IN THE UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CAREPATROL FRANCHISE

SYSTEMS, LLC a Delaware 

Limited Liability Company,

Plaintiff,

vs. 

KIRBY CARE, INC., A Florida

Corporation and WENDY 

KIRBY, an Individual

Defendants / 

COMPLAINT FOR INJUNCTIVE RELIEF AND DAMAGES

Plaintiff, CarePatrol Franchise Systems, LLC (“CarePatrol”), by and through its

undersigned counsel, hereby sues Defendants, Kirby Care, Inc. (“Kirby Care”) and Wendy Kirby

(“Kirby”) (collectively, “Defendants”) and alleges: 

PARTIES AND JURISDICTION

1. This Court has subject matter jurisdiction over the claims relating to the Lanham

Act (15 U.S.C. §§ 1125 et. seq.) pursuant to 28 U.S.C. § 1331 (federal subject matter 

jurisdiction) and 28 U.S.C. § 1338(a) (any act of Congress relating to trademarks). This Court 

has subject matter jurisdiction over the related state law claims under 28 U.S.C. § 1367. 

2. Venue is proper in this judicial district under 28 U.S.C. § 1391, because the

Defendant has committed acts of trademark infringement in, and/or a substantial portion of the 

events giving rise to the claims herein arose in, this Judicial District

CASE NO. 1:20 cv 22662

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3. CarePatrol is a Delaware Limited Liability Company with its principal place of 

business located at 1760 E. Pecos Road, Suite 338, Gilbert, Arizona, 85295. None of its 

members are citizens of the State of Florida.

4. CarePatrol has a legitimate business interest in protecting its substantial 

relationships with prospective or existing customers, trade secrets, valuable confidential business 

information, its goodwill throughout parts of Florida, and protecting against competition in its 

business.

5. Upon information and belief, Kirby is an individual residing in Miami-Dade

County, Florida and is otherwise sui juris.

6. Upon information and belief, Kirby Care is a Florida corporation headquartered at 

22219 SW 99 Court, Cutler Bay, FL 33190.

7. Kirby Care is a Florida entity doing business in the state of Florida. 

8. CarePatrol has engaged undersigned counsel to represent it in this action and is 

obligated to pay a reasonable fee for services rendered herein.

9. CarePatrol is entitled to recover its attorney’s fees and costs in connection with 

this litigation pursuant to Florida Statutes and pursuant to the parties’ franchise agreement, as set 

forth in greater detail below.

10. CarePatrol has complied with all conditions precedent to bringing these claims, or 

such conditions have been waived, excused or prevented.

COMMON ALLEGATIONS

11. CarePatrol is a franchisor of a network of carefully vetted and approved 

franchised businesses that provide senior care placement services throughout the United States. 

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12. To this end, CarePatrol has acquired and developed a unique management and 

business methodology for providing such services, which CarePatrol has branded as its 

“CarePatrol Senior Placement Services” (hereinafter collectively referred to as the “Services”). 

13. In order to provide the Services, CarePatrol has developed and maintained certain 

confidential information, trade secrets, formats, designs, systems, method, specifications, 

standards and procedures as well as other intellectual property rights such as trademarks, services 

marks, logos and other commercial symbols (together with the Services, collectively referred to 

as the “System”).

14. CarePatrol has streamlined the System into a licensable business operation and 

will franchise the same through individuals and entities that are qualified and approved by 

CarePatrol and subject to agreed upon terms and conditions with franchisees as set forth below. 

15. As qualified franchisees, the approved entities and individuals own and operate a 

business in a specified/select location(s) to offer the Services and otherwise benefit from the use 

of CarePatrol’s successful and proprietary System.

16. In exchange for the use of the System and license to offer CarePatrol’s Services, 

the franchisees pay to CarePatrol certain fees and royalties as further specified and agreed upon 

by the parties in a franchise agreement, as outlined below. 

The Franchise Agreement

17. Around March 12, 2014, Defendants agreed to and executed the CarePatrol 

Franchise Agreement to operate a CarePatrol business using CarePatrol’s System and operating 

as Kirby Care (the “Franchise Agreement”). The Franchise Agreement is attached hereto as 

Exhibit A1. 

