JS 44C/SDNY

CIVIL COVER SHEET

REV. 4/2014

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

TT'MJj

PLAINTIFFS

DEFENDANTS

WESTCHESTER TAE KWON DO ACADEMY, INC. AND BEHAD DAVID

ESTATE OF SIHAK HENRY CHO

MORADI

ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER

ATTORNEY:

BENJAMIN LAW PC

111 EAST 14TH STREET, SUITE 469

NEW YORK, NY 10003

IWN)

(212) 673-8350

CAUSE OF ACTION (CITE THE U.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(DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)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
IS THIS AN INTERNATIONAL ARBITRATION CASE?

No 0

FEB 13 201!)

Yes
NATURE OF SUIT

(PLACE AN [x] IN ONEBOXONLY)

TORTS

CONTRACT

&Case No.

ACTIONS UNDER STATUTES

PERSONAL INJURY

PERSONAL INJURY

FORFEITURE/PENALTY

BANKRUPTCY

OTHER STATUTES

[ ] 422 APPEAL

[J 400 STATE

[ I 367 HEALTHCARE/
[]110
[]120
[]130
[]140

11150

[ 1151
[]152

[ 1310 AIRPLANE
[ ] 315 AIRPLANE PRODUCT

INSURANCE
MARINE
MILLER ACT
NEGOTIABLE
INSTRUMENT

LIABILITY

[ J 320 ASSAULT, LIBEL &

SLANDER

RECOVERY OF
OVERPAYMENT &
ENFORCEMENT

( ) 330 FEDERAL

OF JUDGMENT

[ ] 340 MARINE
I ] 345 MARINE PRODUCT

MEDICARE ACT
RECOVERY OF
DEFAULTED
STUDENT LOANS

EMPLOYERS'

