FDD Items 3 & 4 · 2024 filing

Park Inn by Radisson litigation history

What Park Inn by Radisson disclosed about lawsuits, arbitrations and bankruptcy in the 2024 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: 91; Item 3, as counted in the filing

Largest settlement, franchisor's own cases: $85K; As stated in Item 3

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

Filing year: 2024; Disclosures cover the prior ten years

Extracted from the 2024 Franchise Disclosure Document

Item 3: litigation

3 pending matters: (1) Norma Knuth v. Radisson Hotels International class action in Canada re destination marketing fees (2014); (2) Jai Sai Baba LLC v. Choice Hotels - RICO/discrimination suit now stayed pending arbitration (2020); (3) T&T Management Inc. v. Choice Hotels re territory/data misappropriation (2023). Multiple resolved matters including Highmark award against Choice for $779,398.

Item 3 (litigation) · 91 matters disclosed · 3 pending listed

Litigation cases

The franchisor

Pending (2)

T&T Management, Inc. v. Choice Hotels International, Inc., Country Inn & Suites by Radisson, Inc. and Sunshine Fund Port Orange, LLC
pending
Brought by a franchisee · filed 2023-06-26 · United States District Court for the Middle District of Florida · 6:23-cv-01187
“… United States District Court for the Middle District of Florida, Case No. 6:23-cv-01187 On June 26, 2023, Plaintiff T&T Management, Inc. (“Licensee”) commenced a federal district court action in Florida”Page 22 of the 2024 FDD, Item 3
Jai Sai Baba, LLC, et al. v. Choice Hotels International, Inc., et al.
pending
Brought by a franchisee · filed 2020 · United States District Court for the Eastern District of Pennsylvania · 2:20-cv-02823
“… United States District Court for the Eastern District of Pennsylvania, Case No. 2:20-cv- 02823 On June 12, 2020 (amended on July 15, 2020), approximately ninety current and former franchise owners that own and operate one or more Choice branded hotels”Page 21 of the 2024 FDD, Item 3
Within this matter, as the filing narrates it
- Choice Hotels International, Inc. v. DIP Hospitality, LLC, et al.
  pending
  Brought against a franchisee · names the franchisor · filed 2021-04-09 · American Arbitration Association · 01-21-0003-7036
  “… American Arbitration Association, Case #01-21-0003-7036 On April 9, 2021, Choice initiated this arbitration to pursue contractually due franchise fees, a promissory note balance, and lost profit damages from the franchisees in the amount of $498,495.93.”Page 22 of the 2024 FDD, Item 3
Counted as one matter, the way Item 3 groups it.

Concluded (4)

