Case 2:21-cv-12532-DML-APP ECF No. 1, PageID.1 Filed 10/28/21 Page 1 of 18
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`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF MICHIGAN
`Southern Division – Detroit
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`LITTLE CAESAR ENTERPRISES,
`INC.,
`a Michigan corporation, and
`
`LC TRADEMARKS, INC.,
`a Michigan corporation,
`
`Plaintiffs,
`
`v.
`
`GULL 5, INC.,
`an Illinois limited liability company,
`
`SAIRH5, LLC,
`an Illinois limited liability company,
`
`SAIR ALI,
`an Illinois citizen, and
`
`UMBREEN JAYED,
`an Illinois citizen,
`
`Defendants.
`
`Case No. 2:21-cv-12532
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`COMPLAINT
`
`Plaintiffs Little Caesar Enterprises, Inc. and LC Trademarks, Inc.
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`(collectively, “Little Caesar”) bring this action for breach of contract, trademark
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`infringement, unfair competition, and trade dress infringement. Little Caesar has
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`terminated its Franchise Agreements with Defendants based on Defendants’ breach
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`of those Agreements by failing to provide multiple financial statements to Little
`
`Caesar. Despite the terminations, Defendants continue to hold themselves out as
`
`
`
`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF MICHIGAN
`Southern Division – Detroit
`
`LITTLE CAESAR ENTERPRISES,
`INC.,
`a Michigan corporation, and
`
`LC TRADEMARKS, INC.,
`a Michigan corporation,
`
`Plaintiffs,
`
`v.
`
`GULL 5, INC.,
`an Illinois limited liability company,
`
`SAIRH5, LLC,
`an Illinois limited liability company,
`
`SAIR ALI,
`an Illinois citizen, and
`
`UMBREEN JAYED,
`an Illinois citizen,
`
`Defendants.
`
`Case No. 2:21-cv-12532
`
`COMPLAINT
`
`Plaintiffs Little Caesar Enterprises, Inc. and LC Trademarks, Inc.
`
`(collectively, “Little Caesar”) bring this action for breach of contract, trademark
`
`infringement, unfair competition, and trade dress infringement. Little Caesar has
`
`terminated its Franchise Agreements with Defendants based on Defendants’ breach
`
`of those Agreements by failing to provide multiple financial statements to Little
`
`Caesar. Despite the terminations, Defendants continue to hold themselves out as
`
`
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`Case 2:21-cv-12532-DML-APP ECF No. 1, PageID.2 Filed 10/28/21 Page 2 of 18
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`LITTLE CAESARS franchisees.
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`Defendants’ continued, unauthorized use and enjoyment of Little Caesar’s
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`confidential business system and the LITTLE CAESARS trademarks, trade name,
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`and trade dress breaches the Franchise Agreements and violates the Lanham Act, 15
`
`U.S.C. §§ 1114, et seq. Little Caesar seeks injunctive, monetary, and other relief
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`against Defendants for the reasons set forth below.
`
`THE PARTIES
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`1.
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`Plaintiff Little Caesar Enterprises, Inc. is a Michigan corporation with
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`its principal place of business in Detroit, Michigan. It is engaged in the business of
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`franchising independent businesspersons to operate LITTLE CAESARS restaurants
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`throughout the United States. Little Caesar’s franchisees are licensed to use the
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`LITTLE CAESARS trade name, trademarks, and service marks and to operate under
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`the LITTLE CAESARS System, which involves the production, merchandising, and
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`sale of pizza, chicken wings, and related products utilizing special equipment,
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`equipment layouts, interior and exterior accessories, identification schemes,
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`products, management programs, standards, specifications, proprietary marks, and
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`information.
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`2.
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`Plaintiff LC Trademarks, Inc. is a Michigan corporation with its
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`principal place of business in Detroit, Michigan. LC Trademarks, Inc. is the owner
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`of the trademark, service mark, and trade name “LITTLE CAESARS,” and related
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`2
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`Case 2:21-cv-12532-DML-APP ECF No. 1, PageID.3 Filed 10/28/21 Page 3 of 18
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`marks. It licenses these marks to Plaintiff Little Caesar Enterprises, Inc., which in
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`turn licenses them to LITTLE CAESARS franchisees.
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`3.
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`Defendant Gull 5, Inc. is an Illinois corporation with a principal place
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`of business in Harvard, Illinois. Gull 5 owned and operated one LITTLE CAESARS
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`franchise located in Harvard (Store Nos. 1948-0001), pursuant to a Franchise
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`Agreement with Little Caesar. The owner of Gull 5 is Defendant Sair Ali, a citizen
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`and resident of Illinois.
