balwant Bahia, and Paramjit Samra v. The Extreme Pita Franchising USA, Inc., EP Development, Inc., and Feisal Ramjee

  settled

  Brought by a franchisee · The Extreme Pita Franchising USA, Inc. (heading: 'predecessor in interest to MTY Franchising USA, Inc.'; Item 1 says MTY Franchising USA was formerly known by that name) · filed 2015-06-22 · Superior Court of the State of Washington for King County · 15-2-15120-7

  “… Superior Court of the State of Washington for King County, Case No. 15-2-15120-7. On June 22, 2015, Purav Enterprises, L.L.C., Balwant Bahia, and Paramjit Samra (collectively “Plaintiffs”), filed a complaint against The Extreme Pita Franchising USA, Inc.”Page 22 of the 2025 FDD, Item 3

  Outcome: “The parties entered into a settlement agreement on March 11, 2016, in which Defendants paid Plaintiffs the sum of $20,000. The matter was dismissed on March 16, 2016.” (page 23)

Parent, affiliates, master franchisor and subfranchisor

Concluded (11)

• Pretzelsdallas1, Inc. v. Wetzel’s Pretzels, L.L.C.

  settled

  Brought by a franchisee · Wetzel’s Pretzels, L.L.C. · filed 2019 · American Arbitration Association (Los Angeles, California) · 01-19-0002-9326

  “… Los Angeles, California; AAA Case No.01-19- 0002-9326. On or about July 19, 2017, we entered into a franchise agreement with Pretzelsdallas1, Inc. (then known as Triple Scoops, Inc.). On or about September 11, 2019, Pretzelsdallas1, Inc., (“Claimant/Counter Respondent”) a franchisee, filed a demand for arbitration”Page 28 of the 2025 FDD, Item 3

  Outcome: “On September 24, 2021, the parties entered into a settlement agreement, in which a mutual release of all claims was agreed to, and Respondent/Counter Claimant paid Claimant/Counter Respondent the sum of $125,000. The matter was subsequently dismissed with prejudice.”

• Desert Ribs, L.L.C., Famous Gracie, L.L.C., Famous Freddie, L.L.C., Famous George, L.L.C. and Famous Charlie, L.L.C. v. Famous Dave’s of America, Inc.

  settled

  Brought by a franchisee · Famous Dave’s of America, Inc. · filed 2016-03-14 · American Arbitration Association, Minneapolis, Minnesota · 01 16 0000 8549

  “… American Arbitration Association, Minneapolis, Minnesota, Case No. 01 16 0000 8549. On March 14, 2016, the franchisees for the Famous Dave’s® Restaurants in Chandler, Peoria, Mesa and Gilbert, Arizona (“Claimants”)”Page 26 of the 2025 FDD, Item 3

  Outcome: “Upon the dismissal of the MFA claims, Claimants voluntarily dismissed their remaining claims against Famous Dave’s and entered into a confidential settlement agreement and mutual release (the “Settlement Agreement”), dated August 22, 2016, with Famous Dave’s.”

• SFF, L.L.C. v. Carmel Village Yogurt Company L.L.C.

  dismissed

  Brought against a franchisee · SFF, L.L.C. · filed 2016-08-29 · City of Richmond, Virginia Circuit Court · CL16-3927

  “… City of Richmond, Virginia Circuit Court; Case No. CL16-3927. On August 29, 2016, SFF, L.L.C. (“Plaintiff”) filed a lawsuit against three sweetFrog franchisee entities, Carmel Village Yogurt Company L.L.C. (“Defendant Carmel YC”),”Page 25 of the 2025 FDD, Item 3

  Outcome: “Plaintiff paid Defendant Carmel YC $25,000; (iii) Plaintiff reinstated Defendant Huntersville YC’s and Defendant Mooresville YC’s terminated franchise agreements; and (iv) Plaintiff granted Defendant Anto the right to develop a new sweetFrog shop at a mutually acceptable location on or before November 8, 2018. The case was dismissed with prejudice on December 15, 2016.”

• Famous Dave’s of America, Inc. v. Allan Gantes; John Gantes; M Mart 1, L.L.C.; Kurt Schneiter; Shoreline FD Investors, L.L.C.; SR El Centro FD, Inc. SR Long Beach FD, Inc.; SR Palmdale FD, Inc.; SR Restaurant Holdings Group, Inc.; SR Simi Valley FD, Inc.; SR Tracey FD, Inc.

  settled

  Brought against a franchisee · Famous Dave’s of America, Inc. · filed 2015-07-24 · Superior Court of the State of California, County of Los Angeles, Central Division · BC589329

  “… Superior Court of the State of California, County of Los Angeles, Central Division, Case No. BC589329.”Page 27 of the 2025 FDD, Item 3