[J 160
[]190

[1195

RECOVERY OF
OVERPAYMENT
OF VETERAN'S
BENEFITS

LIABILITY

[ ] 350 MOTOR VEHICLE

[ J 355 MOTOR VEHICLE

INJURY

[ J 362 PERSONAL INJURY MED MALPRACTICE

[ ]290

28 USC 157

PROPERTY RIGHTS

REAPPORTIONMENT

[
[
[
[
[

]410 ANTITRUST
J 430 BANKS & BANKING
] 450 COMMERCE
] 460 DEPORTATION
] 470 RACKETEER INFLU
ENCED & CORRUPT

[ ] 820 COPYRIGHTS
[ ] 830 PATENT
M 840 TRADEMARK

PERSONAL PROPERTY

[ ] 370 OTHER FRAUD

[ ] 371 TRUTH IN LENDING

SOCIAL SECURITY

ORGANIZATION ACT

(RICO)
[ 1480 CONSUMER CREDIT
[ 1 490 CABLE/SATELLITE TV
[ ] 850 SECURITIES/
COMMODITIES/

[ ] 380 OTHER PERSONAL

LABOR

PROPERTY DAMAGE

[ ] 385 PROPERTY DAMAGE

[ ] 710 FAIR LABOR

STANDARDS ACT

PRISONER PETITIONS

[ ] 463 ALIEN DETAINEE

[ ] 510 MOTIONS TO
ACTIONS UNDER STATUTES
CIVIL RIGHTS

LAND

CONDEMNATION

[ ]240
[1245

[ ] 423 WITHDRAWAL

[ ] 690 OTHER

INJURY PRODUCT
LIABILITY

[ ] 720 LABOR/MGMT

REAL PROPERTY

1 ]220
[ ]230

[ ] 368 ASBESTOS PERSONAL

21 USC 881

PRODUCT LIABILITY

LIABILITY

[ 1210

PRODUCT LIABILITY

PRODUCT LIABILITY

SUITS
OTHER
CONTRACT
CONTRACT

[ ] 196 FRANCHISE

[ ] 365 PERSONAL INJURY

I 1 375 FALSE CLAIMS

28 USC 158

SEIZURE OF PROPERTY

[ ] 360 OTHER PERSONAL

STOCKHOLDERS

PRODUCT

INJURY/PRODUCT LIABILITY

LIABILITY

(EXCL VETERANS)
[]153

PHARMACEUTICAL PERSONAL f , 625 DRUG RELATED

FORECLOSURE
RENT LEASE &
EJECTMENT
TORTS TO LAND
TORT PRODUCT
LIABILITY
ALL OTHER
REAL PROPERTY

[ ] 440 OTHER CIVIL RIGHTS

(Non-Prisoner)
I ] 441 VOTING
[ ] 442 EMPLOYMENT
[ ] 443 HOUSING/
ACCOMMODATIONS

[ ] 445 AMERICANS WITH

DISABILITIESEMPLOYMENT

VACATE SENTENCE
28 USC 2255

[ ] 530 HABEAS CORPUS

[ ] 535 DEATH PENALTY
[ ] 540 MANDAMUS & OTHER

] 861
) 862
] 863
] 864
] 865

HIA (1395ff)
BLACK LUNG (923)
DIWC/DIWW (405(g))
SSID TITLE XVI
RSI (405(g))

EXCHANGE

[ ] 890 OTHER STATUTORY

RELATIONS

ACTIONS

[ ] 740 RAILWAY LABOR ACT

[ ] 751 FAMILY MEDICAL

LEAVE ACT (FMLA)

[ ] 790 OTHER LABOR
LITIGATION

[ I 791 EMPL RET INC

SECURITY ACT
IMMIGRATION

PRISONER CIVIL RIGHTS

[ ] 462 NATURALIZATION

[ 1550 CIVIL RIGHTS

[ ] 555 PRISON CONDITION
[ ] 560 CIVIL DETAINEE

[
[
[
[
[

APPLICATION

[ ] 465 OTHER IMMIGRATION

[ ] 891 AGRICULTURAL ACTS

FEDERAL TAX SUITS

[ ] 870 TAXES (U.S. Plaintiff or

Defendant)
[ ] 871 IRS-THIRD PARTY

[ ] 893 ENVIRONMENTAL
MATTERS

[ ] 895 FREEDOM OF
INFORMATION ACT

26 USC 7609

[ ] 896 ARBITRATION
[ 1 899 ADMINISTRATIVE
PROCEDURE ACT/REVIEW OR
APPEAL OF AGENCY DECISION

[ ] 950 CONSTITUTIONALITY OF
STATE STATUTES

ACTIONS

CONDITIONS OF CONFINEMENT

[ ] 446 AMERICANS WITH

DISABILITIES -OTHER

[ ]448 EDUCATION

Checkifdemanded in complaint:

CHECK IF THIS IS ACLASS ACTION

UNDER F.R.C.P. 23

DEMAND $_

OTHER

QO YOU CLAJM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.D.N.Y.?
JUDGE

DOCKET NUMBER

CheckYES only ifdemanded in complaint

JURY DEMAND: 0YES QlO

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

(PLACEAN x INONEBOXONLY)

1*1 1 Original

ORIGIN

LJ 2 Removed from

Proceeding

*' 3 Remanded LJ 4 Reinstated or

state court

1'

from

a. all parties represented

Lj 5 Transferred from Q 6 Multidistrict

Reopened

(Specify District)

I I 7 Appeal to District

Litigation

Judge from
Magistrate Judge
Judgment

Appellate
Court

I | b. At least one
party is pro se.

(PLACEANxINONEBOXONLY)

1 U.S. PLAINTIFF

BASIS OF JURISDICTION

2 U.S. DEFENDANT \x\ 3 FEDERAL QUESTION

IF DIVERSITY, INDICATE

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)
CITIZEN OF THIS STATE
CITIZEN OF ANOTHER STATE

PTF

DEF

[ ]1

[ ]1

[ ]2

PTF DEF

[ ]2

CITIZEN OR SUBJECT OF A
FOREIGN COUNTRY

[]3[]3

INCORPORATED or PRINCIPAL PLACE

[ ]4 [ ]4

INCORPORATED and PRINCIPAL PLACE

PTF

DEF

[ ]5

[ ]5

[]6

[]6

OF BUSINESS IN ANOTHER STATE

FOREIGN NATION

OF BUSINESS IN THIS STATE

PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)

THE ESTATE OF SIHAK HENRY CHO

423 WILDWOOD ROAD

NORTHVALE, NJ 07647

DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)

WESTCHESTER TAE KWON DO ACADEMY, INC. & BEHAD DAVID MORADI, 116 NORTH MAIN
STREET, 2ND FLOOR, PORT CHESTER, NY 10573
WESTCHESTER COUNTY

DEFENDANT(S) ADDRESS UNKNOWN

REPRESENTATION IS HEREBY MADE THAT, 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 RIGHTS
COMPLAINT.)
CQIV

DATE X It ?J I(^SIGNATURE QFvATTQRNKr, OF RECORD

ADMITTED TO PRACTICE IN THIS DISTRICT

4a|i

RECEIPT*

[] NO

^\ C X<'~

Hi YES (DATE ADMITTED Mo. 05

Attorney BarCode# AB6886

fT^

Magistrate Judge is to be designated by the Clerk of the CourtMAvJ. Jut'.'" all

Magistrate Judge

is so Designated.