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`4.
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`Defendant SAIRH5, LLC is an Illinois limited liability company with
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`a principal place of business in Marengo, Illinois. SAIRH5 owned and operated one
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`LITTLE CAESARS franchise located in Marengo (Store Nos. 1948-0002), pursuant
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`to a Franchise Agreement with Little Caesar. The sole member of SAIRH5 is
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`Defendant Sair Ali, a citizen and resident of Illinois.
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`5.
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`Defendant Sair Ali is a natural person and a citizen and resident of the
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`State of Illinois. He is the owner of Gull 5 and SAIRH5 and personally guaranteed
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`their obligations under their Franchise Agreements with Little Caesar pursuant to
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`executed personal guarantees.
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`6.
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`Defendant Umbreen Jayed is a natural person and a citizen and resident
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`of the State of Illinois. Umbreen Jayed personally guaranteed the obligations of Gull
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`5 and SAIRH5 under their Franchise Agreements with Little Caesar pursuant to
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`executed personal guarantees.
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`3
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`Case 2:21-cv-12532-DML-APP ECF No. 1, PageID.4 Filed 10/28/21 Page 4 of 18
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`7.
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`Defendants Gull 5, Inc., SAIRH5, LLC, Sair Ali, and Umbreen Jayed
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`are collectively referred to as “Gull 5.”
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`JURISDICTION AND VENUE
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`8.
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`This Court has jurisdiction pursuant to §§ 34(a) and 39 of the Lanham
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`Act, 15 U.S.C. §§ 1116 & 1121; and 28 U.S.C. §§ 1331, 1332, 1338, & 1367(a). The
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`amount in controversy exceeds $75,000, exclusive of interest and costs, and no
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`defendant shares a state of citizenship with any plaintiff.
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`9.
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`This Court has in personam jurisdiction over Defendants because they
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`conduct business in this district and the events giving rise to Little Caesar’s claims
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`occurred in this district.
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`10. Venue is proper in this district pursuant to 28 U.S.C. § 1391(b) and the
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`venue provision contained in the parties’ Franchise Agreements.
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`BACKGROUND FACTS
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`Little Caesar
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`11. Plaintiff Little Caesar Enterprises, Inc. is the franchisor of the LITTLE
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`CAESARS System.
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`12. Plaintiff LC Trademarks, Inc. owns numerous federal registrations for
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`the mark “LITTLE CAESARS” and related marks. Among those registrations are
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`Registration Nos. 2036763, 2028607, 2259637, 3904450, 3925216, and others. Each
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`of these registrations is in full force and effect.
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`4
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`13. Plaintiff Little Caesar Enterprises, Inc. has the exclusive license to use
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`and to license others to use the LITTLE CAESARS marks and trade name and has
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`used them at all times relevant to this action to identify its restaurants and the pizza
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`and other products associated with those restaurants.
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`14. The trade dress of LITTLE CAESARS restaurants includes the signage,
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`lettering style, color scheme, exterior appearance, floor plans, and décor (including,
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`without limitation, menu boards, display racks, and servers’ uniforms) that are
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`featured at the restaurants operated by LITTLE CAESARS franchisees.
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`15. The LITTLE CAESARS
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`trade dress consists of arbitrary
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`embellishments primarily adopted for the purpose of identification and individuality,
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`and is nonfunctional.
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`16. The LITTLE CAESARS trademarks and trade dress are utilized in
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`interstate commerce.
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`The Parties’ Rights And Obligations Under The Franchise Agreements
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`17. Gull 5 was formerly licensed to use the LITTLE CAESARS
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`trademarks, trade name, trade dress, and business system in accordance with the
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`terms of its Franchise Agreements with Little Caesar.
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`18. Among those terms was the obligation to comply with Little Caesar’s
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`recordkeeping and reporting requirements, including but not limited to the
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`obligations to:
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`5
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`Case 2:21-cv-12532-DML-APP ECF No. 1, PageID.6 Filed 10/28/21 Page 6 of 18
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`a.
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`Prepare and preserve for at least four years, complete and
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`accurate books, records, and accounts in accordance with generally accepted
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`accounting principles and in the form and manner prescribed by Little Caesar.
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`(Franchise Agreement § 11.1.)1
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`b.
