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IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF OHIO 

EASTERN DIVISION 

PREMIER DEALER SERVICES,

 INC., 

Plaintiff, 

v. 

ALLEGIANCE 

ADMINISTRATORS, LLC, et al.,

 Defendants. 

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Case No. 2:18-cv-00735-EAS-CMV

Chief Judge Edmund A. Sargus 

Magistrate Judge Chelsey M. 

Vascura 

SECOND AMENDED 

COMPLAINT FOR MONETARY, 

INJUNCTIVE AND OTHER 

RELIEF, WITH JURY DEMAND 

ENDORSED HEREON 

NOW COMES Premier Dealer Services, Inc., and for its Second Amended 

Complaint against Defendants Allegiance Administrators, LLC, and Dimension Service 

Corporation, hereby alleges as follows: 

1. Plaintiff, Premier Dealer Services, Inc. (“Premier”), is an Illinois 

corporation having its principal office in Dublin, Franklin County, Ohio. Premier is in 

the business of providing products and services to automotive dealerships, agents and 

their customers. 

2. Defendant Dimension Service Corporation (“Dimension”), is an Ohio 

corporation having its principal place of business in Dublin, Franklin County, Ohio. 

Defendant Allegiance Administrators, LLC (“Allegiance”), is an Ohio limited liability 

company having its principal place of business in Dublin, Franklin County, Ohio. On 

information and belief, Allegiance was created by the merger of Dimension and other 

entities controlled by Haytham ElZayn. 

3. Since approximately 1998, Premier has been in the business of creating, 

marketing, and administering vehicle service contracts, customer loyalty programs, and 

other products for automobile dealers. 

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4. Over the last 18 years, Premier has done extensive business with a 

Canadian company known as Tricor Automotive Group, Inc. (“Tricor”). Tricor provides 

services to scores of automobile dealerships across Canada (the “Tricor Dealers”). 

Tricor offered affiliated dealers various “Programs” which they, in turn, could sell to 

customers buying new or used vehicles. The Programs included: (a) Vehicle Services 

Agreements, purchased by consumers to provide mechanical coverage in the event of 

breakdown of their vehicle; (b) Mechanical Breakdown Insurance, purchased by 

consumers to provide for mechanical coverage in the event of breakdown of their 

vehicle; (c) Mechanical Limited Warranties, provided to vehicle purchasers at no charge 

by dealerships to provide for mechanical coverage in the event of breakdown of their 

vehicle; and (d), Loyalty Powertrain Products, discussed in more detail below. 

5. During the course of its work, Premier assembled possession of 

information about the repairs that were made to the vehicles of customers who bought 

service contracts in the United States. Those customers submitted claims; repair bills 

were generated and covered claims were paid. That paperwork contained raw, 

unprocessed data about thousands of customers (the “Raw Data”). 

6. The Raw Data was never in the public domain. 

7. In 2006, Premier undertook a major effort to analyze the Raw Data as well 

as other historical loss data for its Vehicle Service Contracts in U.S. markets. Premier 

developed a methodology that analyzed many years of repair costs experienced relative 

to a host of variables, including without limitation make of vehicle, model of vehicle, 

year of manufacture, odometer, nature, scope and duration of any manufacturer’s 

warranty, the customer’s chosen coverage level, and the customer’s chosen coverage 

duration (the “Rating Process”). 

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8. Using the Rating Process, Premier was able to make reliable predictions 

about how much money needed to be set aside for future repairs in any of the thousands 

of possible permutations of the variables (the “Reserves” or “Rates”). “Reserves” are the 

proprietary component of the retail cost of a Service Contract, i.e., the portion of the 

amount paid by the customer that is set aside to be used to pay losses under these 

agreements. Premier’s Rating Process and its fruits—the Reserves or Rates—shall be 

referred to collectively as “Premier’s Trade Secrets.” The Raw Data does not contain the 

Reserves. The Reserves are the product of working the Raw Data. 

9. This project was a complete revamping of how Premier looked at vehicle 

service contracts. Because the project was so important, Premier dedicated significant 

time, resources, and effort to its completion. Premier’s team included three principal 

analysts who worked full time on the project for approximately six months. Premier 

invested tens of thousands of dollars in its completion. 

10. In 2008, Premier further modified the Rating Process to accommodate 

differences in the Canadian market. Through additional labor, Premier adapted this 

Rating Process and the Rates/Reserves it yielded in 2006 for the Canadian market. 