  Outcome: “On September 29, 2018, the parties agreed to enter into a confidential settlement agreement and a mutual release of claims (the “El Centro Settlement Agreement”), which contained the following material terms: (i) SR Defendants received $75,000 towards the payment of their attorney’s fees”

• KOHO, Inc. v. Kahala Franchising, L.L.C.

  settled

  Brought by a franchisee · Kahala Franchising, L.L.C. · filed 2015 · Superior Court of the State of California for the County of Los Angeles · BC572565

  “… Superior Court of the State of California for the County of Los Angeles; Case No.: BC572565. On or about February 17, 2015, Koho, Inc. (“Koho”) filed a Complaint against Kahala Franchising, L.L.C. (“Kahala”) alleging: (i) breach of contract; (ii) unjust enrichment; and (iii) declaratory relief.”Page 23 of the 2025 FDD, Item 3

  Outcome: “territory for the sum of $75,000 and forgave the remaining damages owed in the amount of $130,000.” (page 24)

• Rob & Bud’s Pizza, L.L.C. v. Papa Murphy’s International, Inc. and Papa Murphy’s International, L.L.C.

  settled

  Brought by a franchisee · Papa Murphy’s International, L.L.C. · filed 2015-04-17 · United States District Court for the Western District of Washington (as printed) · 5:15-cv-05090-TLB

  “… United States District Court for the Western District of Washington, Case No. 5:15-cv- 05090-TLB. In spring 2015, Papa Murphy’s sent a notice of default to plaintiff for alleged defaults under the plaintiff’s franchise agreements.”Page 30 of the 2025 FDD, Item 3

  Outcome: “The case was dismissed with prejudice as part of a settlement with plaintiff in this case and the LMP case under which Papa Murphy’s purchased plaintiff’s nine Papa Murphy’s stores at an agreed upon value of the stores’ assets plus $500,000.”

• DTD Pizza LLC, Brian Watson, Alton Spears, LMP Enterprises LLC, ... and Papa's of Tennessee, LLC. v. Papa Murphy’s International LLC, et al. (Case No. 14-2-00904-0) and Mitch and Kristen Brink, Brink Holdings Inc., ... and Red Rust, LLC, v. Papa Murphy’s International LLC, et al. (Case No. 14-2-0174

  settled

  Brought by a franchisee · Papa Murphy’s International, L.L.C. (with related Papa Murphy's entities, directors and executives) · filed 2014 · Washington Superior Court, Clark County · 14-2-00904-0 (consolidated; the second action was 14-2-01743-3)

  “Washington Superior Court, Clark County, Case No. 14-2-01743-3. These two related actions were commenced in April 2014 and June 2014, respectively, by separate groups of current and former franchisees against us, certain members of our board of managers and executive team, and others in Washington Superior Court (Clark County), alleging misrepresentations involving financial performance”Page 29 of the 2025 FDD, Item 3

  Outcome: “Each of the plaintiff groups =entered into settlements with Papa Murphy’s in which they dismissed all of their claims against defendants with prejudice and the action was dismissed in June 2020.”

• Texas Nrgize #1, Inc. v. Kahala Franchising, L.L.C. and Kahala Holdings, L.L.C.

  settled

  Brought by a franchisee · Kahala Franchising, L.L.C. and Kahala Holdings, L.L.C. · filed 2014 · 67th Judicial District Court, Tarrant County, Texas; removed to U.S. District Court for the Northern District of Texas; transferred to U.S. District Court for the District of Arizona, Phoenix Division · 067-272652-14; 4:14-cv-544-Y; CV15-0337 PHX DGC

  “… 67th Judicial District Court, Tarrant County, Texas; Civil Action No.: 067-272652-14 subsequently removed to United States District Court for the Northern District of Texas; Case No.: 4:14-cv-544-Y. On or about June 18, 2014, Texas Nrgize #1, Inc., an Nrgize franchisee (“Plaintiff”), filed a Petition”Page 24 of the 2025 FDD, Item 3

  Outcome: “In December 2015, the parties executed a settlement agreement in which Defendant paid Plaintiff the sum of $35,000. The parties filed a Stipulation to Dismiss With Prejudice on December 18, 2015.” (page 25)

• Urquieta Sweet Frog, L.L.C. and Ana Urquieta v. SweetFrog Enterprises, L.L.C. d/b/a SFF, L.L.C.

  settled

  Brought by a franchisee · SFF, L.L.C. (successor in interest to SweetFrog Enterprises, L.L.C.) · filed 2014-12-23 · American Arbitration Association · 01 14 0001 8086

  “… American Arbitration Association; Case No. 01 14 0001 8086. On December 23, 2014, Urquieta Sweet Frog, L.L.C. and Ana Urquieta, a former sweetFrog franchisee and its owner (collectively “Plaintiffs”), filed a Demand for Arbitration against SweetFrog Enterprises, L.L.C. (“Defendant”).”Page 25 of the 2025 FDD, Item 3

  Outcome: “This matter was settled in December of 2015. Under the settlement, Defendant agreed to pay Plaintiffs $300,000 and the parties executed mutual releases.”