Ruby J. Krajick, Clerk of Court by.

Deputy Clerk, DATED

UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)

Clear Form

Save

Print

Yr. 1990

jUDGErARAS

AMY J. BENJAMIN (AB6886)

BENJAMIN LAW PC

111 EAST 14th STREET

SUITE 469

15 CV

NEW YORK, NEW YORK 10003

Attorneys for Plaintiff

/f) r:../ o

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF NEW YORK

ESTATE OF SHIHAK HENRY CHO,

Plaintiff,
"m

iO

-against-

Case No.

WESTCHESTER TAE KWON DO ACADEMY, INC. AND DAVID BEHDAD

MORADI AKA DAVID MORADI,

Defendants.

VERIFIED COMPLAINT

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:

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 KARATE TAE 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. A copy 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 Ruby Camacho.

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. A copy 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 License on February 10, 2014, the Estate appointed a
new licensee and continued the tradition of the ALLAMERICAN OPEN KARATE TAE 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

" A copy of the

Facebook posting is attached as Exhibit 7. These actions harmed the Estate and the goodwill
associated with the mark ALL AMERICAN OPEN KARATE TAE 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 Infringing Tournament 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. I will
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 MARTIAL ARTS 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 UNDER

SECTION 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 likely to 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 ALL AMERICAN 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.

10

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

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 willfully and 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.

12

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

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

Respectfully submitted,

BENJAMIN LAW PC

Amy J. Benj?
111 East 14th Street
Suite 469

New York, New York 10003

(212) 673-8350
amy@benjaminlawpc .com
Attorneys for Plaintiff Estate of Sihak Henry Cho

13

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. I have personal knowledge of the facts set forth herein, or a reasonable belief that the
facts set forth herein are true and correct.

Date: February 13, 2015

Bv: ^w^t K-Cfar

Kenneth K. Cho

EXHIBIT 1

Microfilm No.:

TW.lretNo.: 2012-1806

Inthe matter of theEstate of:

Sihak Henry Cho, Deceased

CERTIFIED COPY

LETTERS TESTAMENTARY

I Michael R. Dressier, Surrogate do hereby certify that the Last Will and Testament having no codicils ofthe
above named Decedent, late ofthe County ofBergen and State ofNew Jersey, was (were) admitted to Probate

bythe Surrogate's Court ofthe County ofBergen, on June 25,2012, and that Letters Testamentarywere .sued
to Kenneth K. Cho and David P. Cho the Executor/rix(s) named therein, who is (are) duly authorized to take

upon himsellTherself/itself/themselvesthe administration ofthe estate ofsaid testator agreeably to the said Will
having no codicils and said Letters Testamentary have never been revoked and still remain in full force and
effect.

DO NOT ACCEPT WITHOUT RAISED SEAL

WITNESS my hand andsealof office on:

Jane 25,2012

Michael R. Dressier, Surrogate

Page 1 of 1
A41197

EXHIBIT 2

Int. CL: 41

Prior U.S. Cls.: 100,101 and 107

Reg. No. 3,015,207

United States Patent and Trademark Office

Registered Nov. is, 200s

SERVICE MARK
PRINCIPAL REGISTER

ALL AMERICAN OPEN

KARATE TAE KWON

DO KUNGFU
CHAMPIONSHIPS

CHO, SIHAK HENRY (UNITED STATES INDIVI-

DUAL)
423 WILDWOOD ROAD

NO CLAIM IS MADE TO THE EXCLUSIVE

RIGHT TO USE KARATE TAE KWON DO KUNG

pu APART FROM THE MARK AS SHOWN.

NORTHVALE, NJ 07647
FOR: ORGANIZING AND CONDUCTING MAR

TIAL 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.