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`Provide Little Caesar with copies of financial statements
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`showing the results of the operations of its LITTLE CAESARS franchises, within
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`sixty days of the end of each fiscal year of the restaurants, in addition to state and
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`federal tax returns related to its operation of its LITTLE CAESARS franchises,
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`within five days of their filing. (Id. § 11.2.)
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`c.
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`Provide Little Caesar, on forms and in the manner prescribed by
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`Little Caesar: (i) weekly reports of gross sales; (ii) financial statements on a quarterly
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`basis, within thirty days after the end of each quarter; and (iii) such other data and
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`information regarding the operation of its LITTLE CAESARS franchises as Little
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`Caesar may require, within the time frames established by Little Caesar. (Id. § 11.3.)
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`d.
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`Provide Little Caesar, for review or auditing, such additional
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`forms, sales reports, records, information, and data as Little Caesar may reasonably
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`1 Because Gull 5’s Franchise Agreements were executed in different years, the
`wording of and/or the section numbers for the provisions cited in this Complaint
`may vary from one Franchise Agreement to the other; however, the provisions are
`materially the same for the purposes of the Complaint. For ease of reference, the
`citations contained in this Complaint can be found in Gull 5’s most recent Franchise
`Agreement (the Franchise Agreement for Franchise No. 1948-0002).
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`6
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`Case 2:21-cv-12532-DML-APP ECF No. 1, PageID.7 Filed 10/28/21 Page 7 of 18
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`request, on the forms and in the manner as are reasonably requested by Little Caesar.
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`(Id. § 11.4.)
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`19. Furthermore, Gull 5 agreed that Little Caesar had the right to audit the
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`books and records of its LITTLE CAESARS franchises at any time. (Id. § 11.5.)
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`20. Gull 5 agreed that the failure to comply with the terms of the Franchise
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`Agreements would constitute a default under the Agreements and that Little Caesar
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`had the right to terminate the Agreements if Gull 5 failed to cure a default within the
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`time required under the Agreements. (Id. § 13.3.)
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`21. Gull 5 agreed that under certain circumstances Little Caesar had the
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`right to immediately terminate the Franchise Agreements without providing an
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`opportunity to cure, including if Gull 5:
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`a.
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`Refused to permit Little Caesar to inspect its books and records
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`pursuant to Little Caesar’s right to do so under the Franchise Agreements (id.
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`§ 13.2.19); or
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`b.
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`Breached any material term of the Franchise Agreements that
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`was not by its nature curable, or that went to the essence of the Agreements (id.
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`§ 13.2.22).
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`22.
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`In addition, Gull 5 agreed that Little Caesar had the right to terminate
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`any other Franchise Agreement between Gull 5 or any of its affiliates and Little
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`Caesar in the event that a Franchise Agreement between Gull 5 or its affiliate and
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`7
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`Little Caesar was terminated for a default under that agreement. (Id. §§ 13.2.21,
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`13.4.)
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`23. Furthermore, under the terms of the Franchise Agreements, Gull 5
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`agreed that its right to use Little Caesar’s proprietary marks was limited to uses
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`authorized by the Franchise Agreements, and that “any unauthorized use thereof
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`shall constitute an infringement.” (Id. § 7.2.5.)
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`24.
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`It agreed that it would use Little Caesar’s proprietary marks, including
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`but not limited to Little Caesar’s trademarks, trade names, service marks, logos,
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`emblems, trade dress, and other indicia of origin, “only in the manner authorized and
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`permitted by Little Caesar.” (Id. § 7.2.1.)
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`25. Gull 5 was permitted to use Little Caesar’s proprietary marks only in
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`accordance with the LITTLE CAESARS System and the related standards and
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`specifications, which “underlie the goodwill associated with and symbolized by the
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`[p]roprietary [m]arks.” (Id. § 7.1.3.)
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`26. And it agreed that, during the term of the Franchise Agreements and
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`after termination, it would not take any action “which may tend to derogate or
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`jeopardize Little Caesar’s interest” in Little Caesar’s proprietary marks. (Id. § 7.3.2.)
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`Gull 5 also covenanted not to “do or perform any other act injurious or prejudicial
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`to the goodwill associated with the [p]roprietary [m]arks” and the LITTLE
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`CAESARS System. (Id. § 15.2.1.)
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`8
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`Defendants’ Post-Termination Obligations
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`27. Gull 5 agreed that, in the event that its Franchise Agreements were
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`terminated, it would “immediately cease to operate” the restaurants and would not
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`thereafter, directly or indirectly, “represent to the public or hold itself out as a present
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`or former franchisee of Little Caesar.” (Franchise Agreement § 14.1.)