Premier launched this program in 2008. 

11. Through this labor, Premier has developed expertise in the business and 

has developed and maintained its competitive advantage in the marketplace in part 

through these proprietary systems and information. Premier’s rating process enabled 

Programs to be marketed at attractive pricing while that accurately addressing costs and 

risks. 

12. Premier’s competitors in the business of creating, marketing and 

administering vehicle service contracts must also calculate Reserves for their products, 

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e.g., how much money is to be set aside if a customer purchases a five-year service 

contract on a 2015 Nissan Sentra with 30,000 miles on the odometer. While 

competitors will apply similar principles, the process nevertheless involves professional 

judgments and each competitor must answer such questions independently. Premier, 

like other competitors, jealously guards its Trade Secrets. Allegiance considers its own 

rating process so secret that it brought an action to prevent its use by others but a few 

years ago. 

13. Premier took reasonable efforts to protect the secrecy of its Trade Secrets. 

a. Premier’s Trade Secrets are unknown outside the company except 

by persons who have executed a binding non-disclosure agreement. 

b. Premier’s Trade Secrets are unknown within the company except by 

employees in Premier’s Rate Department and to them only after they have executed a 

non-disclosure agreement. 

14. Premier’s Trade Secrets have value by being unknown to Premier’s 

competitors. As Allegiance’s Chief Executive Officer has stated in sworn pleadings in 

another action, “this information gives economic advantage to the person with 

knowledge of it. It is unknown to the general public, is not readily ascertainable by 

proper means by persons or entities who have derived economic value from its 

disclosure and use and was developed . . . with great effort and at great cost for its 

exclusive benefit.” 

15. It would take an inordinate amount of time and expense for a competitor 

to acquire and duplicate Premier’s Trade Secrets. As Defendant Dimension has stated in 

similar litigation, a competitor would have otherwise “to spend years and thousands of 

dollars building this data and perfecting the procedures.” 

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16. Premier and Tricor entered into a Private Label Marketing Agreement in 

2011, a true copy of which is attached at Exhibit D (“the 2011 Agreement”). Pursuant 

to the 2011 Agreement, Premier developed the vehicle service contract forms and 

marketing materials which Tricor sold under its private label “Tricare.” 

17. Section 5.2 of that 2011 Agreement states: 

[Tricor] acknowledges that all information obtained in the scope 

of its agency relating but not limited to the following: trade 

secrets, marketing strategy, customer lists, product performance 

data, past requirements of customers, and methods of doing 

business, to the extent that such information is not generally 

known by competitors, shall be deemed Proprietary 

Information of Premier and its insurer. As a condition of 

this authorization and thereafter, [Tricor] agrees not to make 

use of or disclose to any third parties, any Proprietary 

Information obtained as a result of or in connection with the 

relationship contemplated herein. All computer systems, 

procedures, forms, controls, methods, programs, software, 

hardware, reports, compilations, used or developed while an 

agent of Premier are the exclusive property of Premier or 

its insurer and may not be shared, sold, disclosed in any 

manner either during the term of this Agreement or at any other 

time thereafter. (Emphasis supplied). 

18. Similarly, Section 7.6 of the 2011 Agreement states: 

Intellectual Property. . . . All forms, records and supplies 

including, but not limited to insurance forms and rate charts, 

provided by Premier [per section 2.4], are and will remain the 

property of Premier, and will be surrendered to Premier 

immediately upon demand of Premier. . . . (Emphasis added). 

19. Prior to 2014, Premier served as both the Obligor and the Administrator 

for Tricor. In 2014, Tricor decided it wanted to serve as the Obligor. Those terms were 

memorialized in the October 1, 2014, “the 2014 Agreement,” a true copy of which is 

attached at Exhibit A. 

20. The 2014 Agreement defines “Confidential Information” to “mean this 

Agreement and all data, trade secrets, trademarks or marks, business information, 

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Programs, Dealer Cost, and any other information of any kind whatsoever that a 

party herein discloses, either orally or in writing, to the other party. A writing 

shall include an electronic transfer of information by electronic mail, over the Internet 

or otherwise.” (Emphasis added). Per Section XI.A of the 2014 Agreement, Tricor 

agreed to “keep all Confidential Information of [Premier] confidential.” 

21. Nothing in the 2014 Agreement superseded the provisions of the 2011 

Agreement quoted above regarding Premier’s ownership of Premier’s Trade Secrets. 