THE MARK CONSISTS OF STANDARD CHAR
ACTERS WITHOUT CLAIM TO ANY PARTICULAR

FONT, STYLE, SIZE, OR COLOR.

SER. NO,78429,062, FILED 6-2-2004.

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

ALL AMERICAN OPEN

KARATE TAE KWON
DO KUNGFU
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 Information
Mark 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 whole

Claim:

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

Class Status:

U.S Class(es): 100,101,107

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

Filed ITU: No

Currently ITU: No

Amended ITU: No

Filed 44D: No

Currently 44D: No

Amended 44D: No

Amended 44E: No

Filed 44E: No

Currently 44E: No

Filed 66A: No

Currently 66A: No

Filed No Basis: No

Currently No Basis: No

Amended Use: No

Current Owner(s) Information

Owner Name: Cho, Sihak Henry
Owner Address: 423 Wildwood Road

Northvale, NEW JERSEY 07647

UNITED STATES

Legal Entity Type: INDIVIDUAL

Citizenship: UNITED STATES

Attorney/Correspondence Information

Attorney of Record
Attorney Name: KENNETH K CHO
Attorney Primary Email officeaction@aol.com

Attorney Email Yes

Address:

Authorized:

Correspondent
Correspondent KENNETH K CHO
Name/Address:

PO BOX 110
PO Box 110

NORWOOD, NEW JERSEY 07648

UNITED STATES

Phone: (917)699-1528

Fax:

Correspondent e-mail: officeaction@aol.com

(201)750-2739

Correspondent e-mail Yes

Authorized:

Domestic Representative - Not Found

Prosecution History
Date

Proceeding

Description

Number

Feb. 12, 2015

TEAS RESPONSE TO OFFICE ACTION-POST REG RECEIVED

Jan. 28, 2015

POST REGISTRATION ACTION MAILED - SEC. 8 & 9

76874

Jan. 28, 2015

CASE ASSIGNED TO POST REGISTRATION PARALEGAL

76874

Jan. 13, 2015

TEAS SECTION 8 & 9 RECEIVED

Jul. 13,2011

NOTICE OF ACCEPTANCE OF SEC. 8 & 15-MAILED

Jul. 13,2011

REGISTERED - SEC. 8 (6-YR) ACCEPTED & SEC. 15ACK.

70619
70619

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 RECEIVED

Aug. 23, 2005

PUBLISHED FOR OPPOSITION

99888

Aug. 03, 2005

NOTICE OF PUBLICATION

May 03, 2005

LAW OFFICE PUBLICATION REVIEW COMPLETED

76568

Apr. 29, 2005

ASSIGNED TO LIE

76568

Apr. 18, 2005

APPROVED FOR PUB - PRINCIPAL REGISTER

Apr. 15, 2005

EXAMINER'S AMENDMENT ENTERED

76529
76529

Apr. 14, 2005

ASSIGNED TO LIE

Apr. 14, 2005

EXAMINERS AMENDMENT MAILED

Apr. 14, 2005

EXAMINERS AMENDMENT -WRITTEN

Jan. 07, 2005

NON-FINAL ACTION MAILED

60792

Jan. 06, 2005

NON-FINAL ACTION WRITTEN

60792

Jan. 05, 2005

ASSIGNED TO EXAMINER

60792

Jun. 09, 2004

NEW APPLICATION ENTERED IN TRAM

Maintenance Filings or Post Registration Information

Affidavit of Continued Section 8 - Accepted
Use:

Affidavit of Section 15 - Accepted

Incontestability:

TM Staff and Location Information

TM Staff Information - None
File Location
Current Location: TMEG LAW OFFICE 106

Date in Location: Jan. 28, 2015

EXHIBIT 3

Page 1 of 3

All American Open Tae Kwon Do/Karate/Kung Fu Championship

#W*

2015

All American Open

Tae Kwon Do - Karate - Kung Fu
Championships
Our 50th Annual Championship is scheduled for:
Saturday. March 7.2015

Long Island University's Brooklyn Campus

1 University Plaza, Brooklyn, NY 11201
(Flatbush Ave at DeKalb Avenue)

Henry Cho
For further information:

CALL: (917) 45J-9349

Instruction

E-MAIL: agkimmclhi aul.com

or
HenrvCho(fijaol.com

Tournament

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

Seminars

Books

SCHEDULE OF EVENTS:

9:00 AM: Late Registration

10:15 AM: Judges meeting
10:30 AM: Opening Ceremony
11:00 AM: Children's FORMS
12:00 PM: Children's SPARRING

1:00 PM: BRAKING & WEAPONS FORMS (All Ages)

Videos
Contact

2:00 PM: Adults Black Belt & Advanced FORMS

3:00 PM: Adults FORMS & SPARRING
SPECTATOR TICKETS:

Children (10 and Under): $5.00

General Admission: $10.00
ADVANCE TICKETS:

For additional information and entry blanks write to:

Master Arthur Kimmel, Tournament Promoter

Way of Action, Inc.

