JS 44C/SDNYREV. 4/2014

CIVIL COVER SHEET

The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service ofpleadings or other papers as required by law, except as provided by local rules of court. This form, approved by theJudicial Conference of the United States in September 1974, is required for use of the Clerk of Court for the purpose ofinitiating the civil docket sheet.

PLAINTIFFSTT'MJj

ESTATE OF SIHAK HENRY CHO

ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBERBENJAMIN LAW PC111 EAST 14TH STREET, SUITE 469NEW YORK, NY 10003 (212) 673-8350

DEFENDANTSWESTCHESTER TAE KWON DO ACADEMY, INC. AND BEHAD DAVIDMORADI

ATTORNEY:1 IWN) mCAUSE OF ACTION (CITE THEU.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEFSTATEMENT OF CAUSE)

(DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)

Federal trademark infringement and false designation of origin and unfair competition under 15 USC 1114 and 1125(a); unfair competition u

Has this action, case, orproceeding, orone essentially the same been previously filed in SDNY atany time? NdZresllludge Previously Assigned

If yes,wasthis case Vol. | | Invol. | | Dismissed. No rj Yes | | Ifyes, give date &Case No.No 0 Yes IS THIS AN INTERNATIONAL ARBITRATION CASE?

(PLACE AN [x] INONEBOXONLY)

TORTS

NATURE OF SUIT

FEB 13 201!)ACTIONS UNDER STATUTES

CONTRACT PERSONAL INJURY PERSONAL INJURY FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

[]110 INSURANCE [ 1310 AIRPLANE[ I 367 HEALTHCARE/PHARMACEUTICAL PERSONAL f , 625 DRUG RELATED [ ] 422 APPEAL I 1375 FALSE CLAIMS[J 400 STATE

[]120 MARINE [ ] 315 AIRPLANE PRODUCT INJURY/PRODUCT LIABILITY SEIZURE OF PROPERTY 28 USC 158 REAPPORTIONMENT[]130 MILLER ACT LIABILITY [ ] 365 PERSONAL INJURY 21 USC 881 [ ] 423 WITHDRAWAL [ ]410 ANTITRUST[]140 NEGOTIABLE [ J 320 ASSAULT, LIBEL & PRODUCT LIABILITY [ ] 690 OTHER 28 USC 157 [ J430 BANKS & BANKING

INSTRUMENT SLANDER [ ] 368 ASBESTOS PERSONAL [ ]450 COMMERCE11150 RECOVERY OF ( ) 330 FEDERAL INJURY PRODUCT [ ]460 DEPORTATION

OVERPAYMENT & EMPLOYERS' LIABILITY PROPERTY RIGHTS [ ] 470 RACKETEER INFLUENFORCEMENT LIABILITY ENCED & CORRUPTOF JUDGMENT [ ] 340 MARINE PERSONAL PROPERTY [ ] 820 COPYRIGHTS ORGANIZATION ACT

[ 1151 MEDICARE ACT I ] 345 MARINE PRODUCT [ ] 830 PATENT (RICO)[]152 RECOVERY OF LIABILITY [ ] 370 OTHER FRAUD M 840 TRADEMARK [ 1480 CONSUMER CREDIT

DEFAULTED [ ] 350 MOTOR VEHICLE [ ] 371 TRUTH IN LENDING [ 1490 CABLE/SATELLITE TVSTUDENT LOANS [ J 355 MOTOR VEHICLE(EXCL VETERANS) PRODUCT LIABILITY SOCIAL SECURITY [ ] 850 SECURITIES/

[]153 RECOVERY OF [ ] 360 OTHER PERSONAL COMMODITIES/OVERPAYMENT INJURY [ ] 380 OTHER PERSONAL LABOR [ ] 861 HIA (1395ff) EXCHANGEOF VETERAN'S [ J 362 PERSONAL INJURY - PROPERTY DAMAGE [ ) 862 BLACK LUNG (923)BENEFITS MED MALPRACTICE [ ] 385 PROPERTY DAMAGE [ ] 710 FAIR LABOR [ ] 863 DIWC/DIWW (405(g))

[J 160 STOCKHOLDERS PRODUCT LIABILITY STANDARDS ACT [ ] 864 SSID TITLE XVISUITS [ ] 720 LABOR/MGMT [ ] 865 RSI (405(g)) [ ] 890 OTHER STATUTORY

[]190 OTHER PRISONER PETITIONS RELATIONS ACTIONSCONTRACT [ ]463 ALIEN DETAINEE [ ] 740 RAILWAY LABOR ACT [ ] 891 AGRICULTURAL ACTS

[1195 CONTRACT [ ] 510 MOTIONS TO [ ] 751 FAMILY MEDICALLEAVE ACT (FMLA)

FEDERAL TAX SUITSPRODUCT ACTIONS UNDER STATUTES VACATE SENTENCELIABILITY 28 USC 2255 [ ] 870 TAXES (U.S. Plaintiff or [ ] 893 ENVIRONMENTAL

[ ] 196 FRANCHISE CIVIL RIGHTS [ ] 530 HABEAS CORPUS [ ] 790 OTHER LABOR Defendant) MATTERS[ ] 535 DEATH PENALTY LITIGATION [ ] 871 IRS-THIRD PARTY [ ] 895 FREEDOM OF

[ ]440 OTHER CIVIL RIGHTS [ ] 540 MANDAMUS & OTHER [ I 791 EMPL RET INC 26 USC 7609 INFORMATION ACT

REAL PROPERTY(Non-Prisoner)

I ] 441 VOTING

SECURITY ACT

IMMIGRATION

[ ] 896 ARBITRATION[ 1 899 ADMINISTRATIVE

[ 1210 LAND [ ]442 EMPLOYMENT PRISONER CIVIL RIGHTS PROCEDURE ACT/REVIEW ORCONDEMNATION [ ] 443 HOUSING/ [ ] 462 NATURALIZATION APPEAL OF AGENCY DECISION

1 ]220 FORECLOSURE ACCOMMODATIONS [ 1550 CIVIL RIGHTS APPLICATION [ ] 950 CONSTITUTIONALITY OFSTATE STATUTES

[ ]230 RENT LEASE & [ ]445 AMERICANS WITH [ ] 555 PRISON CONDITION [ ]465 OTHER IMMIGRATIONEJECTMENT DISABILITIES- [ ] 560 CIVIL DETAINEE ACTIONS

[ ]240 TORTS TO LAND EMPLOYMENT CONDITIONS OF CONFINEMENT[1245 TORT PRODUCT

LIABILITY

[ ] 446 AMERICANS WITHDISABILITIES -OTHER

[ ]290 ALL OTHERREAL PROPERTY

[ ]448 EDUCATION

Checkifdemanded in complaint:

CHECK IF THIS IS ACLASS ACTIONUNDER F.R.C.P. 23

DEMAND $_ OTHER

CheckYES only ifdemanded in complaintJURY DEMAND: 0YES QlO

QOYOU CLAJM THIS CASE IS RELATED TO A CIVIL CASENOW PENDING IN S.D.N.Y.?

JUDGE DOCKET NUMBER

NOTE: Youmust also submitat the time of filing the Statement of Relatedness form (Form IH-32).

(PLACEAN x INONEBOXONLY) ORIGIN

1*1 1 Original LJ 2 Removed from *' 3 Remanded LJ 4 Reinstated or Lj 5 Transferred from Q 6 MultidistrictProceeding state court from Reopened (Specify District) Litigation

n a. all parties represented Appellate1' Court

I | b. At leastoneparty is pro se.

(PLACEANxINONEBOXONLY) BASIS OF JURISDICTION IF DIVERSITY, INDICATE 1 U.S. PLAINTIFF 2 U.S. DEFENDANT \x\ 3 FEDERAL QUESTION 4 DIVERSITY CITIZENSHIP BELOW.

(U.S. NOT A PARTY)

CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)(Place an [X] in one box for Plaintiff and one box for Defendant)

I I 7 Appeal to DistrictJudge fromMagistrate JudgeJudgment

PTF DEFCITIZEN OF THIS STATE [ ] 1 [ ] 1

CITIZEN OF ANOTHER STATE [ ] 2 [ ] 2

CITIZEN OR SUBJECT OF AFOREIGN COUNTRY

PTF DEF[]3[]3

PTF DEFINCORPORATED and PRINCIPAL PLACE [ ] 5 [ ] 5OF BUSINESS IN ANOTHER STATE

INCORPORATED or PRINCIPAL PLACE [ ] 4 [ ] 4OF BUSINESS IN THIS STATE

PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)THE ESTATE OF SIHAK HENRY CHO423 WILDWOOD ROADNORTHVALE, NJ 07647

FOREIGN NATION []6 []6

DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)WESTCHESTER TAE KWON DO ACADEMY, INC. & BEHAD DAVID MORADI, 116 NORTH MAINSTREET, 2ND FLOOR, PORT CHESTER, NY 10573

WESTCHESTER COUNTY

DEFENDANT(S) ADDRESS UNKNOWNREPRESENTATION IS HEREBY MADETHAT, AT THIS TIME, I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN

RE9IBENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:

Checkone: THIS ACTION SHOULD BE ASSIGNED TO: [x] WHITE PLAINS MANHATTAN(DO NOT check either box if this a PRISONER PETITION/PRISONER CIVIL RIGHTSCOMPLAINT.)

