SafeSplash Swim School litigation history

The franchisor

Pending (1)

• Milly Ali v. LA Fitness, LLC, Fitness International, LLC, Streamline Brands, SafeSplash Swim School, LLC, SafeSplash Brands LLC, Westchester Swim Studios d/b/a SwimLabs Westchester, and Oman Gutierrez

  pending

  Third-party plaintiff · filed 2024-10-24 · N.Y. Supreme Court for Westchester County · 62625/2024

  “In this matter, a franchisee’s customer filed a lawsuit against us, our franchisee, the franchisee’s landlord (the operator of a Host Location), and the perpetrator related to a sexual assault of an adult that allegedly occurred at the Host Location. We filed a counterclaim against our franchisee to enforce the indemnification p”Page 22 of the 2025 FDD, Item 3

Parent, affiliates and predecessor

Concluded (4)

• Consent Order Number S-21-3104-21-CO01 (State of Washington Department of Financial Institutions, Securities Division - SwimLabs & Rehab Holding Company, Inc.)

  concluded

  Government or regulatory action · SwimLabs & Rehab Holding Company, Inc. · filed 2021-05-17 · State of Washington Department of Financial Institutions, Securities Division · S-21-3104-21-CO01

  “SwimLabs & Rehab Holding Company, Inc., a Colorado corporation from which we acquired substantially all of the assets comprising the SwimLabs® franchise system, entered into a Consent Order with the State of Washington Department of Financial Institutions, Securities Division (“DFI”), on May 17, 2021 (Consent Order Number S-21-3”Page 23 of the 2025 FDD, Item 3

  Outcome:“The Consent Order required SwimLabs & Rehab Holding Company, Inc. to pay $500 to DFI. SwimLabs & Rehab Holding Company, Inc. is not affiliated with us in any way. Disclos”

• New York v. Dunkin' Brands, Inc.

  concluded

  Government or regulatory action · Dunkin' Brands, Inc. · filed 2019-09-26 · N.Y. Supreme Court for New York County · 451787/2019

  “In this matter, the N.Y. Attorney General (“NYAG”) filed a lawsuit against our affiliate, DBI, related to credential-stuffing cyberattacks during 2015 and 2018. The NYAG alleged that the cyber attackers used individuals’ credentials obtained from elsewhere on the Internet to gain access to certain information for DD Perks custom”Page 24 of the 2025 FDD, Item 3

  Outcome:“Under the consent order, DBI agreed to pay $650,000 in penalties and costs, issue certain notices and other types of communications to New York customers, and maintain a comprehensive information security program through September 2026, including pre”

• The People of the State of California v. Arby's Restaurant Group, Inc.

  settled

  Government or regulatory action · Arby's Restaurant Group, Inc. · filed 2019-03-19 · California Superior Court, Los Angeles County · 19STCV09397

  “On March 11, 2019, our affiliate, Arby’s Restaurant Group, Inc. (“ARG”), entered into a settlement agreement with the states of California, Illinois, Iowa, Maryland, Massachusetts, Minnesota, New Jersey, New York, North Carolina, Oregon and Pennsylvania. The Attorneys General in these states sought information from ARG on its us”Page 23 of the 2025 FDD, Item 3

  Outcome:“Under the settlement agreement, ARG paid no money but agreed (a) to remove the disputed provision from its franchise agreements (which it had already done); (b) not to enforce the disputed provision i”

• The People of the State of California v. Dunkin' Brands, Inc.

  settled

  Government or regulatory action · Dunkin' Brands, Inc. · filed 2019-03-19 · California Superior Court, Los Angeles County · 19STCV09597

  “On March 14, 2019, our affiliate, Dunkin Brands, Inc. (“DBI”), entered into a settlement agreement with the Attorneys General of 13 states and jurisdictions concerning the inclusion of “no-poaching” provisions in Dunkin’ restaurant franchise agreements. The settling states and jurisdictions included California, Illinois, Iowa, M”Page 23 of the 2025 FDD, Item 3

  Outcome:“the action was closed after the court approved the parties’ stipulation of judgment. New York v. Dunkin’ Brands, Inc. (N” (page 24)