316 7thStreet, 2nd Floor

50th All American Open

Championships

Brooklyn, NY 11210
Tel: (917) 453-9349

Email: 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 under
18 years of age), then mail it with a self-addressed stamped envelope and
entry fee to the address above. When your entry is accepted, a contest
card will be sent to you. If your entry is received after March 1, it will be
held at the entrance of the Main Gym. Show your I.D. and pick it up at the
Registration Table.
ENTRY FEE

http://www.henrycho.com/tourn.html

2/13/2015

All American Open Tae Kwon Do/Karate/Kung FuChampionship

Page 2 of 3

1. If you register by mail before March 1,2015.

$50.00For Free Sparring, 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, feet
and head are mandatory.

ACCOMMODATIONS:

Local Area Hotels:

Youmaycontact the following hotels for availability and pricing:

(1) Sheraton Brooklyn New York Hotel

228 Duffield St., Brooklyn, NY 11201

TEL: 1-855-239-9480
(2) Hotel Indigo Brooklyn

229 Duffield St., Brooklyn, NY 11201

TEL: 1-866-573-4235

(3) Aloft NY Brooklyn Hotel

216 Duffield St., Brooklyn, NY 11201

TEL: 1-866-767-0278

Categories of Competition (i.e., contests)

Directions to LIU

What is the All American Open?

The All American Open Championship was started in 1965 to
promote the principles of the American Martial Arts. It has been
held every year since and draws contestants from all around the

world. The All American Open is presently recognized as one of the

nation's major martial arts tournaments.

The All American Open was held in Madison Square Garden Center
in New York City for twenty-three consecutive years, from 1967 to
1989. It was at the 1967 All American Open where Chuck Norris and
Bruce Lee first met. The All American Open has been continued and
staged outside the Garden since 1989, and we are proud to say that
many famous champions have participated and won in the All
American Open.

The all American Open provides an opportunity for practitioners of

all styles to meet and compete against each other in a spirit of
cooperation and harmony. The tournament rules are specifically
formulated to cover all the major styles and not favor one over the
others.

What is Tae Kwon Do?

What is Karate?

What is Kunq Fu?

Home Page

http://www.henrycho.com/tourn.html

2/13/2015

All American 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

2015

All American Open

Championships

Tae Kwon Do

Karate/ Kung-Fu
*

The 50th
To be held in the Paramount Gym ofLong Island University's Brooklyn Campus, located atI University
Plaza, Brooklyn, NY11201 at 10:30a.m. on Saturday, March 7, 2015.
(Registration begins at 9:00am)
Check the divisions
visions ^you enter belo w:
m

FORM CONTEST

( ) Tae Kwon Do Hyung

(II) BREAKING CONTEST

mn FREE SPARRING
()Mcn
() Women
( ) Senior
() Children

() Adults Breaking
() Children's Breaking

() Karate Kata
() Kung-Fu Form

( ) Senior Form (all styles)

() Weapons Form
{) Free Style form
() Masters Form (all styles)

WHO ARE YOU?

() 6 Years & Under

() 7-8 Year Olds
() 9-10 Year Olds
() 11-13 Year Olds
(J14-16 Year Olds
017-39 Year Olds
() 40 Year Olds '+'

(Please type or print the following:)

Name

Age_

Address

(Apt. No._
Zip

State

Home Phone: (

Fax: (
Belt Color

School Address

Lbs.

