FDD Items 3 & 4 · 2025 filing

Window Gang litigation history

What Window Gang 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: 18; Item 3, as counted in the filing

Largest settlement, franchisor's own cases: $110K; 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

18 disclosed actions across Window Gang and its affiliated PSB brands (360 Painting, RooterMan, predecessor entities), including franchisee disputes over territory/fraud claims, trademark/trade-secret suits against former franchisees, and multiple state regulatory consent orders (Maryland, Illinois, Virginia, California, Washington) for FDD disclosure/registration violations.

Item 3 (litigation) · 18 matters disclosed · 6 pending listed

Litigation cases

The franchisor and its predecessor

Pending (1)

Willett v. Window Gang, LLC and Paul Flick
pending
Brought by a franchisee · filed 2025-05-29 · U.S. District Court, Western District of Virginia · 3:25-cv-00044
“… (U.S. District Court for the Western District of Virginia, Civil Action No. 3:25-cv-00044).”Page 13 of the 2025 FDD, Item 3

Concluded (1)

Window Gang Ventures Corp. v. Gabriel Salinas, individually, The Gang Group Inc. and Window Ninjas, LLC
settled
Brought by the franchisor · Window Gang Ventures Corp. (North Carolina) - WGVC NC · filed 2018-02-01 · Superior Court Division, Carteret County, North Carolina · 18-CVS- 107
“… filed February 1, 2018 in the General Court of Justice Superior Court Division (Case No 18-CVS- 107) State of North Carolina County of Carteret.”Page 18 of the 2025 FDD, Item 3
Outcome: “The parties subsequently entered into a Settlement Agreement effective October 15, 2019 in which Plaintiff will be paid $110,000.” (page 19)

Parent, affiliates, master franchisor and subfranchisor

Pending (5)

360 Painting, LLC v. Chshelokovskiy, et al.
pending
Brought by the franchisor · 360 Painting, LLC (our affiliate) · filed 2025-05-07 · U.S. District Court, Western District of Virginia · 3:25-cv-00032
“… (U.S. District Court for the Western District of Virginia, Civil Action No. 3:25-cv-00032).”Page 13 of the 2025 FDD, Item 3
Rooterman, LLC v. Klodian Belegu, et al.
pending
Rooterman, LLC (our affiliate) · filed 2024-12-16 · American Arbitration Association, Boston · 012400090057
“in Rooterman, LLC v. Klodian Belegu, et al. (American Arbitration Association, Boston Office, Case No. 012400090057), on December 16, 2024, PSB’s subsidiary Rooterman, LLC filed an arbitration case against the same former franchisee Klodian Belegu and Quality”Page 15 of the 2025 FDD, Item 3
Rooterman, LLC v. Klodian Belegu, et al.
pending
Brought by the franchisor · Rooterman, LLC (PSB's subsidiary, our affiliate) · filed 2024-12-05 · U.S. District Court, District of Massachusetts · 1:24cv- 13015
“… (U.S. District Court, District of Massachusetts, Case No. 1:24cv- 13015). On December 5, 2024, PSB’s subsidiary Rooterman, LLC filed a lawsuit and sought a preliminary injunction against former franchisee Klodian”Page 15 of the 2025 FDD, Item 3
360 Painting, LLC v. Glenn A. Misiph et. al.
pending
Brought by the franchisor · 360 Painting, LLC (our affiliate) · filed 2022-09-27 · U.S. District Court, Western District of Virginia · 3:22-cv-00056-NKM
“… (U.S. District Court, Western District of Virginia, Case No. 3:22-cv-00056-NKM).”Page 14 of the 2025 FDD, Item 3
Glenn Misiph et. al. v. 360 Painting, LLC et. al.
pending
Brought by a franchisee · 360 Painting, LLC (affiliate), Premium Service Brands, LLC (parent) and Paul Flick · filed 2022-10-18 · U.S. District Court, District of Massachusetts · 1:22-cv-11778-AK
“… (U.S. District Court, District of Massachusetts, Case No. 1:22-cv-11778-AK).”Page 14 of the 2025 FDD, Item 3

Concluded (11)