 1 Pursuant to Section § 26.1, the Franchise Agreement is governed by Arizona law.

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18. Pursuant to the terms and conditions of the Franchise Agreement, CarePatrol

granted Defendants the exclusive right to own and operate a CarePatrol business for a period of 

five years within a select location in Florida, which generally included the area surrounding 

Miami-Dade County, and is more specifically identified in the Franchise Agreement (the 

“Protected Territory”). (See Franchise Agreement at § 1.10.)

19. In exchange for the use of CarePatrol’s System and the exclusive right to offer 

CarePatrol’s Services in the Protected Territory, Defendants agreed to pay CarePatrol an initial 

franchise fee upon the signing of the Franchise Agreement and thereafter royalty and service fees 

during the term of the Franchise Agreement. (See Franchise Agreement at § 5.)

20. In the event of the Franchise Agreement’s termination, Defendants were obligated 

to certain post-term requirements, including, among other things, immediately ceasing the use of 

CarePatrol’s Marks, as defined in the Franchise Agreement, and complying with all covenants 

described in Sections 12.03 and 14.01 of the Franchise Agreement. (See Franchise Agreement at 

§§ 12.03 and 14.01.)

21. More specifically, the covenants in Section 14.01 of the Franchise Agreement 

prohibits the operation of a competitive business providing competitive goods or services to 

clients who are located within a fifty (50) mile radius from the Protected Territory and from any 

franchised, CarePatrol-owned or affiliated company-owned premises during the post-term 

restricted period of two years. (See Franchise Agreement at § 14.01.)

22. Section 12.03 of the Franchise Agreement states that, upon termination of the 

Franchise Agreement, Defendants must, among other things, cease doing business under any of 

the Marks, assign all domain names and Internet directory listings that contain the Marks to 

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CarePatrol, and refrain from identifying themselves as a CarePatrol franchisee. (See Franchise 

Agreement at § 12.03.)

23. The Franchise Agreement also provides that CarePatrol “is the sole and exclusive 

owner of the Intellectual Property and the goodwill associated with the Marks,” that the use of 

CarePatrol’s Intellectual Property is derived solely from the Franchise Agreement, and that use 

of the Intellectual Property is limited to a license granted by CarePatrol during the term of the 

Franchise Agreement. (See Franchise Agreement at § 6.)

24. Currently, CarePatrol holds a registration for “Care Patrol” Reg. 3698342 and 

“CarePatrol” Reg. 5835831. These marks are valid, unrevoked, subsisting and constitute prima 

facie evidence of CarePatrol’s exclusive ownership of the trademarks. 

25. Following the completion of the Franchise Agreement’s initial five year term, 

CarePatrol sent Defendants a Notice of Franchise Non-Renewal and Termination of Agreement 

letter in May 2019, attached hereto as Exhibit B. 

26. The Notice and Termination Letter reiterated to Defendants their post-termination 

obligations under the Franchise Agreement. Id. 

27. Notwithstanding their obligations as described above, and more fully set forth in 

the Franchise Agreement, Defendants materially breached the Franchise Agreement by, among 

other things, operating a competitive business utilizing CarePatrol’s System in violation of 

Sections 12.03 and 14.01 of the Franchise Agreement and the Noncompetition Agreement 

attached as “Exhibit I” to the Franchise Agreement. 

28. CarePatrol discovered Defendant’s breaching conduct on several online web 

pages, which improperly advertises the operation of Kirby Care within the Protected Territory. 

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(See Exhibit C) and in violation of the Franchise Agreement. The web pages plainly list Ms. 

Kirby as an agent of Kirby Care. (Id.)

29. Further, Defendants have failed to remove co-branded advertisements and 

continue to utilize co-branded advertisements using CarePatrol’s name in direct breach of the 

Franchise Agreement. (See Exhibit D, Co-Branded Advertisements.) 

30. A search of Florida’s Department of State, Division of Corporation revealed 

Kirby Care’s active status as of February 2020. (See Exhibit E, Florida Entity Search)

31. After CarePatrol’s discovery of the unauthorized continuation of the competitive 

business, CarePatrol sent a letter demanding that Defendants: (i) immediately cease operation of 

the CarePatrol model; (ii) immediately cease operation of Kirby Care and/or any other 

competitive business that would violate the post-termination obligations under the Franchise 

Agreement; and (iv) to contact CarePatrol’s counsel within fourteen (14) days to provide 

sufficient evidence demonstrating that the aforementioned Defendants have taken the foregoing 

action. (See Exhibit F, Cease and Desist Letter.)