DATE X It ?J I(^SIGNATURE QFvATTQRNKr, OF RECORD ADMITTED TO PRACTICE IN THIS DISTRICT[] NOHi YES (DATE ADMITTED Mo. 05 Yr. 1990 )

RECEIPT* ^\ C X

jUDGErARASAMY J. BENJAMIN (AB6886)BENJAMIN LAW PC111 EAST 14th STREETSUITE 469

NEW YORK, NEW YORK 10003Attorneysfor Plaintiff

15 CV /f) r:../ oIN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF NEW YORK

ESTATE OF SHIHAK HENRY CHO,

Plaintiff,

-against-

WESTCHESTER TAE KWON DO ACADEMY, INC. AND DAVID BEHDADMORADI AKA DAVID MORADI,

Defendants.

VERIFIED COMPLAINT

Case No.

Plaintiff, Estate of Sihak Henry Cho, for its Verified Complaint against Defendants, Westchester

Tae Kwon Do Academy, Inc., and Behad David Mirada aka David Moradi, by its undersigned attorneys

hereby alleges as follows:

"m

iO

PARTIES

1. Plaintiff, Estate of Sihak Henry Cho ("Estate" or "Plaintiff') is the Estate of the late

Grandmaster S. Henry Cho ("Grandmaster S. Henry Cho" or "Grandmaster Cho") who

resided at 423 Wildwood Road, Northvale, NJ 07647 and passed away on March 8, 2012.

Co-executors, Kenneth K. Cho and David P. Cho, are acting on behalf of the Estate pursuant

to Letters Testamentary issued by the Bergen County Surrogates Court a true and correct

copy of which is attached as Exhibit 1.

2. Grandmaster S. Henry Cho is the original creator and promoter of the nationally recognized

martial arts tournament "The All American Open Karate Tae Kwon Do Kung Fu

Championships" which has been conducted for 49 years and promoted under the trademark

ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU CHAMPIONSHIPS throughout the

country, including within this judicial district.

3. Upon information and belief, defendants Westchester Tae Kwon Do Academy, Inc.

("Westchester Academy") and Behad David Moradi aka David Moradi are a martial arts

school and individual, respectively, promoting and advertising a martial arts tournament

under the name AMERICAN OPEN MARTIAL ARTS CHAMPIONSHIPS with competitors

located nationwide and within this judicial district. Upon information and belief,

Defendants have an office or other physical presence in this judicial district located at 116

North Main Street, 2nd Floor, Port Chester, NY 10573 and maintain a telephone number at

914-251-0038.

4. Upon information and belief, Defendant Behad David Moradi aka David Moradi ("David

Moradi") is the owner and operator of Defendant Westchester Academy. Westchester

Academy and David Moradi are collectively referred to as "Defendants".

JURISDICTION AND VENUE

5. This Court has subject matter jurisdiction pursuant to 28 U.S.C. 1331,1338(a) and 1367,

and 15 U.S.C. 1121.

6. This Court has personal jurisdiction over the Defendants because, upon information and

belief, Defendants have a physical presence in this judicial district and advertise, promote

and sell tickets for a martial arts tournament in interstate commerce and within this judicial

district under the name AMERICAN OPEN MARTIAL ARTS CHAMPIONSHIPS.

7. Upon information and belief, the acts of Defendants set forth herein constitute trademark

infringement, false designation of origin and false advertising under Federal law and unfair

competition under the common law of the State of New York. Asa result of such acts,

Defendants have and continue to commit torts within this State and judicial district.

8. Venue is proper in this district under 28 U.S.C. 1391.

FACTS COMMON TO ALL COUNTS

9. Since at least as early as January 1975, Grandmaster S. Henry Cho has used the trademark

ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU CHAMPIONSHIPS in connection with

the advertising, promotion and operation of a martial arts tournaments in interstate

commerce, and the sale of merchandise, competition and spectator tickets in interstate

commerce, and in particular, in connection with martial arts competitions.

10. Grandmaster S. Henry Cho is the owner of U.S. Trademark Registration No. 3,015,207 for

the mark ALLAMERICAN OPEN KARATETAE KWON DO KUNG FU CHAMPIONSHIPS for use in

connection with organizing and conducting martial arts competitions in International Class

41. Registration No. 3,015,207 is valid and subsisting and has become incontestable

pursuant to Sections 8 and 15 of the Trademark Act, 15 U.S.C. 1058,1065. Acopy of U.S.

Registration No. 3,015,207 for the mark ALL AMERICAN OPEN KARATE TAE KWON DO KUNG

FU CHAMPIONSHIPS and a current status report are attached hereto as Exhibit 2.

11. Grandmaster S. Henry Cho's ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU

CHAMPIONSHIPS tournament has been advertised and promoted nationwide and within this

judicial district in the martial arts community for 49 years. The 50th anniversary

presentation of this tournament is scheduled for March 7, 2015 and is being advertised on

line at Grandmaster S. Henry Cho's website which is accessible through the URL

www.henrycho.com under the "Tournament" tab. Pages printed from the website about

the Tournament are attached hereto at Exhibit 3. Copies of literature including Invitation

Letters, competition registration forms and additional information that were also mailed to

martial arts instructors and schools are attached hereto at Exhibit 4.

12. Grandmaster S. Henry Cho had the foresight to create, design, and promote the ALL

AMERICAN OPEN KARATE TAE KWON DO KUNG FU CHAMPIONSHIPS tournament as an

"open" tournament with competition rules designed so that one style of martial arts would

NOT have an advantage over any other style during the competition.

13. The ALL AMERICAN OPEN KARATE TAE KWON DO KUNGFU CHAMPIONSHIPS tournament

was held in Madison Square Garden's Felt Forum for 25 years and is a rock bed of American

Martial Arts history, where Bruce Lee met Chuck Norris for the first time. Many well-known

martial artists have competed in the ALL AMERICAN OPEN KARATE TAE KWON DO FUNG FU

CHAMPIONSHIPS tournament including, but not limited to, Thomas LaPuppet, Chuck Norris,

Michael Warren, William Oliver,Gerald Robbins, Tony Blanchard, and RubyCamacho.

14. Since its inception, tens of thousands of martial arts competitors and students have

participated in the ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU CHAMPIONSHIP

tournament.

15. As a result of its 50 year history and the efforts of Grandmaster S. Henry Cho to promote

and advertise the Tournament, the trademark ALL AMERICAN OPEN KARATE TAE KWON DO

KUNGU CHAMPIONSHIPS has developed significant secondary meaning and goodwill such

that members of the Tae Kwon Do, Karate and Kung-Fu communities have come to

associate the trademark ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU

CHAMPIONSHIPS with Grandmaster S. Henry Cho exclusively. The Estate has continued to

run, promote, advertise and oversee the ALL AMERICAN OPEN KARATE TAE KWON DO

KUNG FU CHAMPIONSHIPS tournament according to the teachings, rules and ethics

established by Grandmaster S. Henry Cho in order to maintain and increase the goodwill and

secondary meaning associated with the trademark ALL AMERICAN OPEN KARATE TAE KWON

DO KUNGFU CHAMPIONSHIPS.

16. David Moradi is a former student of Grandmaster Cho who, upon information and belief,

joined Grandmaster S. Henry Cho's Tae Kwon Do school as a 2nd degree black belt from

another instructor, and started training with Grandmaster Cho in the late 1990's.

17. On November 4, 2005, Grandmaster Cho and Defendants entered into a trademark license

pertaining to the Defendants' use of the ALL AMERICAN OPEN KARATE TAE KWON DO KUNG

FU CHAMPIONSHIPS. Acopy of the November 4, 2005 trademark license (the "Trademark

License") is attached as Exhibit 5. Financial information has been redacted from the

Trademark License as it is not relevant at this time and confidential.

18. Defendants breached the terms of the Trademark License, which was terminated on

February 10, 2014. A copy of the February 10, 2014 termination letter is attached as Exhibit

6.

19. The February 10, 2014 termination letter requested a detailed accounting of the income

and expenses for the years 2009-2013. Defendants failed to respond to the February 10,

2014 letter and to date have failed to provide the financial information requested therein.