J. City.

)_
Style studied

Instructor's name
School name

_Wgt._

E-mail Address:

)_

Your rank

.Hgt_

Sex

His e-mail address:

. Phone: (

. pax:(

City

)_

State

Zip

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 Brooklyn
Campus; theEstate, Heirs andExecutors of S. Henry Cho, theEstate Heirs andExecutor of Linda Lutes, andArthur Kimmel for

any injuries that I may sustain during my participation inthe competition. I also assume full responsibility for any ofmy actions
during and inconnection with said tournament. I agree that my performance orattendance atthe competition orboth may be
filmed orotherwise recorded ortelecast live and I consent to theusebytheEstate of S. Henry Cho, SHC Associates, Inc., and

Way 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.
Signature_

Date

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 "Way of Action, Inc." and send it to:
Way of Action. Inc.. 316 7* Street. Brooklyn. NY 11215.

(NO PERSONAL CHECKS ACCEPTED/ NO REFUNDS).

Visit our website; www.henrycho.com

D2015S.H. Cho

2015
All American Open
Championships

Tae Kwon Do

Karate /Kung-Fu
The 50th

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 of martial arts.
9:00am- Registration.
10:15am- Judges Meeting.
10:30am- Opening Ceremony.

EVENT SCHEDULE

DATE: MARCH7,201S(Saturday)
PLACE: Long Island University
(Paramount Gym), Brooklyn Campus

FORM CONTEST

divisions,

and

advanced/Black

Belt

2:00pm- Adults Black Belt Jt Advanced FORMS.

3:00pm- Adults FORMS <t SPARRING.

11:00am- Children's FORMS.

(Any forms of all styles are permitted 3 trophies per Black

belt division. Medals for all other divisions. Divisions may
be added or combined.)
Grand Champion^ The winner of the Masters and
Seniors

12:00pm- Children 'i SPARRING.

1:00pm- BREAKING and WEAPONS (All Ages).

BREAKING CONTEST

FREE SPARRING

Contestants 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.

Grand Champien = The winner of the first place winners of the

Men's Black Belt Drvisions.(4 trophies per Black belt division.
Medals for all other divisions. Divisions may be added or
combined.)

division

champions of Tae Kwon Do, Karate & Kung-fu.

- ADULTS DIVISIONS -

-ADULT'S DIVISIONS-

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

ADULT'S FORMS -

U Men:

(TAE KWON DO/TANG SOO DO FORM)

Q MEN:

D Women (All ranks):

(All Ranks)

BROWN- RED BEIT

fIK & 2K)

YELLOW-ORANGE-WHTTE DIVISION

(KARATE KATA)
0 MflN,;

BLACK BELT DIVISION

- CHILDREN DIVISIONS-

(3K - 6K)

ADVANCED DIVISION

(KUNG-FU FORM)
D

MEN: BLACK BELT DIVISION

ADVANCED DIVISION
BEGINNERS DIVISION

WOMJfiN; BLACK BELT DIVISION

ADVANCED DIVISION
BEGINNERS DIVISION

(SENIORS FORM) -40&older

(All styles of men and women)
BLACK BELT, ADVANCED & BEGINNERS

YELLOW-ORANGE-WHITE BELT

0 13 year olds & Younger: - 12"x 7" size board.

Advanced

& Beginners

(7K-10K)

Divisions

D WOMEN

Other divisions may be created or reapportioned.

3 Trophies for each Black belt division.

(17-39 yra old)

3 Medals for each under belt division

D SENIORS

(M&W 40 +)

OF THE ALL AMERICAN OPEN

KARATE TAE KWON DO KUNG-FU

CHAMPIONSHIPS by

Children's Biack-Brown-Red Divisions.

WHITE-YELLOW-ORANGE DIVISION
GREEN BELT & HIGHER DIVISION

BLACK- BROWN-RED DIVISION

Way of Action, Inc.

D PEE WEE fMYcM-Oldrt: By Size

Beginner (Wht-Ycl-Orangc)Belt Division
Intermediate (Purp-Blue-Grcen) Belt Division
Advanced (Blick-Brown) Belt Division

(SATURDAY)

Q SUPER PEE WEE fl-llYaroyit By Size

Beginner (Wht-Yel-Orangc)Belt Division
Intermediate (Purp-Bluc-Grccn) Belt Divisit
Advanced (Black-Brown) Bell Division

LONG ISLAND UNIVERSITY

(PARAMOUNT GYMNASIUM)
1 University Plaza
Brooklyn, NY 11201

D JUNIOR (11-13 Year Ofcfr): By Size, gender

Beginner (Wht-Yel-Orange)Belt Division, (Boys)