32. Defendants failed and neglected to cease the infringing conduct, and further failed 

and neglected to respond to the Cease and Desist Letter or otherwise contact CarePatrol’s 

counsel to work toward a resolution of the matter. 

33. Pursuant to Sections 12.03 and 14.01 of the Franchise Agreement, Defendants’ 

continued operation of a competitive business under the CarePatrol System constitutes a material 

default under the Franchise Agreement and Noncompetition Agreement.

34. Further, Defendants’ continued and unauthorized use of CarePatrol’s Marks is an 

intentional, knowing, and wrongful infringement of CarePatrol’s Intellectual Property and 

constitutes a material breach of the Franchise Agreement. 

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Post-Termination Obligations and Noncompetition Agreement

35. Pursuant to Section 14.01 of the Franchise Agreement, Defendants agreed not to 

compete with CarePatrol upon the termination of the Franchise Agreement. The Franchise 

Agreement provides, in pertinent part:

“for two (2) years after termination [. . .] neither Franchisee, nor persons associated with 

Franchisee, including owners, managers, employees or agents, may participate directly or 

indirectly or serve in any capacity in any business engaged in the Senior Referral and 

Placement the same as, similar to, or competitive with the System. This covenant not to 

compete applies: (i) [ . . .] after termination within a fifty (50) mile radius from the 

boundary of Franchisee’s Protected Territory, and from any franchised, Franchisorowned or affiliated company-owned premises; (ii) on the Internet; and (iii) on any other 

Multi-Area Marketing channels used by Franchisor. 

(See Franchise Agreement at § 14.01.)

36. In the same way, the Nondisclosure and Noncompetition Agreement, attached to 

the Franchise Agreement as Exhibit I, provides for a similar post-termination covenant not to 

compete in a “Competitive Business,” as defined by the Nondisclosure and Noncompetition 

Agreement, for a period of two (2) years within the same geographic restrictions as Section 

14.01 of the Franchise Agreement. (See Franchise Agreement at Exhibit I, at § 5.)

37. Defendants agreed that any breach of Franchise Agreement and Noncompetition 

Agreement following the termination of the Franchise Agreement would threaten immediate and 

substantial irreparable injury to CarePatrol and would give CarePatrol the right to obtain 

immediate injunctive relief. (See Franchise Agreement at Exhibit I, at § 6.)

38. Therefore, as a result of Defendants’ continuing breaches of the Franchise 

Agreement, CarePatrol has and will continue to suffer damages, including but not limited to, loss 

of good will and loss of reputation. 

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39. Section 17.07 of the Franchise Agreement and Section 13 of the Noncompetition 

Agreement provide that in the event either party institutes legal proceedings to enforce 

provisions of either Agreement, that the prevailing party shall be entitled to recover attorneys’ 

fees and costs from the losing party. (See Franchise Agreement at § 17.07; Noncompetition 

Agreement, at § 13).

Personal Guaranty of the Franchise Agreement

40. At the time of the execution of the Franchise Agreement, Defendant Kirby 

contemporaneously executed a personal Guaranty of the Franchise Agreement (the “Guaranty”). 

(See Franchise Agreement at Attachment V). 

41. In doing so, Defendant Kirby guaranteed to CarePatrol that Defendants would 

perform each and every covenant in the Franchise Agreement and any ancillary agreement 

executed between CarePatrol and Defendants in connection with the Franchise Agreement. 

42. Specifically, Defendant Kirby agreed to the “timely performance of each term, 

covenant, and obligation of the license set forth in the CAREPATROL Franchise Agreement as 

described above.” (See Franchise Agreement at Attachment V, at § 1.01). 

43. As it relates to the non-competition provisions, Defendant Kirby “agree[d] that 

[she] shall be individually bound by the provisions of the Franchise Agreement relating to trade 

secrets, confidentiality, and non-competition.” (See Franchise Agreement at Attachment V, at § 

4.04).

44. Pursuant to the Guaranty, Defendant Kirby is personally liable for the foregoing 

breaching conduct. 

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COUNT I – BREACH OF NON-COMPETITION AGREEMENT

(Against all Defendants)

45. CarePatrol incorporates by reference the preceding allegations as if fully restated 

herein.