20. After termination of the Trademark Licenseon February 10, 2014, the Estate appointed a

new licensee and continued the tradition of the ALLAMERICAN OPEN KARATETAE KWON

DO KUNG FU CHAMPIONS tournament by hosting the 49th annual event on March 15, 2014

at Long Island University's Brooklyn Campus.

21. Upon information and belief, in late February and early March of 2014, Defendants made

false statements to the martial arts community falsely alleging that the March 15, 2014

event was cancelled when, in fact, the 49th annual tournament was held as scheduled.

22. Upon information and belief, on or about March 5, 2014, Defendants organized and

participated in a boycott of the March 15, 2014 event as evidenced by Michael Miller, an

associate of Defendants posting the following on Facebook: "many of us are boycotting the

event Saturday March 15th and won't return if it continues afterwards " Acopy of the

Facebook posting is attached as Exhibit 7. These actions harmed the Estate and the goodwill

associated with the mark ALLAMERICAN OPEN KARATETAE KWON DO KUNG FU

CHAMPIONSHIPS.

23. The 50th Anniversary ALL AMERICAN OPEN KARATE TAE KWON DO KUNGFU

CHAMPIONSHIPS tournament is scheduled for March 7, 2015 at Long Island University's

Brooklyn Campus.

24. Upon information and belief, Defendants deliberately scheduled a competing martial arts

tournament on February 28, 2015 exactly one week before the 50th anniversary ALL

AMERICAN OPEN KARATE TAE KWON DO KUNG FU CHAMPIONSHIPS tournament. Upon

information and belief, Defendants' competing martial arts tournament is being called the

AMERICAN OPEN MARTIAL ARTS CHAMPIONSHIP the tournament ("Infringing

Tournament"). Attached hereto at Exhibit8 is a page from Defendants' website at

www.westchestertkd.com website showing Defendants' sponsorship and advertisement of

the "Infringing Tournament".

25. Upon information and belief, the selection of the name AMERICAN OPEN MARTIAL ARTS

CHAMPIONSHIP for the InfringingTournament was made intentionally and with full

knowledge of Grandmaster Cho's rights in the mark ALL AMERICAN OPEN KARATE TAE

KWON DO KUNG FU CHAMPIONSHIPS.

26. Upon information and belief, Defendants intentionally and with intent to trade on the good

will and fame of the trademark ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU

CHAMPIONSHIPS, have used social media to create the false impression that the Infringing

Tournament is the ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU CHAMPIONSHIPS

tournament, or is approved or sponsored by Grandmaster S. Henry Cho.

27. Upon information and belief, Helen Crowell, another associate of Defendants, made and

continues to make the following false claims on Facebook. "[C]ome join me at the OPEN

MARTIAL ARTS Tournament on Sat. Feb. 28, 2015 Gaucho Gym, 478 Gerard Ave, Bronx NY

10451. Master David Moradi is doing what our great Grandmaster S. Henry Cho would want

.... Keeping our martial arts family together! I'll be remembering that this would be our

Grandmaster's 50th yr and celebrate all that he passed on to me/ us!!! Message Master

Moradi for all the details. I hope to see you all there!!!! OUS!!!!" Atrue and correct print

out of this Facebook posting is attached as Exhibit 9.

28. Upon information and belief, Bill Dewart, another associate of Defendants, made and

continues to make the following false claims on Facebook stating "... am looking forward to

being there to support Master Moradi as he continues in the footsteps of GM Cho. Iwill

look forward to seeing you and Master Lemon on February 28th. See Exhibit 9.

29. Defendants Westchester Academy and David Moradi were and continue to be well aware of

Grandmaster S. Henry Cho's trademark rights in the ALL AMERICAN OPEN KARATE TAE

KWON DO KUNG FU CHAMPIONSHIPS Trademark since they were a former licensee.

30. At no time did Grandmaster S. Henry Cho or the Estate authorize or consent to Defendant's

use of the mark ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU CHAMPIONSHIPS in

connection with the Infringing Tournament.

31. Upon information and belief, Defendants' continued unauthorized use in interstate

commerce of the mark AMERICAN OPEN MARTIALARTS CHAMPIONSHIPS for a martial arts

tournament has caused and is likelyto continue to cause the purchasing public and others

to mistakenly believe that Defendants' February 28, 2015 martial arts tournament is

associated with, sponsored or approved by Grandmaster S. Henry Cho or the Estate when

they are not.

32. The unauthorized acts of Defendants alleged herein have resulted in damage and

irreparable harm to Grandmaster S. Henry Cho and the ALL AMERICAN OPEN KARATE TAE

KWON DO KUNG FU CHAMPIONSHIPS Trademark and goodwill. Unless enjoined by this

Court, Defendants will continue their unlawful activities and continue to damage and

irreparably harm the ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU

CHAMPIONSHIPS Trademark and goodwill.

33. Grandmaster S. Henry Cho and the Estate have no adequate remedy at law.

COUNT I

INFRINGEMENT OF FEDERALLY REGISTERED TRADEMARKS UNDERSECTION 32 OF THE TRADEMARK ACT

34. The Estate repeats and realleges each of the allegations contained in paragraphs 1-33 above

as if fully set forth herein.

35. Defendants' unlawful activities complained of herein have caused and are likely to continue

to cause actual confusion, such that consumers are likelyto mistakenly believe that the

Infringing Tournament advertised and promoted by Defendants are authorized, sponsored

by or otherwise associated with Grandmaster S. HenryCho or the Estate when they are not.

36. Upon information and belief, Defendants' unlawful activities complained of herein have

been willful and intentional and in complete disregard for Grandmaster S. Henry Cho's rights

in the ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU CHAMPIONSHIPS Trademark.

37. Defendants' unlawful activities complained of herein constitute willful infringement of the

Federally registered ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU

CHAMPIONSHIPS Trademark under Section 32 of the Lanham Act, 15 U.S.C. 1114(l)(a).

38. Unless prohibited by the Court, Defendants will continue their unlawful activities

complained of herein to the continued detriment of Grandmaster S. Henry Cho and the

Estate.

39. As a result of Defendants' infringing activities, Grandmaster S. Henry Cho and the Estate

have, are and will continue to suffer irreparable harm and damage.

40. Grandmaster S. Henry Cho and the Estate have no adequate remedy at law.

COUNT II

FALSE DESIGNATION OF ORIGIN UNDER SECTION 43(a) OF THE TRADEMARK ACT

41. The Estate repeats and realleges each of the allegations contained in paragraphs 1-33

above, as if fully set forth herein.

42. Defendants' unlawful activities complained of herein have caused and are likelyto continue

to cause actual confusion, such that consumers are likelyto mistakenly believe that the

martial arts tournament advertised and promoted by Defendants are authorized, sponsored

by or otherwise associated with Grandmaster S. Henry Cho when Cho when they are not.

43. Upon information and belief, Defendants' unlawful activities complained of herein have

been willful and intentional and in complete disregard for Grandmaster S. Henry Cho's rights

in the ALLAMERICAN OPEN KARATE TAE KWON DO KUNG FU CHAMPIONSHIPS Trademark.

44. Defendants' unlawful activities complained of herein constitute willful false designation of

origin and unfair competition under Section 43(a) of the Lanham Act, 15 U.S.C. 1125(a).

45. Unless prohibited by the Court, Defendants will continue their unlawful activities

complained of herein to the continued detriment of Grandmaster S. Henry Cho and the

Estate.

46. As a result of Defendants' infringing activities, Grandmaster S. Henry Cho and the Estate

have, are and will continue to suffer irreparable harm and damage.

47. Grandmaster S. Henry Cho and the Estate have no adequate remedy at law.

10

COUNT III

UNFAIR COMPETITION AND TRADEMARK INFRINGEMENT IN VIOLATION OF THE COMMON

LAW OF NEW YORK

48. Grandmaster S. Henry Cho and the Estate repeats and realleges each of the allegations

contained in paragraphs 1-33 above as if fully set forth herein.

49. Byits unlawful actions set forth herein, Defendants have violated and infringed

Grandmaster S. Henry Cho's common law rights in the ALL AMERICAN OPEN KARATE TAE

KWON DO KUNG FU CHAMPIONSHIPS Trademark and has competed unfairly with

Grandmaster S. Henry Cho in violation of the common law of the State of New York.

50. Defendants' willful conduct amounts to deceit and fraud. Bycausing consumers to be

confused by Defendants' unauthorized use of the ALL AMERICAN OPEN KARATE TAE KWON

DO KUNG FU CHAMPIONSHIPS Trademark, Defendants have deceptively passed off their

tournament services as emanating or being endorsed by Grandmaster S. Henry Cho when

they are not.

51. As a result of Defendants' infringing activities, Grandmaster Cho and the Estate have, are

and will continue to suffer irreparable harm and damage.