Intermediate(Purp-Bluc-Grecn) BeltDivision,(Boys)
Advanced (Black-Brown)Belt Division,(Boys)
Beginner (Wht-Ycl-Orangc)Belt Division, (Girls)
Intermediate (Purp-Blue-Grcen) Belt Division, (Giils)

0 PEE WEE: (7-8 Year ObU)

WHITE-YELLOW-ORANGE DIVISION
GREEN-PURPLE-BLUE DIVISION
BLACK-BROWN-RED DIVISION

D SUPER MINI PEE WEK: (MOYearOhfa)

WHITE-YELLOW-ORANGE DIVISION
GREEN-PURPLE-BLIJE DIVISION
BROWN-RED-BIACK DIVISION

(11-12-13 Year Olds)

WHITE-YELLOW-ORANGE DIVISION
GREEN-PURPLE-BLUE DIVISION
HLACK-BROWN-RED DIVISION

D TEENS:

(14-15-16 Year Olds)

WHITE-YELLOW-ORANGE DIVISION
GREEN-PURPLE-BLUE DIVISION
BROWN-RED-BLACK DIVISION

For Information

Way of Action, Inc.

316 7* Street,Brooklyn,NY 11215

When your entry is accepted, a Contest Card
will be sent to you. If your entry is received after
March i, it will be held at the entrance of the Main

Gym. Show your I.D. and pick it up at the desk.

1.

Advanced (Black-Brown)Bdt Division , (Boys)

TEL: (917) 453-9349 / FAX: (718) 330-0254

Beginner (Wht-Yel-Orange)Belt Division, (Girls)

Intermediate(Purp-Bluc-Grecn) Belt Division, (Girls)
Advanced (Black-Brown) Belt Division, (Girls)

E-mail: agklmmelQaol.com
Website: www.henrycho.com
DIRECTIONS-to.,,
From Manhattan - Via Manhattan Bridge

DeKalb and Flatbush Aves.

Via Brooklyn Bridge

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

By Subway:

The LIU Brooklyn campus is served bv all major

subway tines IRT 4 or 5 train (Lexington Avenue Line)
or 2 or 3 tram (Seventh Ave Line) lo Nevins St Station:
BMT; B. Q. or R tram lo DeKalb Ave Station. TND A.

C, or G tram (Eighth Ave Line) to Hoyl Schermerhorn St

Station. For sub\va\ info,

visit htlp./Avww rnla.mfo/nvct

ACCOMMODATIONS:
Local Area Hotels:

You may contact the following hotels for availability

and pricing:
(1) Sheraton Brooklyn New York Hotel

228 Duffield St., Brooklyn. NY 11201

From Queens

Take the Brooklyn-Queens Expressway (west) lo Tillarv

St Exit Keep right on Tillary St Follow Tillarv St lo

Beginner (Wht-Ycl-Orangc)Belt Division, (Boys)

Intermediate(Purp-Blue-Grcen) Belt Division.(Boys

316 7th Street

Brooklyn, NY 11215

right on Ashland Place and go 2 blocks to DeKalb Ave

and turn right The campus is on the right at comer of

Fill out an entry blank(www,henrycho com) and sign.

(Guardian's signature is required if under 18 years of
age.) Then, mail it with a self-addressed, stamped
envelope and entry fee to (before March 1, 2015):

q TEENS(14lol6vearaofc): By Size . gender)

Master Arthur Kimmel

Take Flatbush A\ e Extension, turn left on M\ ille Ave.

REGISTRATION:

Advanced (Black-Brown) Belt Division, (Girls)

Way of Action, Inc.

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

CHILDREN'S DIVISIONS Intermediate (Purp-Blue-Grecn) Bell Division

Advanced (Black-Brown) Belt Division

MARCH 7, 2015

0 MINI PEE WEE: (Up to 6 Year Olds)

Black Belt Division

Advanced Division

0 MINI PEE WEE fUn to 6 Yr OMst: By Size

Beginner (Wht-Yel-Orange)Belt Division

(WEAPONS FORM)

Children's Grand Champitra: The winner of

Black Belt Division

Brown Red Division

Beginner Divisio

50th ANNUAL PRESENTATION

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

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

KARATE)

OncDivisi

Purple- BlueGreen Division

Ycl - Orange -While Division

(MASTERS FORM - 5th DAN +)

(All styles of men and women)