46. The Noncompetition Agreement is a valid and enforceable agreement which 

requires, among other things, that Defendants not own, operate, or have any interest, (as an 

owner, partner, director, officer, employee, manager, consultant, shareholder, creditor, 

representative, agent or in any similar capacity) in any competitive business. 

47. The Franchise Agreement and Noncompetition Agreement provide that 

Defendants are not to compete with CarePatrol for a period of two (2) years within the Protected

Territory, as defined in the Franchise Agreement.

48. Defendants have breached their obligations to CarePatrol under the 

Noncompetition Agreement by continuing to operate a business that provides similar or identical 

services that Defendants provided as a franchisee of CarePatrol in contravention of the Franchise 

Agreement and Noncompetition Agreement, as Defendants have not waited one (2) years from 

the termination of the Franchise Agreement to engage in a competitive business.

49. Defendants have further breached their obligations to CarePatrol under the 

Franchise Agreement and Noncompetition Agreement by operating a competitive business 

within the geographic area in which Defendants are prohibited from engaging in or operating a 

competitive business. 

50. CarePatrol performed all of its obligations to Defendants under the 

Noncompetition and Franchise Agreements.

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51. As a direct and proximate result of Defendants’ breaches of the Noncompetition 

Agreement as described herein, CarePatrol has suffered and will continue to suffer damages in 

full amounts that have yet to be determined.

52. CarePatrol will also suffer irreparable harm if Defendants are not prohibited from 

ceasing operation of their competitive business in violation of the Franchise Agreement and 

Noncompetition Agreement. 

53. Defendants’ competitive activities have resulted in direct competition with other 

CarePatrol franchisees.

54. A temporary and permanent injunction against Defendants for their continued 

breach of the Agreement is reasonably necessary to protect CarePatrol’s legitimate business 

interests. If Defendants are not immediately enjoined, CarePatrol will suffer irreparable harm. 

WHEREFORE, CarePatrol demands: (1) temporary and permanent injunctive relief 

restraining Defendants from directly and indirectly competing with CarePatrol according to the 

terms of the Franchise Agreement; (2) compensatory damages and disgorgement of profits 

resulting from CarePatrol’s breach of the Agreement; (3) entry of an order directing Defendants

to pay CarePatrol’s reasonable attorneys’ fees and costs pursuant to Fla. Stat. § 542.335(1)(k); 

and (4) such other relief as this Court deems just and appropriate.

COUNT II – BREACH OF THE FRANCHISE AGREEMENT

(Against all Defendants)

55. CarePatrol incorporates by reference the preceding allegations as if fully restated 

herein. 

56. The Franchise Agreement is a valid and enforceable agreement which requires, 

among other things, that Defendants refrain from (a) operating a competitive business within the 

Protected Territory for a period of two (2) years following the termination of the Franchise 

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Agreement; and (b) the use of CarePatrol’s Intellectual Property as set forth in the Franchise 

Agreement. 

57. CarePatrol performed all of its obligations to Defendants under the Franchise 

Agreement.

58. As stated above, Defendants’ conduct constitutes a breach of the above-described 

contractual obligations contained in the Franchise Agreement. 

59. As a direct and proximate result of Defendants’ breaches of the Franchise 

Agreement as described herein, CarePatrol has suffered and continues to suffer, irreparable 

harm. Further, CarePatrol has incurred, and continues to incur, monetary damages in a full 

amount that has yet to be determined. 

COUNT III – FEDERAL TRADEMARK INFRINGEMENT UNDER

15 U.S.C. § 1114

(Against all Defendants)

60. CarePatrol incorporates by reference the preceding allegations as if fully restated 

herein. 

61. CarePatrol has applied for and obtained registrations for its CarePatrol Marks. 

The registrations are: 3698342 and 5835831. 

62. The CarePatrol Marks are inherently distinctive, arbitrary and fanciful and has 

acquired secondary meaning. The public associates the CarePatrol Marks exclusively with 

CarePatrol’s services. This is a result of the inherent distinctiveness of the Marks and of the 

distinctiveness acquired through extensive advertising, sales, and use in commerce, throughout 

the United States in connection with CarePatrol’s services and franchise system. 

63. Despite these well-established rights, Defendants have used and continue to use, 

without CarePatrol’s authorization, CarePatrol’s Marks in connection with the operation of 

Defendants’ competitive business.