52. Grandmaster Cho and the Estate have no adequate remedy at law.

PRAYER FOR RELIEF

WHEREFORE, The Estate of Grandmaster S. Henry Cho respectfully requests that this Court enter

judgment in its favor and against Defendants that:

A. Defendants have willfullyand intentionally infringed the ALL AMERICAN OPEN KARATE TAE

KWON DO KUNG FU CHAMPIONSHIP Trademark.

11

B. Defendants, their officers, agents, servants, employees and attorneys, parents, subsidiaries and

affiliates and all others in active concert or participation with them, who receive actual notice of the

Order of Judgment by any method:

a. be permanently enjoined and restrained from using the ALL AMERICAN OPEN KARATE TAE

KWON DO KUNG FU CHAMPIONSHIPS Trademark or any marks which are confusingly similar to the ALL

AMERICAN OPEN KARATE TAE KWON DO KUNG FU CHAMPIONSHIPS Trademark in connection with the

advertisement, promotion or sale of competition and spectator tickets to martial arts tournaments and

related merchandise;

b. be ordered to remove and destroy all signage, advertising and promotional materials, bearing

the ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU CHAMPIONSHIPS Trademark or any marks

which are confusingly similar to the ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU

CHAMPIONSHIPS Trademark; and

c. be ordered to recall and destroy all advertising, materials and products bearing the ALL

AMERICAN OPEN KARATE TAE KWON DO KUNG FU CHAMPIONSHIPS Trademark or any marks which

are confusingly similar to the ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU CHAMPIONSHIPS

Trademark.

C. Defendants be required to submit to the Court within thirty (30) days of entry of Judgment a

report detailing their compliance with B above.

D. Defendants be required to pay to the Estate of Grandmaster S. HenryCho damages in an

amount to be determined at trial and that such damages be trebled pursuant to 15 U.S.C. 1117..

E. Defendants be required to turn over their profits gained by their infringingactivities to the

Estate of Grandmaster S. Henry Cho and that such profits be trebled pursuant to 15 U.S.C. 1117.

F. Plaintiffs be awarded exemplary and punitive damages in an amount to be determined at trial.

12

G. This be declared an exceptional case within the meaning of 1 5 U.S.C. 111 7(a) and Plaintiffs

be awarded their costs and attorneys' fees within the meaning of 15 U.S.C. 1117(a) or as otherwise

permitted by law.

I. Plaintiffs be awarded pre and post judgment interest on all sums due from Defendants.

J. Plaintiffs be awarded such other and further relief as the Court deems just and proper.

Plaintiffs hereby demand trial by jury.

Dated: February 13, 2015

13

Respectfully submitted,

BENJAMIN LAW PC

Amy J. Benj?111 East 14th StreetSuite 469

New York, New York 10003(212) 673-8350amy@benjaminlawpc .com

Attorneys for Plaintiff Estate of Sihak Henry Cho

VERIFICATION

Kenneth K. Cho under penalty of perjury hereby states and declares:

1. lam one of the executors of the Plaintiff Estate of Sihak Henry Cho and the eldest son

of Sihak Henry Cho.

2. Ihave personal knowledge of the facts set forth herein, or a reasonable belief that the

facts set forth herein are true and correct.

i

Date: February 13, 2015 i

Bv: ^w^t K-CfarKenneth K. Cho

EXHIBIT 1

TW.lretNo.: 2012-1806

Inthematter of theEstate of:Sihak Henry Cho, Deceased }

Microfilm No.:

CERTIFIED COPY

LETTERS TESTAMENTARY

I Michael R. Dressier, Surrogate do hereby certify that the Last Will and Testament having no codicils of theabove named Decedent, late of the County ofBergen and State ofNew Jersey, was (were) admitted to Probateby the Surrogate's Court of the County ofBergen, on June 25,2012, and that Letters Testamentary were .suedto Kenneth K. Cho and David P. Cho the Executor/rix(s) named therein, who is (are) duly authorized to takeupon himsellTherself/itself/themselves the administration of the estate of said testator agreeably to the said Willhaving no codicils and said Letters Testamentary have never been revoked and still remain in full force andeffect.

DO NOT ACCEPT WITHOUT RAISED SEAL

A41197

WITNESS my hand andsealof office on:Jane 25,2012

Michael R. Dressier, Surrogate

Page 1 of 1

EXHIBIT 2

Int. CL: 41

Prior U.S. Cls.: 100,101 and 107Reg. No. 3,015,207

United States Patent and Trademark Office Registered Nov. is, 200s

SERVICE MARKPRINCIPAL REGISTER

ALL AMERICAN OPENKARATE TAE KWON

DO KUNGFUCHAMPIONSHIPS

CHO, SIHAK HENRY (UNITED STATES INDIVI- NO CLAIM IS MADE TO THE EXCLUSIVEDUAL) RIGHT TO USE KARATE TAE KWON DO KUNG

423WILDWOOD ROAD pu APART FROM THE MARK AS SHOWN.NORTHVALE, NJ 07647

FOR: ORGANIZING AND CONDUCTING MARTIAL ARTS COMPETITIONS, IN CLASS 41 (U.S. CLS. SEC. 2(F).100,101 AND 107).

FIRST USE 1-1-1975; IN COMMERCE 1-1-1975. SER. NO,78429,062, FILED 6-2-2004.

THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM TO ANY PARTICULARFONT, STYLE, SIZE, ORCOLOR. G. MAYERSCHOFF, EXAMINING ATTORNEY

Generated on: This page was generated by TSDR on 2015-02-13 07:51:13 EST

Mark: ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU CHAMPIONSHIPS

US Serial Number: 78429062 Application Filing Date: Jun. 02, 2004

US Registration Number: 3015207 Registration Date: Nov. 15, 2005

Register: Principal

Mark Type: Service Mark

Status: A Sections 8 and 15 combined declaration has been accepted and acknowledged.

Status Date: Jul. 13,2011

Publication Date: Aug. 23, 2005

Mark InformationMark Literal Elements: ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU CHAMPIONSHIPS

Standard Character Claim: Yes. The mark consists of standard characters without claim to any particular font style, size, or color.

Mark Drawing Type: 4 - STANDARD CHARACTER MARK

Disclaimer: KARATE TAE KWON DO KUNG FU

Acquired Distinctiveness In wholeClaim:

Goods and Services

Note: The following symbols indicate that the registrant/owner has amended the goods/services:

Brackets [..] indicate deleted goods/services; Double parenthesis ((..)) identify any goods/services not claimed in a Section 15 affidavit of incontestability; and Asterisks *..* identify additional (new) wording in the goods/services.

For: ORGANIZING AND CONDUCTING MARTIAL ARTS COMPETITIONS

International Class(es): 041 - Primary Class U.S Class(es): 100,101,107Class Status: ACTIVE

Basis: 1(a)First Use: Jan. 01,1975 Use in Commerce: Jan. 01,1975

Basis Information (Case Level)Filed Use: Yes Currently Use: Yes Amended Use: No

Filed ITU: No Currently ITU: No Amended ITU: No

Filed 44D: No Currently 44D: No Amended 44D: No

Filed 44E: No Currently 44E: No Amended 44E: No

Filed 66A: No Currently 66A: No

Filed No Basis: No Currently No Basis: No

Current Owner(s) InformationOwner Name: Cho, Sihak Henry

Owner Address: 423 Wildwood RoadNorthvale, NEW JERSEY 07647UNITED STATES

Legal Entity Type: INDIVIDUAL Citizenship: UNITED STATES

Attorney/Correspondence Information

ALL AMERICAN OPENKARATE TAE KWON

DO KUNGFUCHAMPIONSHIPS

Attorney Name: KENNETH K CHO

Attorney Primary Email officeaction@aol.comAddress:

Correspondent KENNETH K CHOName/Address: PO BOX 110

PO Box 110NORWOOD, NEW JERSEY 07648UNITED STATES

Phone: (917)699-1528Correspondent e-mail: officeaction@aol.com

Attorney of Record

Attorney Email YesAuthorized:

Correspondent

Fax: (201)750-2739Correspondent e-mail Yes

Authorized:

Domestic Representative - Not Found

Prosecution History

Date Description

Feb. 12, 2015 TEAS RESPONSE TO OFFICE ACTION-POST REG RECEIVED

Jan. 28, 2015 POST REGISTRATION ACTION MAILED - SEC. 8 & 9

Jan. 28, 2015 CASE ASSIGNED TO POST REGISTRATION PARALEGAL

Jan. 13, 2015 TEAS SECTION 8 & 9 RECEIVED

Jul. 13,2011 NOTICE OF ACCEPTANCE OF SEC. 8 & 15-MAILEDJul. 13,2011 REGISTERED - SEC. 8 (6-YR) ACCEPTED & SEC. 15ACK.Jul. 13, 2011 CASE ASSIGNED TO POST REGISTRATION PARALEGAL