22. Nothing in the 2011 Agreement or the 2014 Agreement conveyed, 

assigned, or otherwise transferred any of Premier’s Trade Secrets to Tricor. 

23. Premier was never Tricor’s employee under either the 2011 Agreement or 

the 2014 Agreement. Irrespective of the language of the 2014 Agreement, the Reserves 

for this Premier product—which Tricor then sold under its “private label”—were always 

calculated by Premier. 

24. One of the products Premier offers is its Lifetime Powertrain Loyalty 

Program (the “Program”). The Program is designed to give a Lifetime Powertrain 

Loyalty Program Certificate (“LPLP Certificate”) to customers of participating dealers. 

Loyalty Powertrain Products are dealership “giveaway” products which promote 

customer retention and provide for mechanical coverage in the event of breakdown 

upon meeting various service requirements. Customers are required to ensure that 

certain maintenance recommended by the vehicle manufacturer be performed at the 

dealer’s service centers. Covered parts under the Program include the drive axle and its 

subcomponents, the transmission/transfer case and its subcomponents, and the engine 

and its subcomponents. Premier has been continuously using the registered service 

marks “Lifetime Powertrain Protection” and “Lifetime Engine Protection” (U.S. 

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Registration Nos. 4,116,450 and 4,116,449, respectively) in commerce since May 1, 

2008. 

25. On or about January 25, 2018, Tricor, without Premier’s knowledge or 

consent, disclosed Premier’s Trade Secrets—particularly its Reserves or Rates—to 

employees of Defendant Dimension, including without limitation Paul Miles. Allegiance 

received Premier’s Trade Secrets from Tricor in various ways, including without 

limitation, in numerous telephone conversations, e-mails, and in-person meetings, 

which took place between multiple personnel from both Tricor and Allegiance. Tricor 

provided Premier’s Trade Secrets to Allegiance in various electronic formats, including 

Adobe and Excel files. 

26. Approximately one month after the initial wrongful disclosure, Dimension 

created Allegiance. 

27. On information and belief, Dimension gave Tricor a minority interest in 

Allegiance to persuade Tricor to breach its obligation in the 2014 Agreement to give 

Premier 12-month’s notice of the termination of that exclusive agreement. 

28. Tricor accepted Defendants’ inducement and began forwarding 

transactions to Allegiance in lieu of Premier for administration. 

29. After complying with the cure provisions of the 2014 Agreement, Premier 

terminated the 2014 Agreement with Tricor on May 29, 2018. After that date, Tricor 

had no right to use Premier’s Trade Secrets. 

30. Without any lawful authority, Tricor Dealers continued to access Premier’s 

electronic portal to illicitly obtain Rates by back-dating transactions to dates prior to the 

May 29, 2018 termination. These misappropriations of Premier’s Trade Secrets 

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occurred more than 3,000 times. Defendants processed and administered transactions 

based on these misappropriations. 

31. Without Premier’s knowledge or consent, Allegiance incorporated 

Premier’s Trade Secrets into an electronic system to facilitate the ability of Tricor’s 

dealers to access Premier’s Trade Secrets via the internet. 

32. With full knowledge that Premier and Tricor had entered into the 

Administration Agreement, Defendants took various actions to replicate Premier’s 

Program without Premier’s knowledge or consent. Defendants acted in concert with the 

common objective of hijacking the Program and depriving Premier of the benefits it was 

entitled to under the Administration Agreements as the creator of the Program. 

33. Defendants sought to supplant Premier in Premier’s relationship with 

Tricor, despite Defendants’ knowledge that it could not perform the services provided by 

Premier without access to Premier’s proprietary Rating Process. On information and 

belief, Allegiance and Dimension have no comparable system in the Canadian market 

place that would enable them to make the sound business decisions yielded by Premier’s 

Trade Secrets. 

34. Defendants succeeded in persuading Tricor to breach the Administration 

Agreement with Premier, including without limitation the term therein requiring 12 

months’ notice of cancellation. As a direct result of Defendants’ actions, Premier will 

lose significant profits in an amount exceeding the jurisdictional threshold of this Court. 

35. Defendants acted with the common objective of hijacking Premier’s 

proprietary Rating Process so as to enable it to do what neither of them could not do on 

their own, i.e., to step into Premier’s shoes and profit from the relationship Premier 

cultivated over nearly two decades. 

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36. Allegiance has no physical presence in Tricor’s market in Canada. All acts 

taken by Allegiance were carried out by its employees in and about Dublin, Ohio. 