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`28.
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`In addition, it agreed that it would immediately and permanently cease
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`to use, in any manner whatsoever, any products, ingredients, trade secrets,
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`confidential methods, procedures, and techniques associated with the LITTLE
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`CAESARS System and/or proprietary marks. (Id. § 14.2.)
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`29.
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`It also agreed to return to Little Caesar all of Little Caesar’s confidential
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`manuals and other confidential information. (Id. § 14.9.)
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`30. Gull 5 agreed that, upon termination of the Franchise Agreements, it
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`would not use “any designation of origin or description or representation which
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`falsely suggests or represents an association or connection with Little Caesar.” (Id
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`§ 14.5.)
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`31. And it agreed to take any actions necessary to cancel any assumed name
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`or equivalent registration that contains the LITTLE CAESARS Proprietary Marks,
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`as the term is defined in the Franchise Agreements, and to furnish evidence of
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`compliance within thirty days after the termination of the Agreements. (Id. § 14.3.)
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`32. Under the Franchise Agreements, Gull 5 agreed that, upon termination,
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`Little Caesar would have the option to purchase any or all of the furnishings,
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`equipment, signs, fixtures, or supplies related to the operation of its franchised
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`restaurants. In addition, it agreed to assign to Little Caesar, at its request, any
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`interests it had in any lease for the restaurant premises. (Id. §§ 14.4, 14.10.)
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`33. Gull 5 also agreed to a reasonable post-termination covenant against
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`competition, which states that it may not, directly or indirectly, for itself or through,
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`on behalf of, or in conjunction with any person, persons, or legal entity “own,
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`maintain, advise, operate, engage in, be employed by, make loans to, or have any
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`interest in or relationship or association with a business which is a quick or fast
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`service restaurant engaged in the sale of pizza, pasta, sandwiches, chicken wings,
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`and/or related products,” for a continuous uninterrupted period of one year following
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`the termination of the Franchise Agreements (or a final court order regarding the
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`same), in any Designated Market Area of any LITTLE CAESARS restaurant, and
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`for a continuous uninterrupted period of two years following the termination of the
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`Franchise Agreements (or a final court order regarding the same), in the Designated
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`Market Area(s) in which its former LITTLE CAESARS restaurants are located. (Id.
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`§ 15.3.) Gull 5 further agreed that breaching this and any other covenants in the
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`Franchise Agreements would cause Little Caesar irreparable injury for “which no
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`adequate remedy at law may be available, and agree[d] to pay all court costs and
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`attorneys’ fees incurred by Little Caesar in obtaining injunctive or other equitable
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`Case 2:21-cv-12532-DML-APP ECF No. 1, PageID.11 Filed 10/28/21 Page 11 of 18
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`legal relief . . . .” (Id. § 15.4.)
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`34.
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`It agreed that it would pay to Little Caesar and its affiliates all sums
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`owed, and Little Caesar’s costs, expenses, and reasonable attorneys’ fees incurred
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`by reason of any default or termination of the Franchise Agreements, or the
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`enforcement of Gull 5’s post-termination obligations. It also agreed to pay Little
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`Caesar liquidated damages. (Id. §§ 14.6, 14.7, 14.8, 15.4, 23.9.)
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`35. Pursuant to the personal guarantees attached as Exhibit A to the
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`Franchise Agreements, Defendants Sair Ali and Umbreen Jayed agreed to be
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`personally bound by the covenants and obligations of the Franchise Agreements,
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`including the obligation to pay Little Caesar and its affiliates and the obligation to
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`comply with the post-termination covenant against competition.
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`Defendants’ Defaults Under Their Franchise Agreements
`And The Termination Of Their Franchise Agreements
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`36. Over the course of 2020, Gull 5 failed to submit its quarterly financial
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`statements within thirty days after the end of the quarter as required by its Franchise
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`Agreements. By early 2021, Gull 5 had failed to submit financial statements for the
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`fourth quarter of 2019 and all of 2020.
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`37. As a result, on April 12, 2021 notified Gull 5 that it was in default of
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`its Franchise Agreements and that its Franchise Agreements would be terminated
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`unless it produced its fourth-quarter 2019 and all 2020 quarterly financial statements
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`within thirty days.
