UNITED STATES DISTRICT COURTDISTRICT OF MINNESOTAAnytime Fitness, Inc., aMinnesota corporation,Plaintiff,v.Rainbow Fitness, LLC, a Nevadalimited liabilitycompany, Fort Apache Fitness,LLC, a Nevada limited liabilitycompany, Blue DiamondFitness,LLC, a Nevada limitedliability company, LawrenceFagan, an individual,and LindaFagan, an individual,Defendants.File No.
Plaintiff Anytime Fitness, Inc. (“AFI”) for its complaint against DefendantsRainbow Fitness, LLC, Fort Apache Fitness, LLC, Blue Diamond Fitness, LLC, LawrenceFagan,and Linda Faganstates and alleges as follows:
For the past 16months, Defendants have been taught by AFI how to develop andsuccessfully operate a limited service 24-hour co-ed fitness center business. They reapedthe substantial benefits conferred upon them by AFIunder five-year franchise agreements,which have permitted Defendants to quickly build a successful business in a field in whichthey had no prior experience. AFI provided Defendants with the information and “knowhow” to get their business up and running, and then to successfully operate their fitness
Case 0:09-cv-02185-JMR-FLN Document 1 Filed 08/20/09 Page 1 of 24