37. In engaging in this conduct, Defendants acted willfully, maliciously and in 

wanton disregard for the rights of Premier. At all times, Allegiance and Dimension have 

had actual knowledge that their conduct: was and remains unlawful; was and remains in 

contravention of Premier’s rights; and would proximately result in significant injury to 

Premier. 

38. Defendants’ conduct has caused, and, if allowed to continue, will continue 

to cause, irreparable damage to Premier’s business, reputation, and goodwill. 

Regarding these damages, Premier has no adequate remedy at law. 

39. This Court has jurisdiction over this dispute and the parties. 

40. Venue is proper in this Court. 

COUNT I 

MISAPPROPRIATION OF TRADE SECRETS 

41. Premier incorporates the preceding allegations of its Complaint as if 

rewritten verbatim herein. 

 42. Premier shared its Trade Secrets with Tricor after Tricor executed 

agreements, including without limitation the 2011 Agreement and 2014 Agreement, 

requiring Tricor to safeguard Premier’s Trade Secrets. 

43. Premier’s Trade Secrets derive independent economic value by not being 

accessible to Premier’s competitors, who can profit from its use or disclosure. 

44. Premier has taken all reasonable measures under the circumstances to 

maintain the secrecy of Premier’s Trade Secrets, including by having third parties sign 

agreements requiring that such information be kept confidential. 

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45. Premier’s Trade Secrets are entitled to protection as such under Ohio 

Revised Code §1333.61 et seq. 

46. On and after January 25, 2018, Tricor wrongfully disclosed, and 

Defendants wrongfully accepted, Premier’s Trade Secrets, i.e., Premier’s Reserves and 

Rates. 

47. As veteran competitors in the vehicle service contract business, 

Defendants at all times well knew that administrators calculate reserves for their 

customers and treat these calculations as their own trade secrets. Like Premier, 

Defendants considers this kind of information such a valuable trade secret that 

Defendant Dimension has sued to protect it. 

48. At the time Tricor disclosed Premier’s Trade Secrets to Defendants, 

Defendants had actual or constructive knowledge that the information provided by 

Tricor was Premier’s Trade Secrets. 

49. At the time Tricor disclosed Premier’s Trade Secrets to Defendants, 

Defendants had actual or constructive knowledge that the information provided by 

Tricor was being disclosed without the knowledge or consent of Premier. 

50. At the time of Tricor’s disclosure and/or Defendants’ use of Premier’s 

Trade Secrets, Defendants knew or had reason to know that Tricor was under a 

contractual obligation to maintain the secrecy of Premier’s Trade Secrets. 

51. Allegiance knows now, as it knew when it accepted the Reserve 

calculations from Tricor, that these were its competitor’s trade secrets. Defendants 

chose to accept and review them for their unfair commercial gain. 

52. On information and belief, Defendants made insignificant changes to the 

reserves to conceal the fact that the rates were based on Premier’s Trade Secrets. The 

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changes to Premier’s Rates made by Defendants were not based on any independent 

analysis of Raw Data because Tricor did not provide any Raw Data to Defendants. 

53. Defendants chose to use Premier’s Trade Secrets as the basis for creating a 

new “Rate Sheet” that would not be “disruptive” Tricor’s operations because of its 

similarities to Premier’s Rates. 

54. By the conduct described above, Defendants willfully misappropriated 

Premier’s Trade Secrets. 

55. The foregoing conduct of Defendants, including, but not limited to, the 

misappropriation and commercial exploitation of Premier’s Trade Secrets, constitutes 

an actual, as well as threatened, misappropriation and misuse of Premier’s trade secretprotected information under Ohio Revised Code §1333.61, et seq. 

56. Defendants are liable to Premier for their receipt and exploitation of 

Premier’s Trade Secrets, because, at the times of such disclosures and exploitation, 

Defendants knew that their awareness of these trade secrets was derived from and 

through persons who owed duties to Premier to maintain their secrecy, and limit their 

use. 

57. Allegiance is a competitor of Premier. Allegiance serves customers other 

than Tricor across the United States. By wrongfully obtaining Premier’s Trade Secrets, 

Defendants have obtained an unfair commercial advantage in the marketplace, not only 

in Tricor’s market but throughout the United States as well. 

58. Premier is entitled to recover damages from Defendants for the actual 

losses caused by its trade secret misappropriation. Premier is unable to ascertain, at 

present, the full extent of the losses suffered as a result of Defendants’ conduct, or the 

extent to which Defendants have been unjustly enriched. 

