Maui Wowi litigation history

The franchisor and its predecessor

Concluded (5)

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

  settled

  Brought by a franchisee · 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 24 of the 2025 FDD, Item 3

  Outcome: “On June 19, 2017, the parties entered into a settlement agreement whereby Kahala repurchased Koho’s Area Developer territory for the sum of $75,000 and forgave the remaining damages owed in the amount of $130,000.”

• 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. · 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,”Page 23 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.”

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

  settled

  Brought by a franchisee · filed 2014 · 67th Judicial District Court, Tarrant County, Texas; removed to United States District Court for the Northern District of Texas; transferred to District of Arizona · 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.”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 26)

• In the Matter of Maui Wowi Franchising, Inc., Before the Securities Commissioner of Maryland, Case No. 2007-0194

  concluded

  Government or regulatory action · Maui Wowi Franchising, Inc. (predecessor in interest to Kahala Franchising, L.L.C.) · filed 2007 · Securities Commissioner of Maryland · 2007-0194

  “… On September 12, 2007, “MWF” entered into a Consent Order with the Maryland Commissioner resulting from MWF inadvertently entering into two franchise agreements with two Maryland residents (“Second Maryland Franchisees”) without delivering to them the appropriate Offering Circular.”Page 33 of the 2025 FDD, Item 3

  Outcome: “... training program or trainer to monitor MWF’s franchise activities in Maryland for two years; and to reimburse the Maryland Attorney General for its investigation and resolution costs in the total amount of $2,500.”

• In the Matter of Maui Wowi Franchising, Inc., Before the Securities Commissioner of Maryland, Case No. 2005-0651

  concluded

  Government or regulatory action · Maui Wowi Franchising, Inc. (predecessor in interest to Kahala Franchising, L.L.C.) · filed 2005 · Securities Commissioner of Maryland · 2005-0651

  “… On November 11, 2005, Maui Wowi Franchising, Inc., the predecessor franchisor of the Maui Wowi brand (“MWF”), entered into a Consent Order with the Securities Commissioner of Maryland (“Commissioner”) resulting from MWF inadvertently entering into four franchise agreements with”Page 32 of the 2025 FDD, Item 3

Status not stated in the filing (1)

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

  Brought against a franchisee · Circuit Court of the Nineteenth Judicial Circuit Lake County, Illinois · 2024LA00000001

  “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 34 of the 2025 FDD, Item 3

Parent, affiliates, master franchisor and subfranchisor

Concluded (7)

• 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 · AAA Case No.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 against Wetzel’s Pretzels,”Page 29 of the 2025 FDD, Item 3

  Outcome: “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.” (page 30)

• 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”) filed a Demand for Arbitration”Page 27 of the 2025 FDD, Item 3

• 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 28 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 contingent” (page 29)

• 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, Inc. and Papa Murphy’s International, L.L.C. · filed 2015-04-17 · United States District Court for the Western District of Washington · 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 31 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, et al. v. Papa Murphy’s International LLC, et al. (consolidated with Mitch and Kristen Brink, et al. v. Papa Murphy’s International LLC, et al.)

  settled

  Brought by a franchisee · Papa Murphy’s International LLC (and related Papa Murphy’s entities, board members and executives) · filed 2014 · Washington Superior Court, Clark County · 14-2-00904-0 (consolidated with 14-2- 01743-3)

  “DTD Pizza LLC, Brian Watson, Alton Spears, LMP Enterprises LLC, Pizza Enterprises LLC, Alan and Denise Barnett, DOB Enterprises, Inc., Douglas and Lesia Billing, Rob & Bud's Pizza, Robert J. Dickerson Trust UA, Rob Dickerson, 4LM Enterprises, Inc., Jana and Randell Liles, Ben and Kim Mayfield, SEAMS Holdings LLC, Scott and Erica Shelby, Robert Hoersting, PM Savannah LLC, James and Mona King, Hans”Page 30 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.” (page 31)

• 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 · SweetFrog Enterprises, L.L.C. d/b/a SFF, 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 26 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 by the franchisor · 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 (as captioned); 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.”Page 27 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.”

Status not stated in the filing (1)

• 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 34 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 (Chief Executive Officer) and Robert Langford (Chief Concept Officer – Family Restaurant Division) · filed 2017 · United States Bankruptcy Court for the District of Delaware · 15-12406 (KG)

  “In re: Restaurants Acquisition I, L.L.C. (Giuliano vs. W. Craig Barber et. al. 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 against our Chief Executive Officer W.”Page 29 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.”