FDD Items 3 & 4 · 2025 filing

OpenWorks litigation history

What OpenWorks disclosed about lawsuits, arbitrations and bankruptcy in the 2025 Franchise Disclosure Document. Item 3 lists the material legal actions a franchisor must report; Item 4 covers bankruptcy. This is the franchisor's own disclosure, not a court record, and not legal advice.

Items 3 (litigation) & 4 (bankruptcy) at a glance

What the filing discloses

Cases disclosed: 9; Item 3, as counted in the filing

Largest settlement, franchisor's own cases: $10K; As stated in Item 3

Bankruptcy (Item 4): None; Franchisor, parent, predecessor or officer

Filing year: 2025; Disclosures cover the prior ten years

Extracted from the 2025 Franchise Disclosure Document

Item 3: litigation

Multiple breach of contract suits by former franchisees alleging failure to provide promised account volumes. Cases filed in AZ, MO, CO, TX, WA, CA. Several settled with payments ranging from $4,000 to $185,000.

Item 3 (litigation) · 9 matters disclosed · 1 pending listed

Litigation cases

The franchisor

Pending (1)

VS & KK Services LLC v. O.P.E.N. America, Inc.
pending
Brought by a franchisee · Montgomery County Justice Court, Texas · 23CV3-003597
“… (Montgomery County Justice Court, Texas, Case No. 23CV3-003597). VS & KK Services LLC, a Texas franchisee, filed a complaint against OpenWorks alleging breaches of contract.”Page 9 of the 2025 FDD, Item 3

Concluded (8)

Jody Williams v. O.P.E.N. America, Inc.
settled
Brought by a franchisee · filed 2021-08-09 · Circuit Court of Cass County, Missouri · 21CA-CC00162
“… (Circuit Court of Cass County, Missouri, Case No. 21CA-CC00162). Mr. Williams, a former franchisee in the Kansas City market area residing in Missouri, filed a complaint against OpenWorks alleging Breach of Contract on August 9, 2021 and served OpenWorks on August 19, 2021.”Page 10 of the 2025 FDD, Item 3
Outcome: “The parties reached a settlement agreement in April 2022, with OpenWorks paying the Plaintiff $9,000 and dissolving $9,500 of Plaintiff’s debt owed to OpenWorks.”
Vontray Nubine v. O.P.E.N. America, Inc. DBA OpenWorks
dismissed
Brought by a franchisee · filed 2021-07-28 · Superior Court of Maricopa County; United States District Court of Colorado · CV2021-011972; 1:23-cv-02144-SBP
“… (Superior Court of Maricopa County, Case No. CV2021-011972 and United States District Court of Colorado Case No. 1:23- cv-02144-SBP).”Page 9 of the 2025 FDD, Item 3
Outcome: “dismissed the case with prejudice, and allowed OpenWorks to submit a motion for attorney fees. We Clean Everything LLC v. O.P.E.N.” (page 10)
Ruth Mark v. O.P.E.N. America, Inc. d/b/a/ OPENWORKS
settled
Brought by a franchisee · filed 2018 · U.S. District Court for the District of Colorado; U.S. District Court for the District of Arizona · 1:18-cv-02412-NRN; 2:18-cv-03780-JAT
“… (U.S. District Court for the District of Colorado, Case No. 1:18-cv-02412-NRN;”Page 10 of the 2025 FDD, Item 3
Outcome: “This matter was settled in November 2019, with OpenWorks paying the named Plaintiff $70,000 and forgiving her debt in return for Plaintiff’s release.” (page 11)
L. Solano v. Tanaka, Reliable Maintenance, Cambro Manufacturing Co., OpenWorks, O.P.E.N. America, Inc.
settled
Brought by a franchisee · filed 2015 · Superior Court of California, Orange County · 30-2015-00823186-CU-OE- CJC
“… (Superior Ct. CA, Orange County, Case No. 30-2015-00823186-CU-OE- CJC).”Page 11 of the 2025 FDD, Item 3
Outcome: “OpenWorks and Cambro settled the matter for a payment of $12,500 to the employee and a payment of $2,500 to the California Labor Workforce and Development Agency in return for the employee’s release and dismissal of claims against OpenWorks and Cambro, which was approved by the court in January 2017.”
Ainashe Atosh v. O.P.E.N. America, Inc.
settled
Brought by a franchisee · King County District Court, Washington · 23CIV07799KCX
“… (King County District Court, Washington, Case No. 23CIV07799KCX). Mr. Atosh, a former franchisee, filed small claims complaint against OpenWorks alleging that OpenWorks failed to deliver on its promises.”Page 10 of the 2025 FDD, Item 3
Outcome: “The parties reached a settlement agreement in November 2023, with OpenWorks paying the Plaintiff $1,200. Jody Williams v. O.P.E.N.”
Amber Beasley v. O.P.E.N. America, Inc. d/b/a OPENWORKS
settled
Brought by a franchisee · Superior Court of California, County of Los Angeles · 19STCV43673
“… (Superior Court of California, County of Los Angeles, Case No. 19STCV43673).”Page 10 of the 2025 FDD, Item 3
Outcome: “This matter was fully settled in April 2020, with OpenWorks paying the plaintiff $4,000 and forgiving her debt in exchange for Plaintiff’s release.”
JM & GW Investments LLC v. O.P.E.N. America.
settled
Brought by a franchisee · No case filed (mediation)
“… (No Case Filed). Jodie Leamer, a former Texas franchisee, through herself and her entity JM & GW Investments LLC, made allegations against OpenWorks claiming Breach of Contract during the years 2019 and 2020.”Page 10 of the 2025 FDD, Item 3
Outcome: “reached a settlement agreement, with OpenWorks paying the Plaintiff $10,000 and dissolving the remainder of the Plaintiff’s debt owed to OpenWorks.”
We Clean Everything LLC v. O.P.E.N. America, Inc.
concluded
Brought by a franchisee · Maricopa County Superior Court, Arizona · CV2024-007361
“… (Maricopa County Superior Court, Arizona, Case No. CV2024-007361). We Clean Everything LLC, a Texas Franchisee, filed a complaint against OpenWorks alleging breaches of contract.”Page 10 of the 2025 FDD, Item 3

Item 3 lists the litigation the franchisor must disclose; a matter against a parent, an affiliate or a named officer is not a matter against the franchisor, and pending claims are allegations, not findings.

Disclosure signals that moved the score

How this shows up in the verdict

Multiple litigation cases including breach of contract, labor law violations (minimum wage, overtime, meal periods), and fraud/misrepresentation claims signal operational and compliance problems

The verdict grade is FranchiseVerdict's editorial assessment across SBA loan performance, unit growth, revenue and disclosure signals. It is not investment advice.

Before you weigh a lawsuit

How to read Item 3

A franchisor must disclose pending actions and any material civil action involving the franchise relationship, plus convictions or civil judgments for fraud, unfair or deceptive practices, or franchise-law violations, going back ten years. A case the franchisor brought against a franchisee counts too. Item 3 does not include every dispute: settled claims below the materiality line and matters resolved in private arbitration can be absent.

Questions worth asking current and former franchisees, using the contact list in Item 20:

Were you, or anyone you know in the system, party to a dispute with the franchisor?
Was it resolved by settlement, arbitration or a court, and on what terms?
Has the number of disputes gone up or down since you signed?

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