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`11
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`38. Gull 5 did not produce its fourth-quarter 2019 financial statements, nor
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`did it produce any of its 2020 quarterly financial statements, within 30 days of the
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`April 12 Notice. Accordingly, by Notice of Default and Notice of Franchise
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`Agreements Termination dated June 7, 2021, Little Caesar terminated Gull 5’s
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`Franchise Agreements effective immediately upon Gull 5’s receipt of the June 7
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`notice.
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`39. The June 7 Notice of Default and Notice of Franchise Termination
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`informed Gull 5 that Little Caesar would not enforce the termination by itself, but
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`instead would submit the matter to a court for judicial enforcement. Gull 5 elected
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`to continue to operate its franchises pending judicial enforcement of the termination.
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`40. Gull 5 continues to operate its LITTLE CAESARS franchises, in
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`violation of its post-termination obligations.
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`41. Gull 5 has also committed additional defaults of its Franchise
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`Agreements, by failing to provide quarterly financial statements for the first two
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`quarters of 2021.
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`42. Gull 5’s actions have caused and continue to cause monetary damage
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`and irreparable harm to Little Caesar, including harm to Little Caesar’s reputation
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`and goodwill.
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`12
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`Case 2:21-cv-12532-DML-APP ECF No. 1, PageID.13 Filed 10/28/21 Page 13 of 18
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`COUNT I
`Breach of Contract
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`43. The allegations of paragraphs 1 through 42 are hereby incorporated by
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`reference.
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`44. The conduct described in this Complaint constitutes material breaches
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`of the contractual provisions of the Franchise Agreements cited herein, including the
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`post-termination obligations.
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`45. These breaches constitute good cause for terminating the Franchise
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`Agreements.
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`46. As a direct and proximate result of these actions, Little Caesar has
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`suffered and is continuing to suffer irreparable injury, and has incurred and is
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`continuing to incur monetary damages in an amount that has yet to be determined.
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`COUNT II
`Trademark Infringement
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`47. The allegations of paragraphs 1 through 46 are hereby incorporated by
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`reference.
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`48. The use in commerce of Little Caesar’s trademarks and trade names by
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`the Defendants outside the scope of the Franchise Agreements and without Little
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`Caesar’s consent is likely to confuse or deceive the public into believing, contrary
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`to fact, that the unauthorized activities of the Defendants are licensed, franchised,
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`sponsored, authorized, or otherwise approved by Little Caesar. Such unauthorized
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`13
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`use of Little Caesar’s trademarks and trade names infringes its exclusive rights in its
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`trademarks under § 32 of the Lanham Act, 15 U.S.C. § 1114, and applicable state
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`law.
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`49. The acts of the Defendants were and are being done knowingly and
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`intentionally to cause confusion, or to cause mistake, or to deceive.
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`50. As a direct and proximate result of the Defendants’ actions, Little
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`Caesar has suffered and is continuing to suffer irreparable injury, and has incurred
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`and is continuing to incur monetary damages in an amount that has yet to be
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`determined.
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`COUNT III
`Unfair Competition
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`51. The allegations of paragraphs 1 through 50 are hereby incorporated by
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`reference.
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`52. The use in commerce of Little Caesar’s trademarks, trade names, and
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`trade dress by the Defendants outside the scope of the Franchise Agreements and
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`without the consent of Little Caesar is likely to cause confusion, or to cause mistake,
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`or to deceive as to the origin, sponsorship, or approval of their goods, services, or
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`commercial activities. Such unauthorized use of Little Caesar’s trademarks and trade
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`names violates § 43 of the Lanham Act, 15 U.S.C. § 1125(a), and applicable state
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`law.
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`
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`53. The acts of the Defendants were and are being done knowingly and
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`intentionally to cause confusion, or to cause mistake, or to deceive.
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`54. As a direct and proximate result of the Defendants’ actions, Little
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`Caesar has suffered and is continuing to suffer irreparable injury, and has incurred
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`and is continuing to incur monetary damages in an amount that has yet to be
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`determined.
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`COUNT IV
`Trade Dress Infringement
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`55. The allegations of paragraphs 1 through 54 are hereby incorporated by
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`reference.
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`56. The Defendants’ restaurants are
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`identified by signs, exterior
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`appearance, packaging, containers, and other items on which the LITTLE
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`CAESARS proprietary marks appear in the same distinctive style and color scheme
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`as Little Caesar uses for the pizza restaurants operated by Little Caesar’s licensees.