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64. Defendants’ infringing use of CarePatrol’s Marks is likely to confuse or deceive 

the public into believing, contrary to fact, Defendants’ business is sponsored, franchised, 

licensed, or otherwise approved by, or in some way connected with or affiliated with CarePatrol. 

This is especially true in light of the relatedness of the services offered by both parties, the 

marketing channels used, and the customers targeted by the parties. 

65. Defendants’ infringement of CarePatrol’s Marks is in violation of § 32 and §43(a) 

of the Lanham Act, 15 U.S.C. § 1114 and 1125(a), respectively.

66. Defendants’ misappropriation has been, and continues to be done, with the intent

to cause confusion, mistake, and to deceive consumers concerning the source and/or sponsorship 

of Defendants’ services.

67. Unless enjoined, Defendants’ infringement has caused and will continue to cause 

CarePatrol immediate and irreparable injury. Accordingly, Plaintiff is entitled to injunctive relief 

under 15 U.S.C. § 1116 because the irreparable injury is in an amount not yet ascertainable, and 

for which Plaintiff has no adequate remedy at law.

68. As a direct and proximate result of Defendants’ conduct, CarePatrol is entitled to 

damages, treble damages, statutory damages, the equitable remedy of an accounting for, a 

disgorgement of, all revenues and/or profits wrongfully derived by Defendants’ through their 

infringement and all attorney fees and costs pursuant to 15 U.S.C. § 1117.

COUNT IV- UNFAIR COMPETITION UNDER 15 U.S.C. § 1125(a)

(Against all Defendants)

69. CarePatrol incorporates by reference the preceding allegations as if fully stated 

herein. 

70. Defendants’ use of CarePatrol’s Marks is likely to cause confusion, mistake, or 

deception as to the source, origin, sponsorship, or approval of Defendants’ services

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71. Defendants’ use of CarePatrol’s Marks constitutes unfair competition within the 

meaning of Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a).

72. Defendants have engaged in acts of unfair competition with full knowledge of 

such unfair competition in violation of Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a).

73. Defendants have engaged in acts of unfair competition with the intent to cause 

confusion, mistake, and deception among the public as to the source, origin, sponsorship, or 

approval of Defendants’ services. 

74. As a result of Defendants’ actions, CarePatrol has suffered, and continues to 

suffer, irreparable harm. Further, CarePatrol has incurred monetary damages in a full amount that 

has yet to be determined. 

COUNT V – BREACH OF GUARANTY

(Against Defendant Kirby)

75. CarePatrol incorporates by reference the preceding allegations as if fully restated 

herein. 

76. At the time Defendants entered into the Franchise Agreement, they executed a 

Personal Guaranty of the Franchise Agreement (the “Guaranty”), conferring personal liability 

upon Defendant Kirbby for any breaches of the Franchise Agreement by Defendants. See 

Attachment V to Franchise Agreement.

77. The Guaranty is a valid and enforceable agreement between CarePatrol and 

Defendant Kirby. 

78. Pursuant to the Guaranty, Kirby personally guaranteed and assured the full and 

complete performance of the Defendants under the Franchise Agreement, which included the 

Noncompetition Agreement and the Post-Termination obligations. 

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79. Defendant Kirby breached the Guaranty by failing to ensure or otherwise causing 

Defendants to breach their obligations under the Franchise Agreement and Noncompetition 

Agreement. 

80. As a direct and proximate result of Defendants’ breaches of the Franchise 

Agreement, Noncompetition Agreement, and Defendant Kirby’s breaches of the Guaranty as 

described herein, CarePatrol has suffered and will continue to suffer, damages. 

COUNT VI – INJUNCTIVE RELIEF

(Against all Defendants)

81. CarePatrol incorporates by reference the preceding allegations as if fully restated 

herein. 

82. Defendants actions in using CarePatrol’s Marks and operating a competitive 

business are violations of the Franchise Agreement and Noncompetition Agreement.

83. It is probable that CarePatrol will recover from Defendants after a trial on the 

merits on its claims for breach of contract, false advertising, and trademark infringement. 

84. The Franchise Agreement, Noncompetition Agreement, and Guaranty represent 

valid and enforceable contracts. 

85. Pursuant to the Franchise and Noncompetition Agreements, Defendants were 

bound by the provision to not own, operate, or have any interest in a competitive business during 

the Post-Term Restricted Period. 