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COUNT II 

COPYRIGHT INFRINGEMENT 

59. Premier incorporates the preceding allegations of its Complaint as if 

rewritten verbatim herein. 

60. Premier is the exclusive owner of copyrighted forms for use in its business, 

including the LPLP Certificate. A true copy of Premier’s LPLP Certificate is attached as 

Exhibit C, at 3. 

61. Premier registered its copyright with the U.S. Copyright Office and was 

assigned Registration Number TX7-741-273 (the “’273 Registration”). A true copy of the 

‘273 Registration for the LPLP Certificate is attached as Exhibit C, at 1-2. The ‘273 

Registration reflects a date of first publication of June 26, 2012. The ‘273 Registration is 

a derivative work of Premier’s prior Lifetime Powertrain Program Loyalty Certificate, 

first published May 1, 2008 and registered with the U.S. Copyright Office as 

Registration TX 7-673-553 (the ‘553 Registration). A true copy of the ‘553 Registration 

and deposit item is attached as Exhibit C, at 4-6. Collectively, the ‘273 and ‘553 

Registrations are referenced herein as the “Premier Copyrights”. 

62. Premier developed and created the LPLP Certificate. 

63. Premier never granted a license to or otherwise authorized Tricor, Tricor’s 

agents, or Tricor’s dealers to use, reproduce, create derivative works from, or distribute 

the LPLP Certificate outside of their relationship with Premier. 

64. Premier never granted a license to or otherwise authorized any party to 

create derivative works from the LPLP Certificate. 

65. Premier never granted a license to or otherwise authorized Defendants to 

use, reproduce, create derivative works from, or distribute the LPLP Certificate. 

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66. The replicated form inadvertently sent to Premier (attached hereto as 

Exhibit B, hereinafter, the “Derivative LPLP Certificate”) is strikingly similar to the 

LPLP Certificate owned and registered by Premier and attached hereto as Exhibit C. 

67. In one pertinent part, the Derivative LPLP Certificate states, under Section 

5, “Other Requirements,” the following: 

“OTHER REQUIREMENTS. . . . In addition to the maintenance 

requirements outlined above, within 90 days after the 10 year 

anniversary of the VEHICLE PURCHASE DATE, and every 5 

years thereafter (within 90 days), You are required to confirm 

that You (a) still own the vehicle; and (b) You have maintained 

Your vehicle as required. You may submit Your confirmation by 

certified mail to the following address: Confirmation Dept. PO 

Box 2082, Dublin, Ohio, 43017, USA.” 

68. The mailing address in the above paragraph appearing in the Derivative 

LPLP Certificate of Exhibit B is different from the mailing address in the original LPLP 

Certificate shown in Exhibit C. 

69. On information and belief, Allegiance owns and controls “PO Box 2082” in 

Dublin, Ohio, and acts as the repository of confirmation notices supplied by customers 

to vehicle service contracts. 

70. On information and belief, Defendants participated in the creation of the 

infringing form in Dublin, Ohio, including providing directions to the customer 

regarding the confirmation necessary to obtain the benefits of the program. 

71. On information and belief, Defendants or Tricor, distributed the 

Derivative LPLP Certificate to Tricor dealers without authorization from Premier. 

72. On information and belief, Defendants knew or had reason to know that 

the creation of the Derivative LPLP Certificate, its distribution to Tricor dealers, and its 

use, copying, and distribution by the Tricor dealers, Tricor, and Defendants in the 

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course of administering a new vehicle service program without Premier’s authorization 

was an infringement of the Premier Copyrights. 

73. On information and belief, Defendants actively and materially participated 

with Tricor in causing or inducing the Tricor Dealers to copy and distribute the 

Derivative LPLP Certificate in the course of administering vehicle service contracts and 

Defendants profited thereby. 

74. On information and belief, Defendants actively and materially participated 

with Tricor in infringing other copyrighted works owned by Premier in the course of 

Defendants’ administration of a vehicle service contract program cloned from Premier’s 

Program, the identity of which will be confirmed in discovery. 

75. Defendants obtained a direct financial benefit from the infringement of 

the Premier Copyrights by Defendants, Tricor, and the Tricor Dealers. 