Dahya Investments Incorporated, et al. v. Choice Hotels International, Inc., et al.
judgment
Brought by a franchisee · filed 2021-06-29 · American Arbitration Association; United States District Court for the District of Maryland, Southern Division · AAA 01-21-0004-5563; 8:2023cv01685
“… American Arbitration Association, Case #01-21-0004-5563 United States District Court for the District of Maryland, Southern Division, Case No. 8:2023cv01685 On June 29, 2021, Dahya Investments Incorporated and Dinu Patel (“Dahya”) filed an arbitration against Choice Hotels International, Inc.”Page 28 of the 2024 FDD, Item 3
Outcome: “A Final Award was issued on May 9, 2023, against Choice and in favor of Dahya in the amount of $882 and in favor of Choice and against Dahya for the sum of $603,483.00. Choice filed a motion to confirm the Final Award against Dahya and the Final Award was confirmed into a judgment on January 17, 2024 at the motion to seal hearing.”
Highmark Lodging, LLC, et al. v. Choice Hotels International, Inc., et al.
judgment
Brought by a franchisee · filed 2021-06-29 · American Arbitration Association; United States District Court for the Eastern District of Pennsylvania · AAA 01-21-0004-5554; 5:20cv2823
“… American Arbitration Association, Case #01-21-0004-5554 United States District Court for the Eastern District of Pennsylvania, Case #5:20cv2823 On June 29, 2021, Highmark Lodging, LLC and Darshan Patel (“Highmark”) filed an arbitration against Choice Hotels International, Inc.”Page 28 of the 2024 FDD, Item 3
Outcome: “A Final Award was issued on July 27, 2023 against Choice and in favor of Highmark in the amount of $740,072.25. Highmark filed a motion to confirm the Final Award and Choice filed a motion to vacate in part. Choice’s motion was denied, and a final judgment was entered against Choice in the amount of $779,398.40 on March 4, 2024.”
Sender Kohl v. Choice Hotels International, Inc.
settled
Brought by a franchisee · filed 2018-10-29 · United States District Court for the Southern District of Florida, Fort Lauderdale Division, and American Arbitration Association · 0:18-cv-62597; AAA 01-19-0000-1797
“… United States District Court for the Southern District of Florida, Fort Lauderdale Division, Case #0:18-cv-62597 and American Arbitration Association, Case #01-19-0000-1797 On October 29, 2018, Sender Kohl filed an action against us seeking damages in an unspecified amount.”Page 28 of the 2024 FDD, Item 3
Outcome: “On August 25, 2021, the parties settled this dispute. As part of the settlement, Choice agreed to pay its former franchisee $85,000.00 in exchange for dismissal of the arbitration.”
Wydredge, L.L.C., H & P Investments, Clayton Wyman, Barry Eldredge and James Rumpsa v. Choice Hotels International, Inc.
settled
Brought by a franchisee · filed 2012-08-31 · American Arbitration Association · 16-114-000517-12
“On August 31, 2012, Wydredge, L.L.C., H & P Investments, Clayton Wyman, Barry Eldredge and James Rumpsa filed an arbitration demand against Choice Hotels International, Inc. The arbitration demand sought unspecified damages for unjust enrichment, intentional misrepresentation, negligent misrepresentation, breach of contract, and breach of implied covenant of good faith and fair dealing.”Page 28 of the 2024 FDD, Item 3
Outcome: “On July 7, 2014, the parties settled this dispute. As part of the settlement, Choice made certain concessions to franchisees in connection with two existing franchise agreements for other properties owned by franchisees reducing the royalty rate to 4.65% for 24 months and 4.25% for 24 months respectively.”

Status not stated in the filing (8)