Jun. 01, 2011 TEAS SECTION 8 & 15 RECEIVED

Nov. 15, 2005 REGISTERED-PRINCIPAL REGISTER

Oct. 14, 2005 UNDELIVERABLE MAIL - NO ACTION TAKEN

Sep. 26, 2005 PAPER RECEIVEDAug. 23, 2005 PUBLISHED FOR OPPOSITIONAug. 03, 2005 NOTICE OF PUBLICATIONMay 03, 2005 LAW OFFICE PUBLICATION REVIEW COMPLETEDApr. 29, 2005 ASSIGNED TO LIEApr. 18, 2005 APPROVED FOR PUB - PRINCIPAL REGISTERApr. 15, 2005 EXAMINER'S AMENDMENT ENTEREDApr. 14, 2005 ASSIGNED TO LIEApr. 14, 2005 EXAMINERS AMENDMENT MAILEDApr. 14, 2005 EXAMINERS AMENDMENT -WRITTENJan. 07, 2005 NON-FINAL ACTION MAILED

Jan. 06, 2005 NON-FINAL ACTION WRITTEN

Jan. 05, 2005 ASSIGNED TO EXAMINER

Jun. 09, 2004 NEW APPLICATION ENTERED IN TRAMMaintenance Filings or Post Registration Information

Affidavit of Continued Section 8 - AcceptedUse:

Affidavit of Section 15 - AcceptedIncontestability:

TM Staff and Location Information

Current Location: TMEG LAW OFFICE 106

TM Staff Information - NoneFile Location

Date in Location: Jan. 28, 2015

ProceedingNumber

76874

76874

70619

70619

99888

76568

76568

76529

76529

60792

60792

60792

EXHIBIT 3

All American Open Tae Kwon Do/Karate/Kung Fu Championship Page 1 of 3

Henry Cho

Instruction

Tournament

Seminars

Books

Videos

Contact

50th All American OpenChampionships

#W*

2015All American Open

Tae Kwon Do - Karate - Kung FuChampionships

Our 50th Annual Championship is scheduled for:Saturday. March 7.2015

Long Island University's Brooklyn Campus1 University Plaza, Brooklyn, NY 11201

(Flatbush Ave at DeKalb Avenue)

For further information:CALL: (917) 45J-9349

E-MAIL: agkimmclhi aul.com

or

HenrvCho(fijaol.com

(Note: Time and Ticket Fees are subject to change)SCHEDULE OF EVENTS:

9:00 AM: Late Registration10:15 AM: Judges meeting10:30 AM: Opening Ceremony11:00 AM: Children's FORMS12:00 PM: Children's SPARRING1:00 PM: BRAKING & WEAPONS FORMS (All Ages)2:00 PM: Adults Black Belt & Advanced FORMS3:00 PM: Adults FORMS & SPARRING

SPECTATOR TICKETS:Children (10 and Under): $5.00General Admission: $10.00

ADVANCE TICKETS:For additional information and entry blanks write to:

Master Arthur Kimmel, Tournament PromoterWay of Action, Inc.316 7thStreet, 2nd FloorBrooklyn, NY 11210Tel: (917) 453-9349Email: aqkimmel@aol.com or henrycho@aol.com

FOR COMPETITION REGISTRATION:Click on ENTRY BLANK and print out an Entry Blank for the competition.Fill out the entry blank, sign it (Guardian's signature is required if under18 years of age), then mail it with a self-addressed stamped envelope andentry fee to the address above. When your entry is accepted, a contestcard will be sent to you. If your entry is received after March 1, it will beheld at the entrance of the Main Gym. Show your I.D. and pick it up at theRegistration Table.ENTRY FEE

http://www.henrycho.com/tourn.html 2/13/2015

All American Open Tae Kwon Do/Karate/Kung FuChampionship Page 2 of3

1. If you register by mail before March 1,2015. $50.00ForFreeSparring, Form,or Breaking.- $60.00 for any two events. $70.00 for any three events.2. If you register after March 1, 2015. $55 for one event, $65 for two, and $75 for three events.

MANDATORY EQUIPMENT:Mouth guards, groin cups (male), and safety equipment for hands, feetand head are mandatory.

ACCOMMODATIONS:Local Area Hotels:

Youmaycontact the following hotels for availability andpricing:

(1) Sheraton Brooklyn New York Hotel228 Duffield St., Brooklyn, NY 11201TEL: 1-855-239-9480

(2) Hotel Indigo Brooklyn229 Duffield St., Brooklyn, NY 11201TEL: 1-866-573-4235

(3) Aloft NY Brooklyn Hotel216 Duffield St., Brooklyn, NY 11201TEL: 1-866-767-0278

Categories of Competition (i.e., contests)

Directions to LIUi

What is the All American Open?The All American Open Championship was started in 1965 topromote the principles of the American Martial Arts. It has beenheld every year since and draws contestants from all around theworld. The All American Open is presently recognized as one of thenation's major martial arts tournaments.The All American Open was held in Madison Square Garden Centerin New York City for twenty-three consecutive years, from 1967 to1989. It was at the 1967 All American Open where Chuck Norris andBruce Lee first met. The All American Open has been continued andstaged outside the Garden since 1989, and we are proud to say thatmany famous champions have participated and won in the AllAmerican Open.The all American Open provides an opportunity for practitioners ofall styles to meet and compete against each other in a spirit ofcooperation and harmony. The tournament rules are specificallyformulated to cover all the major styles and not favor one over theothers.

What is Tae Kwon Do? What is Karate?

What is Kunq Fu? Home Page

http://www.henrycho.com/tourn.html 2/13/2015

AllAmerican Open TaeKwon Do/Karate/Kung Fu Championship Page 3 of 3

Copyright 2015 SHC Associates, Inc.Send mail to henrycho@aol.com with questions or comments about this web site.

http://www.henrycho.com/tourn.html 2/13/2015

EXHIBIT 4

All American OpenChampionships

2015 Tae Kwon DoKarate/ Kung-Fu

* * * *

The 50th

To be held in the Paramount Gym ofLong Island University's Brooklyn Campus, located atI UniversityPlaza, Brooklyn, NY11201 at 10:30a.m. onSaturday, March 7, 2015.

(Registration begins at 9:00am)Check the divisions ^visions you enter below:

m FORM CONTEST( ) Tae Kwon Do Hyung

(II) BREAKING CONTEST() Adults Breaking

mn FREE SPARRING()Mcn

() Karate Kata () Children's Breaking () Women() Kung-Fu Form ( ) Senior( ) Senior Form (all styles) () Children() Weapons Form{) Free Style form() Masters Form (all styles)

(Please type or print the following:)

Name Age_ Sex

Address

State

Home Phone: ( )_

Your rank

Instructor's name

Zip E-mail Address:

Belt Color

(Apt. No._ J. City.

Fax: ( )_

Style studied

His e-mail address:

WHO ARE YOU?() 6 Years & Under() 7-8 Year Olds() 9-10 Year Olds() 11-13 Year Olds(J14-16 Year Olds017-39 Year Olds() 40 Year Olds '+'

.Hgt__Wgt._

School name. Phone: ( )

City

. pax:( )_School Address State Zip

Lbs.

I, the undersigned, hereby waive all claims against any or all persons connected with the All American Open Tae Kwon Do/Karate/ Kung-fu Championship Tournament; Way ofAction, Inc SHC Associates Inc.; Long Island University's BrooklynCampus; theEstate, Heirs andExecutors of S. Henry Cho, theEstate Heirs andExecutor of Linda Lutes, andArthur Kimmel forany injuries that I may sustain during my participation inthe competition. I also assume full responsibility for any ofmy actionsduring and inconnection with said tournament. I agree that my performance orattendance atthe competition orboth may befilmed orotherwise recorded ortelecast live and I consent to theusebytheEstate ofS.Henry Cho, SHC Associates, Inc., andWay ofAction, Inc. its assignees and licensees ofmy name, likeness, voice, poses, pictures and biographical data concerning me,fully orin part and inany form orlanguage with orwithout other material, throughout the world without limitation, for television,radio and/or theatrical motion pictures byany devices now known orhereafter devised, and I waive any compensation therefor.

Date Signature_

Signature of Guardian or Parent if under 18

Entry Fee: $50forForm, Breaking or Sparring / $60for2 events and$70for3 events,when you register by mail before March 1, 2015.

$55 foroneevent / $65 for2/ $75 for3, if youregister after March 1,2015.

MakeMONEY ORDER, payable to "Wayof Action, Inc." and send it to:Way ofAction. Inc.. 316 7* Street. Brooklyn. NY 11215.

(NO PERSONAL CHECKS ACCEPTED/ NO REFUNDS).