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`57. The Defendants’ use of trade dress that is identical or confusingly
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`similar to the LITTLE CAESARS trade dress outside the scope of the Franchise
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`Agreements constitutes a false designation of the origin of the Defendants’
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`restaurants, which is likely to cause confusion, or to cause mistake, or to deceive the
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`public as to the affiliation, connection, or association of their restaurants with the
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`LITTLE CAESARS restaurants operated by Little Caesar’s licensees. Such adoption
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`of Little Caesar’s trade dress violates § 43 of the Lanham Act, 15 U.S.C. § 1125,
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`and the common law.
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`15
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`58. The Defendants’ acts were and are being done knowingly and
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`intentionally to cause confusion, or to cause mistake, or to deceive.
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`59. As a result of the Defendants’ actions, Little Caesar has suffered and is
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`continuing to suffer irreparable injury, and has incurred and is continuing to incur
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`monetary damages in an amount that has yet to be determined.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiffs pray that this Court:
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`A.
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`Enter a declaratory judgment holding that Defendants’ conduct violated
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`the terms of the Franchise Agreements and constitutes good cause for terminating
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`the Franchise Agreements;
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`B.
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`Enter an injunctive order ratifying and enforcing the termination of the
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`Franchise Agreements as of the effective date of Little Caesar’s Notice of Franchise
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`Agreement Termination, or as otherwise provided by applicable law;
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`C.
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`Enter an order enjoining Defendants, and all those acting by, through,
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`or in concert with them, by preliminary and permanent injunction, from using the
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`LITTLE CAESARS trademarks, trade names, and trade dress, and from otherwise
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`engaging in unfair competition with Little Caesar;
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`D.
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`Enter an injunctive order directing Defendants, and all those acting by,
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`through, or in concert with them, to comply with all applicable post-termination
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`obligations as provided in the Franchise Agreements, including but not limited to
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`Case 2:21-cv-12532-DML-APP ECF No. 1, PageID.17 Filed 10/28/21 Page 17 of 18
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`promptly paying all sums owed to Little Caesar and its affiliates, complying with the
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`post-termination noncompete, complying with any request from Little Caesar to
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`purchase any equipment or other assets of the franchise, and taking all steps to
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`transfer their leasehold interests in the franchise to Little Caesar or its designee in
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`the event that Little Caesar elects to exercise any rights it or any of its affiliates or
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`subsidiaries might have in such interests;
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`E. Award Plaintiffs judgment against Defendants for the damages
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`Plaintiffs have sustained and the profits Defendants have derived as a result of their
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`trademark infringement, trade dress infringement, and unfair competition, assessing
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`such damages in a separate accounting procedure, and then trebling those damages
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`in accordance with Section 35 of the Lanham Act, 15 U.S.C. § 1117;
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`F.
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`Enter judgment in favor of Plaintiffs for the damages they have
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`suffered, including liquidated damages as provided for by the Franchise Agreements,
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`as a result of Defendants’ conduct, plus prejudgment interest allowed by law;
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`G. Award Plaintiffs their costs and attorneys’ fees incurred in connection
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`with this action, pursuant to the Franchise Agreements and Section 35 of the Lanham
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`Act, 15 U.S.C. § 1117, including the costs incurred in conducting any and all
`
`necessary inspections; and
`
`H. Award Plaintiffs such other relief in its favor as this Court may deem
`
`
`
`17
`
`
`
`Case 2:21-cv-12532-DML-APP ECF No. 1, PageID.18 Filed 10/28/21 Page 18 of 18
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`just and proper.
`
`Dated: October 28, 2021
`
`
`
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`
`
`
`
`
`
`/s/Larry J. Saylor
`
`Larry J. Saylor (P28165)
`Kimberly A. Berger (P56165)
`MILLER, CANFIELD, PADDOCK
` & STONE P.L.C.
`150 West Jefferson Avenue, Suite 2500
`Detroit, Michigan 48226
`Telephone: (313) 496-7986
`Facsimile: (313) 496-8454
`Saylor@millercanfield.com
`Berger@millercanfield.com
`
`Robert L. Zisk (admitted in E.D. Mich.)
`Justin L. Sallis (admitted in E.D. Mich.)
`LATHROP GPM LLP
`The Watergate
`600 New Hampshire Avenue, N.W. – Suite 700
`Washington, D.C. 20037
`Telephone: (202) 295-2200
`Facsimile: (202) 295-2250
`robert.zisk@lathropgpm.com
`justin.sallis@lathropgpm.com
`
`Attorneys for Plaintiffs
`
`18
`
`
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