Choice Hotels International, Inc. v. 144 Investors, LLC and Surjeet Kaur
Brought against a franchisee · filed 2023-08-11 · U.S. District Court Eastern District of New York (Brooklyn) · 1:23cv06066
“144 Investors, LLC and Surjeet Kaur U.S. District Court Eastern District of New York (Brooklyn) 1:23cv06066 August 11, 2023”Page 27 of the 2024 FDD, Item 3
Choice Hotels International, Inc. v. 67585 Hacienda, LLC and Calvin Chun
Brought against a franchisee · filed 2023-01-31 · American Arbitration Association · 01-23-0000-4410
“67585 Hacienda, LLC and Calvin Chun American Arbitration Association 01-23-0000-4410 January 31, 2023”Page 23 of the 2024 FDD, Item 3
Choice Hotels International, Inc. v. Donald R. Dreiske, Lance B. Stuart, James R. Stuart, Harvey W. Lester and Rebecca Kenny
Brought against a franchisee · filed 2023-01-31 · American Arbitration Association · 01-23-0000-4309
“Donald R. Dreiske, Lance B. Stuart, James R. Stuart, Harvey W. Lester and Rebecca Kenny American Arbitration Association 01-23-0000-4309 January 31, 2023”Page 23 of the 2024 FDD, Item 3
Choice Hotels International, Inc. v. Jai Sai Baba, LLC, Dipesh Patel and MDPD13 Investments, LLC
Brought against a franchisee · filed 2023 · United States District Court for the District of Maryland, Southern Division, transferred to United States District Court for the Eastern District of Pennsylvania, Philadelphia · 8:2023cv00146; 8:2023cv03360
“Jai Sai Baba, LLC, Dipesh Patel and MDPD13 Investments, LLC United States District Court for the District of Maryland, 8:2023cv00146 8:2023cv03360 January 19, 2023 August 25, 2023”Page 22 of the 2024 FDD, Item 3
Choice Hotels International, Inc. v. Jeet Hospitality, Inc. and Indravaden Patel
Brought against a franchisee · filed 2023-02-02 · American Arbitration Association · 01-23-0000-4726
“Jeet Hospitality, Inc. and Indravaden Patel American Arbitration Association 01-23-0000-4726 February 2, 2023”Page 23 of the 2024 FDD, Item 3
Choice Hotels International, Inc. v. Kei. V. Inc. and Seyed A. Mousavizadeh
Brought against a franchisee · filed 2023-02-02 · American Arbitration Association · 01-23-0000-4732
“Kei. V. Inc. and Seyed A. Mousavizadeh American Arbitration Association 01-23-0000-4732 February 2, 2023”Page 23 of the 2024 FDD, Item 3
Choice Hotels International, Inc. v. Le Cercle Rouge, LLC, David Adehou and Milan G. Mody
Brought against a franchisee · filed 2023-01-31 · American Arbitration Association · 01-23-0000-4439
“Le Cercle Rouge, LLC, David Adehou and Milan G. Mody American Arbitration Association 01-23-0000-4439 January 31, 2023”Page 23 of the 2024 FDD, Item 3
Choice Hotels International, Inc. v. SC Hotel Group, LLC, SC Hotel Partners, LLC, Lajwanti Gandhi and Rolan Chowdhury
Brought against a franchisee · filed 2023-01-18 · Circuit Court for Montgomery County, Maryland · C15CV23000171
“SC Hotel Group, LLC, SC Hotel Partners, LLC, Lajwanti Gandhi and Rolan Chowdhury Circuit Court for Montgomery County, Maryland C15CV23000171 January 18, 2023”Page 22 of the 2024 FDD, Item 3

Parent, affiliates, master franchisor and subfranchisor

Pending (1)

Norma Knuth v. Radisson Hotels International, Inc., et al.
pending
Radisson Hotels International, Inc. and Country Inn & Suites by Radisson, Inc. ('Country'), now wholly owned subsidiaries of the franchisor Choice · filed 2014-12-05 · Court of Queen’s Bench for Saskatchewan · QBG No. 2560 of 2014
“… Court of Queen’s Bench for Saskatchewan, Court File No. QBG No. 2560 of 2014 On December 5, 2014, Norma Knuth filed a complaint under the Class Actions Act against over 25 named defendants, including Country, alleging that the defendants wrongfully collected undisclosed destination marketing fees”Page 21 of the 2024 FDD, Item 3
Within this matter, as the filing narrates it
- Matter with no printed caption
  Brought against a franchisee · names an affiliate · Radisson and Country (claimants for contribution and indemnification) · filed 2017-06-02 · Court of Queen’s Bench for Saskatchewan (implied; within Knuth)
  “On June 2, 2017, Radisson and Country filed a Statement of Claim against 2 current and 3 former franchisees/licensees, that had not entered into tolling agreements, seeking contribution and indemnification.”Page 21 of the 2024 FDD, Item 3
Counted as one matter, the way Item 3 groups it.

This list shows 15 of the 91 matters Item 3 discloses; the rest are in the filing.

2 of the proceedings above are indented under the matter they belong to because the filing narrates them inside it — an appeal, a consolidated case, a related arbitration. Each carries its own quote and page. They are counted with their matter, not as extra matters, so this list and the 91 Item 3 discloses agree.

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 active litigations including class action, anti-competitive claims, and trade secret misappropriation suggest systemic operational/legal problems
Choice Hotels' royalty recovery lawsuits indicate payment compliance issues across system

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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