Visit our website; www.henrycho.com

D2015S.H. Cho

All American OpenChampionships

2015

The 50th

Tae Kwon Do

Karate /Kung-Fu

Allrecognized Tae Kwon Do,Tang Soo Do, Karate, and Kung-Fu teachers andtheir students arecordially invited toattend the50th annual AllAmerican Open Karate,TaeKwon DoandKung-Fu Championship Tournament This nationwide tournament is wellknown throughout theworld asoneofthefinestpresentations ofmartial arts.

EVENTSCHEDULEDATE: MARCH7,201S(Saturday)PLACE: Long Island University

(Paramount Gym), Brooklyn Campus

FORM CONTEST(Any forms of all styles are permitted 3 trophies per Blackbelt division. Medals for all other divisions. Divisions maybe added or combined.)Grand Champion^ The winner of the Masters andSeniors divisions, and advanced/Black Belt divisionchampions of Tae Kwon Do, Karate & Kung-fu.

- ADULT'S FORMS -(TAE KWON DO/TANG SOO DO FORM)

Q MEN: BLACK BELT DIVISIONBROWN-RED BELT DIVISIONPURPLE-BLUE-GREEN DIVISIONYELLOW-ORANGE-WHTTE DIVISION

G WOMEN: BLACK BELT DIVISIONBROWN-RED-PURPLE-BLUE DIVISIONGREEN-YELL-ORANGE-WHITE DIVISION

(KARATE KATA)0 MflN,; BLACK BELT DIVISION

ADVANCED DIVISIONBEGINNERS DIVISION

D WOMEN: BLACK BELT DIVISIONADVANCED DIVISIONBEGINNERS DIVISON

(KUNG-FU FORM)D MEN: BLACK BELT DIVISION

ADVANCED DIVISIONBEGINNERS DIVISION

Q WOMJfiN; BLACK BELT DIVISIONADVANCED DIVISIONBEGINNERS DIVISION

(SENIORS FORM) -40&older(All styles of men and women)

BLACK BELT, ADVANCED & BEGINNERS(MASTERS FORM - 5th DAN +)

(All styles of men and women)(WEAPONS FORM)

Q Legal Weapon only (All ages & ranks) 1-2Divisions

- CHILDREN'S FORMS -(TAE KWON DO/ TANG SOO DO/

KARATE)Children's Grand Champitra: The winner of

Children's Biack-Brown-Red Divisions.0 MINI PEE WEE: (Up to 6 Year Olds)

WHITE-YELLOW-ORANGE DIVISIONGREEN BELT & HIGHER DIVISIONBLACK- BROWN-RED DIVISION

0 PEE WEE: (7-8 Year ObU)WHITE-YELLOW-ORANGE DIVISIONGREEN-PURPLE-BLUE DIVISIONBLACK-BROWN-RED DIVISION

D SUPER MINI PEE WEK: (MOYearOhfa)WHITE-YELLOW-ORANGE DIVISIONGREEN-PURPLE-BLIJE DIVISIONBROWN-RED-BIACK DIVISION

(11-12-13 Year Olds)WHITE-YELLOW-ORANGE DIVISIONGREEN-PURPLE-BLUE DIVISIONHLACK-BROWN-RED DIVISION

D TEENS: (14-15-16 Year Olds)WHITE-YELLOW-ORANGE DIVISIONGREEN-PURPLE-BLUE DIVISIONBROWN-RED-BLACK DIVISION

(KUNG-FU)D CHILDREN: (UP TO 16 Year Olds): 1-2Divisions

REGISTRATION:Fill out an entryblank(www,henrycho com)and sign.(Guardian's signature is required if under 18years ofage.) Then, mail it with a self-addressed, stampedenvelope and entry fee to (before March 1, 2015):

Way of Action, Inc.316 7* Street,Brooklyn,NY 11215

When your entry is accepted, a Contest Cardwill be sent to you. If your entry is received afterMarch i, it will be held at the entrance of the MainGym. Show your I.D. and pick it up at the desk.

D ENTRY FEE:1. (If you register by mail before March 1,2015)-

$50 for Free Sparring, Form, or Breaking,$60 for any 2 events, and $70 for 3 events.

2 (If you register after March 1, 2015) -$55 for one event, $65 for two and $75 for three.

D SPECTATOR TICKETS:Children (10andunder):$5. /General Admission: $10

EQUIPMENT:Groin cups (male), mouth guards, and safetyequipment for the hands, feet and head are mandatory.

9:00am- Registration.10:15am- Judges Meeting.

10:30am- Opening Ceremony.11:00am- Children's FORMS.

BREAKING CONTESTContestants must be training at least for one year.

#2 pine boards (1" thick) are recommended.(All other objects must be pre-approved.)

Two attempts only.

- ADULTS DIVISIONS -(All boards are to be cut into 12"x Tsize.)

U Men: Black Belt DivisionBrown-Red-Purple-Blue Beit DivisionGreen-Yellow-Orange-White Division

D Women (All ranks): 1-2 Divisions

- CHILDREN DIVISIONS-D 14 to 16 year olds: - 12"x 8" size board.

Advanced & Beginners Divisions0 13 year olds & Younger: - 12"x 7" size board.

Advanced & Beginners Divisions

Other divisions may be created or reapportioned.3 Trophies for each Black belt division.3 Medals for each under belt division

50th ANNUAL PRESENTATIONOF THE ALL AMERICAN OPEN

KARATE TAE KWON DO KUNG-FUCHAMPIONSHIPS by

Way of Action, Inc.

MARCH 7, 2015(SATURDAY)

LONG ISLAND UNIVERSITY(PARAMOUNT GYMNASIUM)

1 University PlazaBrooklyn, NY 11201

For InformationWay of Action, Inc.

Master Arthur Kimmel316 7th Street

Brooklyn, NY 11215TEL: (917) 453-9349 / FAX: (718) 330-0254

E-mail: agklmmelQaol.comWebsite: www.henrycho.com

DIRECTIONS-to.,,

From Manhattan - Via Manhattan BridgeTake Flatbush A\ e Extension, turn left on M\ ille Ave.right on Ashland Place and go 2 blocks to DeKalb Aveand turn right The campus is on the right at comer ofDeKalb and Flatbush Aves.

Via Brooklyn BridgeTake Adams Si. make left turn onto Tillarv St and keepright: after crossing Flatbush A\ e Extension bear rightonto Nav> St. which becomes Ashland Place, go 2blocks and turn right on DeKalb Ave.The campus is onthe right at corner of DeKalb and Flatbush Aves.

From QueensTake the Brooklyn-Queens Expressway (west) lo TillarvSt Exit Keep right on Tillary St Follow Tillarv St loFlatbush Ave and make a left, then a left on M\ rtle Aveand a right on Ashland Place Go 2 blocks and turn rigluon DeKalb Ave The campus is on (he light at comer ofDeKalb and Flatbush Aves.

From Staten Island or BrooklynTake the BrookKn-Queens Expressway (east) toCadman Pla/a West Follow Cadman Pla/a West loTillarv St. Bear righton Tillarv St and keepnghl.crossing Flatbush Ave Extension and bearing right ontoNa\\ St. which becomes Ashland Place Proceed toDeKalb Aveaid turn right The campusis on the rightatcorner of DeKalh and Flatbush Aves

12:00pm- Children 'i SPARRING.1:00pm- BREAKING and WEAPONS (All Ages).2:00pm- Adults Black Belt Jt Advanced FORMS.3:00pm- Adults FORMS

All American Open mm~\ Tae Kwon DoChampionships ^^^^.ZP Karate/ Kung-Fu

*

The 50th

February 6, 2015

On behalfof S. Henry Cho Tae Kwon Do and the late Grandmaster S. Henry Cho, wecordially invite you, your students and your martial arts schools to attend the 50th AnniversaryCelebration ofthe AllAmerican Open Karate Tae Kwon Do Kung Fu Championships to beheld on Saturday, March 7,2015 at Long Island University's Brooklyn Campus.

This year marks ahalf century of bringing together martial artists from differing styles tocompete against each other, while fostering camaraderie amongst the competitors, spectators,teachers and Masters. This 50th year anniversary event will provide an opportunity to celebrate50 years of American Martial Arts tradition, and pay tribute to the late Grandmaster S. HenryCho.

As part of the festivities, a50th Anniversary Celebration Dinner is also being planned onthe evening ofMarch 6, 2015 in New York City and will pay tribute to Grandmaster Cho, therich history of the All American Open; and those competitors, Grand Champions, and Masterswho were are part ofthis history. All proceeds from the tournament and dinner will go toGrandmaster Cho's widow, Mrs. Cho. We hope that you can join us for these wonderful andhistorical events.