In the Matter of 360 Painting, LLC, and Paul Flick
concluded
Government or regulatory action · 360 Painting, LLC (our affiliate) and Paul Flick · filed 2022 · Securities Commissioner of Maryland · 2022-0226
“… Administrative Proceeding Before the Securities Commissioner of Maryland, Case No. 2022-0226.”Page 18 of the 2025 FDD, Item 3
In the matter of determining whether there has been a violation of the Franchise Investment Protection Act of Washington by: 360 Painting, LLC, and In the matter of determining whether there has been a violation of the Franchise Investment Protection Act of Washington by: Pro-Lift Doors Franchise, L
concluded
Government or regulatory action · 360 Painting, LLC and Pro-Lift Doors Franchise, LLC (our affiliates) · filed 2022-10-04 · Washington Department of Financial Institutions, Securities Division · S-22-3399-22-CO01
“In the matter of determining whether there has been a violation of the Franchise Investment Protection Act of Washington by: 360 Painting, LLC, and In the matter of determining whether there has been a violation of the Franchise Investment Protection Act of”Page 18 of the 2025 FDD, Item 3
360 Painting, LLC v. The DeGregorio, LLC, et al.
settled
Brought by the franchisor · 360 Painting, LLC (our affiliate) · filed 2021-08-27 · U.S. District Court, Northern District of Illinois, Eastern Division · 1:21-cv-04577
“… (U.S. N.D. Ill., East. Div., Case # 1:21-cv-04577). Filing date: August 27, 2021. 360 Painting, LLC filed a Complaint against former franchisee Greg DeGregorio and several associated corporate entities based”Page 15 of the 2025 FDD, Item 3
Outcome: “pursuant to which 360 Painting paid $21,000. An agreed dismissal order requesting a dismissal of all claims with prejudice was entered by the Court on January 11, 2022.”
In The Matter of the Commissioner of Financial Protection and Innovation v. 360 Painting, LLC, Pro-Lift Doors Franchise, LLC, Maid Right, LLC, Handyman Pro, LLC, Kitchen Wise, LLC, Renew Crew, LLC, Rubbish Works, LLC, and Paul Flick, an individual
concluded
Government or regulatory action · 360 Painting, LLC, Pro-Lift Doors Franchise, LLC, Maid Right, LLC and other affiliates, and Paul Flick · filed 2021-11-19 · California Department of Financial Protection and Innovation · File Origination ID 33649, 26267, 110487, 293487, 292987, 339827, 99696, 365318, 403947
“In The Matter of the Commissioner of Financial Protection and Innovation v. 360 Painting, LLC, Pro-Lift Doors Franchise, LLC, Maid Right, LLC, Handyman Pro, LLC, Kitchen Wise, LLC, Renew Crew, LLC, Rubbish Works, LLC, and Paul Flick, an individual,”Page 17 of the 2025 FDD, Item 3
Commonwealth of Virginia, ex. rel. State Corporation Commission v. 360 Painting, LLC
settled
Government or regulatory action · 360 Painting, LLC (our affiliate) · filed 2020 · Virginia State Corporation Commission · SEC-2020-00055
“In the matter of Commonwealth of Virginia, ex. rel. State Corporation Commission v. 360 Painting, LLC, No. SEC-2020-00055, investigation by the Virginia State Corporation Commission.”Page 17 of the 2025 FDD, Item 3
In the Matter of 360 Painting, LLC
concluded
Government or regulatory action · 360 Painting, LLC (our affiliate) · filed 2020 · Illinois Attorney General · 20-AVC-F001
“… No. 20-AVC-F001, investigation by Illinois Attorney General’s Office. In January 2020, the Illinois Attorney General’s Office began an investigation of potential violations of the Illinois Franchise Disclosure Act by 360”Page 17 of the 2025 FDD, Item 3
Deborah Carreno v. 360 Painting, LLC, et al.
settled
Brought by a franchisee · 360 Painting, LLC (our affiliate) · filed 2019-11-22 · U.S. District Court, Southern District of California · 19cv2239-LAB-BGS
“… (U.S. District Court, Southern District of California, Case No. 19cv2239-LAB-BGS).”Page 15 of the 2025 FDD, Item 3
Outcome: “pursuant to which 360 Painting agreed to pay Plaintiff $57,500. Both parties claims were dismissed with prejudice by Order dated November 18, 2021.” (page 16)
Dispatch Technologies, Inc. v. Premium Service Brands, LLC
settled
Brought by a third party · Premium Service Brands, LLC (PSB) · filed 2019-03-29 · Superior Court, Suffolk County, Massachusetts · 1984CV01003
“… (case #1984CV01003, The Superior Court, Suffolk County, Trial Court of Massachusetts, filed March 29, 2019).”Page 16 of the 2025 FDD, Item 3
Outcome: “The parties settled on May 20, 2019 with Premium Service Brands, LLC agreeing to pay $190,000 to mutually terminate the contract and be able to pursue a new CRM vendor.”
YP, LLC d/b/a yellowpages.com, LLC v. 360 Painting, LLC
settled
Brought by a third party · 360 Painting, LLC (our affiliate) · filed 2017-07-17 · Superior Court of Dekalb County, Georgia · 17CV7398
“… (case # 17CV7398, Superior Court of Dekalb County, State of Georgia, filed July 17, 2017).”Page 16 of the 2025 FDD, Item 3
Outcome: “The parties settled all claims with 360 Painting, LLC agreeing to pay (via installments) $21,000 of the alleged $37,765.19 outstanding principal account balance due, and the lawsuits were mutually dismissed on August 27, 2018.”
In the Matter of 360 Painting, LLC f.k.a. 360 Painting, Inc., and Paul Flick
concluded
Government or regulatory action · 360 Painting, LLC (our affiliate) and Paul Flick · filed 2016-02-23 · Securities Commissioner of Maryland · 2015-0477
“… Administrative Proceeding Before the Securities Commissioner of Maryland, Case No. 2015-0477, as modified by Order Modifying Consent Order dated January 4, 2017.”Page 16 of the 2025 FDD, Item 3
MMG-360 LLC, et al. v. Paul Flick, Home Service Franchising, Inc., 360 Painting LLC, Maintenance Made Simple LLC, et al.
settled
360 Painting LLC (affiliate), Paul Flick and related entities · filed 2011-04-06 · Court of Common Pleas, Cuyahoga County, Ohio · CV-11-752725
“MMG-360 LLC, et al. v. Paul Flick, Home Service Franchising, Inc., 360 Painting LLC, Maintenance Made Simple LLC, et al.”Page 16 of the 2025 FDD, Item 3
Outcome: “the parties signed a formal settlement agreement dated May 26, 2020 under which Defendants paid $100,000 to Plaintiffs on June 2, 2020 in exchange for full general releases.”

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.

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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