86. The Franchise Agreement also provides that CarePatrol “is the sole and exclusive 

owner of the Intellectual Property and the goodwill associated with the Marks,” that the use of 

CarePatrol’s Intellectual Property is derived solely from the Franchise Agreement, and that use 

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of the Intellectual Property is limited to a license granted by CarePatrol during the term of the 

Franchise Agreement. (See Franchise Agreement at § 6). 

87. Defendants admit in the Franchise Agreement that the terms of the restrictive 

covenant are reasonable limitations as to time, geographic area, and scope of activity to be 

restrained and do not impose a greater restraint than necessary to protect the goodwill or other 

business interest of CarePatrol. (See Attachment E to the Franchise Agreement at § 7). 

88. Defendants’ actions of utilizing the CarePatrol name and operating a competitive 

business plainly violates Defendants’ obligations under the Agreements. 

89. Defendants are unable to justify or defend their breaches and unauthorized 

conduct. 

90. As a result of the foregoing, CarePatrol and suffered, and will continue to suffer 

certain, imminent, and irreparably injury as a result of Defendants actions, and if Defendants are 

allowed to continue to operate a competitive business in violation of the Franchise Agreement 

and Noncompetition Agreement, including but not limited to, economic injury, loss of goodwill, 

harm to its business reputation, loss of standing in the community, and loss of business 

opportunities.

91. Additionally, CarePatrol stands to suffer certain, imminent, and irreparable injury 

as a result of Defendants’ co-branded advertisements which are likely to confuse or deceive the 

public into believing, contrary to fact, that the unauthorized activities of Defendants are licensed, 

franchised, sponsored, authorized, or otherwise approved by CarePatrol. These injuries include 

loss of reputation and loss of goodwill. 

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92. Defendants specifically agreed to the proprietary of injunctive relief in the 

Franchise Agreement and Noncompetition Agreement. (See Franchise Agreement at § 16.8; 

Noncompetition Agreement at § 8). 

CarePatrol requests injunctive relief requiring that all Defendants:

a. immediately cease operation of Kirby Care, Inc., and any and all operations of 

any competitive business; 

b. immediately cease any and all use of CarePatrol’s name, brand, or other 

Intellectual Property as defined in the Franchise Agreement;

c. provide a detailed accounting of Defendants’ business activities to CarePatrol in 

order for CarePatrol to receive its duly earned royalty fees. 

d. abide by any and all continuing obligations under the Franchise Agreement. 

PRAYER

WHEREFORE, for the reasons stated above, CarePatrol respectfully requests that this 

Court grant the following relief: 

a. An order enjoining and prohibiting Defendants from operating any “competitive 

business” as that term is defined and used in the Franchise and Noncompetition Agreement 

consistent with the terms therein;

b. An order enjoining Defendants, and their agents, servants, employees, and 

attorneys, from infringing upon CarePatrol’s trademarks, trade names, and other Intellectual 

Property as that term is defined and used in the Franchise Agreement.

c. An order requiring Defendants to provide to CarePatrol a detailed accounting of 

Defendants’ business activities in order for CarePatrol to receive its duly earned royalty fees;

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d. Prejudgment interest in accordance with Section 35 of the Lanham Act 15 U.S.C. 

§ 1117 and applicable law;

e. Its costs, expenses, and attorneys' fees incurred in connection with this action 

pursuant to Fla. Stat. § 542.335(1)(k) and Section 35 of the Lanham Act, 15 U.S.C. § 1117;

f. A judgment in favor of CarePatrol for actual, consequential 

and/or equitable damages incurred as a result of the breaches of the Franchise Agreement, 

Noncompetition Agreement, and Guaranty;

g. An order requiring Defendants to abide by any and all continuing obligations 

under the Franchise Agreement;

h. An order granting CarePatrol any such additional relief as this Court deems just 

and equitable. 

Respectfully submitted this 26th day of June, 2020.

DICKINSON WRIGHT PLLC

350 East Las Olas Blvd., Suite 1750

Fort Lauderdale, FL 33301

Tel.: (954) 991-5420

Fax: (844) 670-6009

Vijay G. Brijbasi

Alan J. Perlman, Esq.

Florida Bar No. 826006

aperlman@dickinsonwright.com

Vijay G. Brijbasi, Esq.

Florida Bar No. 15037

vbrijbasi@dickinsonwright.com

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