More information can be found at the website httD://www.henrvcho.com/tourn.html(under the "tournament" tab) or you may email Master Kimmel at agkimmel@aol.com (tel: 917-453-9349) or the Cho Family at shenrychotkd@gmail.com (tel: 917-699-1528).Best regards,

S. Henry Cho Tae Kwon Do (50th Anniversary Tournament and Dinner Committee^Grandmaster Filipo GiordanoGrandmaster Frank RodriquezMaster John R. SanoMaster Thomas ScalaMaster Hal SchiffMasterNicolas Gonzalez, San German Tae Kwon DoMaster Arthur Kimmel, Way of Action, Inc.Master James AuteriJ.B. MillerLisa AlonzoKenneth and David Cho

All American Open *flf\ Tae Kwon DoChampionships \^^^LP Karate/ Kung-Fu

3fl3Hr

EXHIBIT 5

AGREEMENT

This AGREEMENT made on the 4th day ofNovember, 2005 ("Effective Date"), by andbetween Grandmaster S. Henry Cho on behalfof the SHC Associates, Inc., with a mailingaddress at P.O. Box 495, Tappan, New York 10983, U.S.A. ("Headquarters"); and Behdad DavidMoradi, representing Westchester Tae Kwon Do Academy, Inc, located at 10 Rye Ridge Plaza,#32, Rye Brook, NY 10537, U.S.A.(hereinafter referred to as "Student").

WHEREAS, Grandmaster S. Henry Cho is the creator and promoter of the nationallyrecognized martial arts tournament known as the All American Open Tae Kwon Do KarateKung-Fu Championship Tournament ("All American Open") which has been promoted for morethan 40 years;

WHEREAS, Student desires to continue promoting the All American Open andencouraging the philosophies of good sportsmanship and competition in an open martial artstournament;

NOW, THEREFORE, Grandmaster S. Henry Cho and the Student agree to thefollowing:

1. Grandmaster S. Henry Cho shall license the exclusive rights to promote and operate theAll American Open for the consideration set forth in paragraph 2 below.

a. The rights granted herein include the right to:i. use the trademark ALL AMERICAN OPEN KARATE TAE KWON DO

KARATE CHAMPIONSHIPS;ii. use the copyrights in printed materials necessary to plan, schedule and ran

the All American Open which include but are not limited to posters,handbills, information sheets, contestant cards, tickets and the like;

iii. own the databases ofpast martial arts competitors, schools, clubs and/ororganizations;

1. Student shall grant Grandmaster Cho the right to use the databaseonce the ownership therein is transferred;

iv. use the "know-how" required to organize, plan and run the All AmericanOpen; and

v. use the "goodwill" that have been developed and associated with the AllAmerican Open during the past 40 years.

2. As consideration for the rights granted in paragraph 1, Student shall pay the sum ofiollars to Grandmaster Cho.

For convenience, Student may pay five installments of4dollars each overthenext five year period. Each(installment may be divided into two equal payments of|

Page 1 of4

dollars each. The first payment ofJ^#vill be due nolater than December 31, 2005, and the second payment ofgmmmnll be due seven days before the scheduled 2006 tournament date. Theremaining 4installments may be paid at the end ofthe year and one week beforethe event accordingto the same schedule.

b All Entry Blanks will be maintained by Grandmaster Cho until the entire amountin paragraph 2above is received from Student. After the entire consideration ispaid the Student will then have the rights and licenses set forth in Paragraph 1butwill continue to provide copies ofthe Entry Blanks to Grandmaster Cho so thatGrandmaster Cho may update and use the database ofcompetitors, schools, clubsand/or organizations.

3 Grandmaster Cho will use his reasonable efforts to invite and encourage other Marial artsmasters and schools to participate in the All American Open and also encourage theparticipation of foreign branch schools. To the extent possible, Grandmaster Cho will tryto attend the Opening Ceremony at the All American Open and, ifpossible, the dinner atthe conclusion of the event.

4 Student shall be liable for all expenses associated in planning, promoting and operatingthe All American Open including but not limited to rental fees for the venue, printingcharges trophy costs, postage, advertising, the hotel fees for honored guests and the like.

a For the convenience ofthe parties, Grandmaster Cho may advance payment for anexpense and such expense shall be reimbursed back to Grandmaster Cho byStudent uponpresentation of thereceipt.

5 Student acknowledges that there are "goodwill" and intangibles associated with the AllAmerican Open and Grandmaster Cho's reputation, and Student agrees to uphold thesevalues, traditions andgood sportsmanship.

6 In the event ofan incapacitating illness ordeath ofGrandmaster Cho, then this agreementwill remain binding between Student and Grandmaster Cho's surviving spouse or heirsand 10% ofnet proceeds from the All American Open shall be paid to GrandmasterCho's surviving spouse orheirs solong asshesurvives.

7 Student will maintain liability insurance coverage for the All American Open and willinclude Grandmaster Cho (personally) and SHC Associates, Inc. insuch insurancecoverage, policy and/or insurance policy rider.

8 Student will have no rights to the video and photographic footage from the first fortyyears of the All American Open and for those All American Open tournaments held whileStudent is making payments pursuant to Paragraph 2(a). Grandmaster Cho will own orcontinue to own these rights. After the entire consideration inParagraph 2 ispaid, thenStudent shall then own the rights to all the video and photographic footage for those All

Page 2 of4

American Open tournaments starting from that point that the consideration ispaid infull.Once Student has paid the consideration in full, then Student shall provide GrandmasterCho with copies ofany and all video and photographic footage requested byGrandmasterCho, along with all legal rights and permissions tousethis footage.

9. Ifthe All American Open isnot held for three consecutive years during the 15 year periodstarting from the Effective Date, then the rights granted inthis Agreement will revertback to Grandmaster Cho or his heirs.

10. In order toencourage Sponsors to support the All American Open, then any parties,including Grandmaster Cho and Student, will receive a20% finder's fee for any and allmoneys from sponsorships, television rights or movie rights that are provided for or basedon the All American Open.

a. The remaining 80% ofthe moneys from sponsorships, television rights ormovierights will be shared equally between Grandmaster Cho and Student (i.e.,Grandmaster Cho shallreceive 40%andStudent shall receive 40%).

b. The finder's fee and shares may berenegotiated upon themutual consent ofGrandmaster Cho and Student.

11. The Student willnothave anyrights to thename, likeness, trademarks, goodwill or thelike ofGrandmaster S. Henry Cho or SHC Associates, Inc.

12. The Student agrees tobe subject to personal jurisdiction inthe State ofNew Jersey, theUnited States of America, and accepts and acknowledges thejurisdiction of theUnitedStates courts pertaining to anydispute, which may arise under this agreement.

13. The Student shall indemnify and hold harmless Grandmaster S. Henry Cho, hisrepresentatives, SHC Associates, Inc, the World Council ofMartial Arts organization andany other Branch Schools from any and all losses, claims or causes ofaction includingbut not limited to any incidental and consequential damages arising outofor in any wayassociated with the Student engaging inMartial Arts training and business, and operatingand promoting the All American Open mcluding, but not limited to, the reasonable costsand attorney's fees.

14. For aperiod of15 years from the Effective Date, the Student shall not transfer any ofitsrights or obligations under this Agreement without the prior written consent ofGrandmaster S. Henry Cho.

15. Student acknowledges that the terms ofthis Agreement areConfidential and that anydisclosure by Student ofthe terms ofthis Agreement requires the prior written consent ofGrandmaster Cho.

Page 3 of4

16. Any provision orprovisions of this Agreement which in anyway contravenes thelaws ofNew Jersey or theUnited States ofAmerica shall be deemed separable and shall notaffect anyotherprovisionor provisions ofthis Agreement.

IN WITNESS WHEREOF, theparties hereto havecaused this agreement to be executedas ofthe date and year first above-written.

Signed in the presence of:S.Henry

Behdad David MoradiWestchesterTae Kwon Do Academy, Inc10RyeRidgePlaza, #32Rye Brooli

Page 4 of4

EXHIBIT 6

viaemail (westchestertkd@aol.com) and U.S. MailBehdad David MoradiWestchester Tae Kwon Do Academy, Inc.116 North Main Street, 2nd FloorPort Chester, NY 10573

Estate of Sihak Henry Cho423 Wildwood RoadNorthvale, NJ 07647

February 10, 2014

Re: November 4,2005 License Agreement

Dear David:

We are hereby providing you with notice ofyour breach ofthe November 4,2005 licenseagreement between Westchester Tae Kwon Do Academy, inc., and SHC Associates, Inc. (hereinafterreferred toas the"AAO Agreement") and, on behalf ofthe Estate ofSihak Henry Cho, we terminate alllicenses and rights granted in the AAO Agreement.