• Fresh Enterprises, L.L.C. v. Ledang Investment Group, L.L.C., Vincent Tienn Le, Ho Tien Le and Hue This Dang

  settled

  Brought against a franchisee · Fresh Enterprises, L.L.C. (successor in interest to BF Acquisition, L.L.C.) · filed 2013-07-02 · Superior Court of the State of California, County of Santa Clara; arbitrated before the American Arbitration Association · 1-13-CV-257219; AAA 72-20-1400-0126

  “… Superior Court of the State of California, County of Santa Clara, Case No. 1-13- CV-257219. On July 2, 2013, Fresh Enterprises, L.L.C., as successor-in-interest to Baja Fresh Westlake Village, Inc. (“Plaintiff”), filed a complaint against Ledang Investment Group, L.L.C.;”Page 26 of the 2025 FDD, Item 3

  Outcome: “On February 2, 2015, the Arbitrator issued an award in favor of Cross Claimants Ledang in the amount of $660,620.84. The parties entered into a Settlement and Release Agreement on July 20, 2015, under which Counter Defendants paid the Cross Claimants Ledang the sum of $585,000 and the matter was dismissed with prejudice.”

• State of Maryland Determination

  concluded

  Government or regulatory action · Triune, LLC (predecessor of affiliate BF Acquisition Holdings, L.L.C.) · filed 2012 · Office of the Attorney General of Maryland (Maryland franchise regulator) · 2012-0073

  “… Case Number 2012-0073. In February 2012, the State of Maryland alleged that during the period January 1, 2009 to November 26, 2009, Triune, LLC (“Triune”): (i) did not retain signed acknowledgements of receipt reflecting the dates that its Franchise Disclosure Document was delivered to certain Maryland residents and non-residents;”Page 32 of the 2025 FDD, Item 3

  Outcome: “Without admitting or denying the allegations, in September 2012, Triune voluntarily entered into a Consent Order with the Office of the Attorney General of Maryland and agreed to: (i) not violate the Maryland Law in the future; (ii) pay the Office of the Attorney General the sum of $50,000 as a civil penalty;”

Status not stated in the filing (2)

• Cold Stone Creamery Leasing Company, Inc. v. JRF, Inc.

  Brought against a franchisee · Cold Stone Creamery Leasing Company, Inc. · Iowa District Court for Dallas County · SCSC050015

  “Suit for Forcible Entry and Detainer Cold Stone Creamery Leasing Company, Inc. v. JRF, Inc.; Iowa District Court for Dallas County; Case No.: SCSC050015.”Page 33 of the 2025 FDD, Item 3

• Kahala Franchising, L.L.C. v. All About Food, Inc. and Chu Yup Lee a/k/a Michale Lee

  Brought against a franchisee · Kahala Franchising, L.L.C. · Circuit Court of the Nineteenth Judicial Circuit Lake County, Illinois · 2024LA00000001

  “Lawsuits Filed by Franchisor Kahala Franchising, L.L.C. Against Franchisees During Fiscal Year December 1, 2023 through November 30, 2024 Suit for Breach of Contract Kahala Franchising, L.L.C. v. All About Food, Inc. and Chu Yup Lee a/k/a Michale Lee; In the Circuit Court of the Nineteenth Judicial Circuit Lake County, Illinois; Case No.: 2024LA00000001.”Page 33 of the 2025 FDD, Item 3

Officers and directors (individuals, not the company)

Concluded (1)

• In re: Restaurants Acquisition I, L.L.C. (Giuliano vs. W. Craig Barber et. al.

  settled

  W. Craig Barber (printed as 'our Chief Executive Officer') and Robert Langford ('our Chief Concept Officer – Family Restaurant Division'); section heading: VI BrandCo, L.L.C. · filed 2017 · United States Bankruptcy Court for the District of Delaware · 15-12406 (KG)

  “… United States Bankruptcy Court for the District of Delaware on December 2, 2015 (Case No. 15-12406 (KG)). On December 1, 2017, the Chapter 7 trustee in the Restaurants Acquisition I, L.L.C. (“RAI”) bankruptcy proceeding filed suit in the United States Bankruptcy Court”Page 28 of the 2025 FDD, Item 3

  Outcome: “On March 6, 2019, Barber and Langford each settled with the Chapter 7 trustee by each agreeing to pay to the trustee and estate separate payments totaling $150,000 each over a three-year period.”