76. Upon information and belief, Defendants acts constitute violations of one 

or more of the following sections of the U.S. Copyright Act: 

a. Defendants engaged in direct infringement of the Premier 

Copyrights in violation of 17 U.S.C. §106; 

b. Defendants engaged in contributory copyright infringement of the 

Premier Copyrights by inducing, causing, or materially contributing to the infringing 

conduct of Tricor and/or Tricor dealers while Defendants knew or should have known 

the same to be an infringement; 

c. Defendants imported and/or exported infringing copyrighted works 

in violation of 17 U.S.C. §602(2); and 

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d. Defendants induced, caused, or materially contributed to the 

violation of 17 U.S.C. §602(2) by conduct of Tricor and/or Tricor dealers while 

Defendants knew or should have known the same to be a violation. 

77. Defendants’ continued activities in violation of Premier’s rights in the 

Premier Copyrights constitute continued copyright infringement. 

78. Defendants’ infringement of Premier’s exclusive rights was and is willful. 

79. Defendants infringed the Premier Copyrights copyright to obtain a 

commercial advantage in the market. 

80. As a result of Defendants’ acts of copyright infringement and the foregoing 

allegations, Premier has suffered damages in an amount to be determined at trial and is 

entitled to statutory damages under the Copyright Act. 

PRAYER FOR RELIEF 

WHEREFORE, Plaintiff Premier Dealer Services, Inc., prays for judgment 

against Defendant Allegiance Administrators, LLC, and Defendant Dimension Service 

Corporation, jointly and severally, as follows: 

A. Trial by jury on all issues so triable; 

B. Actual damages in an amount exceeding $25,000; 

C. Disgorgement per 17 U.S. Code §504(b) of any and all profits resulting 

from Defendants’ wrongful acts; 

D. An Order directing an accounting per 17 U.S. Code § 504(b) of any and all 

gains profits and advantages derived directly or indirectly from their use of 

Premier’s copyrighted material; 

E. At the election of Premier after conducting appropriate discovery, an 

Order per 17 U.S. Code §504(c)(1), requiring Defendants to pay an amount 

of statutory damages in an appropriate sum per work infringed; 

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F. That, based on the Court’s finding that Defendants acted willfully, an 

Order per 17 U.S. Code §504(c)(2), at the election of Premier after 

conducting appropriate discovery, requiring Defendants to pay an award 

of increased statutory damages in an appropriate sum per work infringed; 

H. An Order per 17 U.S. Code §505 and other law directing Defendants to pay 

Premier’s full cost, legal expenses and reasonable attorneys fees incurred 

in this action; 

I. An Order preliminarily without bond and permanently enjoining 

Defendants, their agents, representatives, officers, employees, and all 

those acting in concert therewith, to restrain and enjoin Defendants as set 

forth herein, including without limitation, regarding: (i) infringement of 

Premier’s copyrights; and (ii) further misappropriation and disclosure of 

Premier’s trade secrets; 

J. An Order requiring Defendants to return all Premier’s property; 

K. An award of punitive damages; 

L. An Award of pre- and post-judgment interest; and 

M. Such other relief as the Court deems appropriate. 

Respectfully submitted, 

/s/ Gregory J. Krabacher 

Gregory J. Krabacher (0079259) 

BRICKER & ECKLER, LLP 

100 South Third Street 

Columbus, Ohio 43215 

(614) 227-2314 

(614) 227-2390 (Fax) 

Email: GKrabacher@bricker.com 

Scott R. Thomas (0061040) 

Jason W. Chastang (0091377) 

HEMMER DEFRANK WESSELS PLLC 

250 Grandview Drive, Suite 500 

Ft. Mitchell, Kentucky 41017 

Telephone: (859) 344-1188 

Fax: (859) 578-3869 

Email: sthomas@HemmerLaw.com 

jchastang@HemmerLaw.com 

Counsel for Plaintiff 

Premier Dealer Services, Inc.

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CERTIFICATE OF SERVICE 

I hereby certify that on this 25th day of January, 2019, I electronically filed the 

foregoing with the Clerk of Court using the CM/ECF system, which will send notification 

of such filing to all parties who have appeared electronically, including without 

limitation the counsel below. There are no parties who need to be served by manual 

means. 

Christopher W. Tackett, Esq. 

Cassandra M. Dohar, Esq. 

NARDONE LIMITED

300 East Broad Street, Suite 490 

Columbus, Ohio 43215 

ctackett@nardonelimited.com 

cdohar@nardonelimited.com 

/s/ Gregory R. Krabacher 

Gregory J. Krabacher (0079259) 

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