As we previously mentioned in our January 15, 2014 letter to you, we are in receipt ofa check ithe amount of$ 495.00 made out to Myung Sook Cho purportedly for10 percent ofthe net proceedsfrom the March 16,2013 All American Open Karate tae Kwon Do Kung-Fu Tournament (hereinafter"2013 All American Open"). We arealso in receipt ofthe copies ofthe Entry Blanks from the 2013 AllAmerican Open which you hand-delivered to Kenneth Cho onJanuary 17,2014inPuerto Rico. We notethat all these actions evidenceyour continuedacknowledgement and acceptance of yourongoingobligations under the AAO Agreement.

We understand from your All American Open Settlement Letter (postmarked November27,2013) that you claim that the net profit from the 2013 All American Open was$ 4,950.25. This net profitamount issignificantly lowerthan previous yearsand is lessthan 50 percent of the net profits whenthetournament was run at Manhattan or Queens College. The numbers that you provided don't makesense basedon the 48 year history of this tournament. Weare not able to reconcile the fact that whileyou have a lower expense profile running the tournament at LIU's Brooklyn Campus (no rental fee to usethe gym), more net profit was made when the tournament was held at Manhattan College (Draddy Gymwith a gym rental fee of around$ 5,000) witha higher expenseprofile. We are unable to ascertainwhether this decrease in net profits isa result of underreportingor mismanagementof the All AmericanOpen. We formally request an accounting of all the income and expenses (in more detail thanpreviously provided inyour AAO Settlement letter) for the last five years, 2009- 2013,of the AllAmerican Open tournaments.

Yourfailure to hold the tournament at a more high-profile venue (like Manhattan or QueensCollege), the continued erosion of profitsand your mismanagement of the All American Open are

in

Behdad David MoradiFebruary 10,2014Page 2 of 3

damaging Grandmaster Cho's reputation and damaging the goodwillassociated with the trademark ALLAMERICAN OPEN KARATE TAEKWON DO KUNG-FU CHAMPIONSHIPS.

Furthermore, your breach of the June 22,2004 agreement between Westchester Tae Kwon DoAcademy, Inc. and SHC Associates, Inc. (the "GradePromotion Agreement"), as outlined inour letter ofJanuary 30, 2014, hasalsodamaged the reputation ofour latefather. Grandmaster S. Henry Cho and S.Henry Cho Tae Kwon Do; and the goodwill inthe All American Opentournament and trademark whichourfather actively promotedfor morethan 4 decades. More specifically, with respect to at least theOctober13,2012 and October27,2013 Grade Promotion Tests,you misled GrandmasterGiordano andMasters Schiff, Kimmel and Arteri intoconvening S.Henry Cho Tae Kwon Do Grade Promotion/testcommittees, misused the resources of S.Henry TaeKwon Do and failed to submitthe appropriatedocumentation andfees. Such actions are damaging our father's reputation and the goodwill that isassociated with the ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU CHAMPIONSHIPS trademarkand tournament in a very public way in frontofyour students andthe studentsof Grandmaster S. HenryCho. These actions are notconsistent with being a martial artistandstudentofGrandmaster S. HenryCho.

You havefailed to comply with paragraph 5 of the AAO Agreement, which requiresyoutouphold the goodwill and intangibles associated with the All American Open and the reputation of S.Henry Cho, and "... upholdthese values,traditions and good sportsmanship." Part of the values ofGrandmasterCho and hisreputation isthat a student remainsa student ingood standingwithGrandmaster Cho andSHC Associates. This important ethical tenet iseven reinforced inyourblack beltagreement which you executed in 2009, and which all black belts inS. Henry Cho Tae Kwon Do honor.However, onJanuary 17and 18,2014, you admitted and acknowledged your breach ofparagraphs 10-13 and 16oftheGrade Promotion Agreement by intentionally testing, promoting and issuing your owndiplomas toyour students without theknowledge orconsent ofSHC Associates, Inc., S. Henry Cho'sestate orheirs. You have openly and expressly declared in front ofmasters and students ofS. Henry ChoTae Kwon Do thatyou have not been and will not remain astudent in good standing with S. Henry ChoTae Kwon Do.

We have attached a copy ofanInformation Sheet for the2014 All American Open and note thatit is being presented by the AAO Committee of Way ofAction, Inc. Please be advised that Way of Action,Inc. is not licensed to use the mark ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FUCHAMPIONSHIPS and the Estate did not give Way ofAction, Inc. permission touse the mark, if youhave licensed orgiven Way ofAction, Inc. permission to use the mark ALL AMERICAN OPEN KARATE TAEKWON DO KUNG FU CHAMPIONSHIPS, then you are also in breach ofparagraph 14ofthe AAOAgreement by attempting to transfer"... rights orobligations under [the AAO Agreement] without theprior written consent ofGrandmaster S. Henry Cho" for the2014 All American Open Tournament. Yourattempt to openly advertise that "Way ofAction, Inc." is promoting the March 15, 2014 tournament isan attempt toeither sublicense ortransfer rights orobligations, orboth, under the AAO Agreement, aright which you do not have under the AAO Agreement. The Estate of Sihak Henry Cho does NOTconsent to Way ofAction, Inc's use ofthemark. We have notified Way ofAction, Inc. that ithas norights to use thetrademark ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU CHAMPIONSHIPSandthat your actions are inbreach ofthe AAO Agreement which hasbeenterminated.

Behdad David MoradiFebruary 10,2014Page 3 of 3

In light of the clear breaches of the AAO Agreement and the Grade Promotion Agreement byyou and Westchester TDK Academy, Inc., you are hereby notified that we are terminating the rightslisted in paragraph 1of the AAO Agreement. Specifically, the following licenses are hereby terminatedeffective immediately:

1. The license to use the trademark ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FUCHAMPIONSHIPS;

2 The license to use copyrighted materials for the All American Open including but notlimited to posters, handbills, information sheets, contest cards, tickets and the like;

3. The license to use theknow-how from theAll American Open; and4. Thelicense to use the goodwill of the All American Open.

Accordingly, we hereby demand that you immediately cease and desist from advertising,promoting or hosting any martial arts tournament that uses the trademark, copyrights, know-how,goodwill or intellectual property of the mark ALL AMERICAN OPEN KARATE TAE KWON DO KUNGFUCHAMPIONSHIPS or the likeness of Grandmaster S.Henry Cho.

Sincerely,

Kenneth K. Cho

Javia^jCo-Executors of the Estate of Sihak Henry Cho

EXHIBIT 7

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EXHIBIT 8

WESTCHESTER TAE KWON DOACADEMY MARTIAL ARTS for CHILDREN and ... Page 1of 1

HOME

INSTRUCTORS

CLASS SCHEDULE

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LOCATION

Special Event!

American OpenMartial ArtsChampionship

Tae Kwon Do, Karate,Kung Fu, Tang Soo Do

Gaucho Gym478 Gerard AvenueBronx, NY 10451

SaturdayFebruary 28, 201510:00AM to 8:00PM

WESTCHESTER TAE KWON DO ACADEMY

HOME OF TRADITIONAL MARTIAL ARTS FOR CHILDREN AND ADULTS

Westchester Tae Kwon Do AcademyMartial Arts for Children and Adults

We are a traditional Tae Kwon Do (Martial Arts) School for children and adultsdedicated to preserving a noble purpose: To develop and serve the Individual, theCommunity and the Arts.

This is accomplished by a disciplined and rigorous regimen of training which bringstogether the student and the instructor in an atmosphere of mutual respect. We helpour students achieve a high sense of Self Confidence, Mental Preparedness andPhysical Fitness.

As a center for learning (Do-jang), Westchester Tae Kwon Do Academy provides aplace where students of ALL ages ranging from young children to adults and all walksof life come together under one roof in an atmosphere of EQUALITY and develop asense of community and camaraderie.

2008 Westchester Tae Kwon Do Academy116 North Main Street 2nd Floor, Port Chester, NY 10573

Phone: 914-251-0038 Fax: 914-251-0214

http://www.westchestertkd.com/ 2/13/2015

EXHIBIT 9

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Heyeveryone!Comejoinme at Ihe OPENMARTIAL ARTSTournamentSat. Feb. 28,2015 GauchoGym, 478 Gerard ave, Bronx, NY 10451.Master David Moradi isdoing what ourgreat Grandmaster S.Henry Chowould want.... keeping our martial arts family together!! I'll berememberingthatthiswould be ourGrandmaster's 50thyrandcelebrate allthathepassed ontome/usl!! Message Master Moradi for all thedetails. Ihope tosee you all there!!! OUSII!

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) Bill Dewart Greetings Master Helen, Iamsoexcited that you folks win beJoining us intheBronx, myok)stomping grounds! Iwasbomandraised intheBronxandamlooklng forward to being theretosupport Master Mora* as hecontinues inthefootsteps ofGM Cho. Iwill took forward loseeing you andMaster Lemonon February28th. Peace.Yours in Taekwondo,Bill Dewart

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