One Division

Advanced & Beginners Divisions

ADVANCED DIVISION

BEGINNERS DIVISON

One Division

PURPLE - BLUE-GREEN BELT

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

BEGINNERS DIVISION

D WOMEN: BLACK BELT DIVISION

Heavy Weight- (178 Lbs+)

Lt-Hvy Weight (162-177 Lbs)

Middleweight (145-161Lbs)
Light Weight (144 Lbs-)

1-2 Divisions

PURPLE-BLUE-GREEN DIVISION

G WOMEN: BLACK BELT DIVISION

BROWN-RED-PURPLE-BLUE DIVISION
GREEN-YELL-ORANGE-WHITE DIVISION

MEN.
BLACK BELT:

Brown-Red-Purple-Blue Beit Division

Green-Yellow-Orange-White Division

BLACK BELT DIVISION

BROWN-RED BELT DIVISION

Black Belt Division

TEL: 1-855-239-9480

(2) Hotel Indigo Brooklyn

229 Duffield St.. Brooklyn, NY 11201

ENTRY FEE:

Flatbush Ave and make a left, then a left on M\ rtle Ave

TEL: 1-866-573-4235

(If you register by mail before March 1,2015)-

and a right on Ashland Place Go 2 blocks and turn riglu

on DeKalb Ave The campus is on (he light at comer of

(31 Aloft NY Brooklyn Hotel

$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.

DeKalb and Flatbush Aves.

From Staten Island or Brooklyn

Take the BrookKn-Queens Expressway (east) to

D SPECTATOR TICKETS:

Cadman Pla/a West Follow Cadman Pla/a West lo

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

Tillarv St. Bear right on Tillarv St and keep nghl.

crossing Flatbush Ave Extension and bearing right onto

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

Na\\ St. which becomes Ashland Place Proceed to

DeKalb Aveaid turn right The campus is on the right at

corner of DeKalh and Flatbush Aves

216 Duffield St, Brooklyn, NY 11201

TEL: 1-866-767-0278

D ADVANCE TICKETS:
Send Money Order to:
Way of Action, Inc.

316 7th Street, Brooklyn,NY 11215

TEL: (917)453-9349/ FAX: (718) 330-0254
E-MAIL: agkimmel@aol.com.

PLEASE

POST

AllAmerican Open
Championships

mm~\

Tae Kwon Do

^^^^.ZP Karate/ Kung-Fu

*

The 50th
February 6, 2015

On behalfof S. Henry Cho Tae Kwon Do and the late Grandmaster S. Henry Cho, we

cordially invite you, your students and your martial arts schools to attend the 50th Anniversary

Celebration ofthe AllAmerican Open Karate Tae Kwon Do Kung Fu Championships to be

held 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 to
compete against each other, while fostering camaraderie amongst the competitors, spectators,
teachers and Masters. This 50th year anniversary event will provide an opportunity to celebrate
50 years of American Martial Arts tradition, and pay tribute to the late Grandmaster S. Henry
Cho.

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

historical events.

More information can be found atthe website httD://www.henrvcho.com/tourn.html

(under the "tournament" tab) or you may email Master Kimmel at agkimmel@aol.com (tel: 917453-9349) 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 Giordano

Grandmaster Frank Rodriquez

Master John R. Sano
Master Thomas Scala
Master Hal Schiff

Master Nicolas Gonzalez, San German Tae Kwon Do

Master Arthur Kimmel, Way of Action, Inc.
Master James Auteri
J.B. Miller

Lisa Alonzo

Kenneth and David Cho

AllAmerican Open
Championships

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Tae Kwon Do

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The 50th
February 6, 2015
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-4 44 http://www. henrycho.com/tourn.html 44 agkimmel@aol.com tel: (917) 453

-9349 or shenrychotkd@gmail.com tel: (917) 699-1528 5.^4 44^ 4^44.
444qq.

S. Henry Cho Tae Kwon Do (50th Anniversary Tournament and Dinner Committee)

Grandmaster Filipo Giordano

Grandmaster Frank Rodriquez

Master John R. Sano

Master Thomas Scala

Master Hal Schiff

Master Nicolas Gonzalez, San German Tae Kwon Do

Master Arthur Kimmel, Way of Action, Inc.

J-B. Miller
Kenneth and David Cho

Master James Auteri

LisaAlonzo

EXHIBIT 5

AGREEMENT

This AGREEMENT made on the 4th day of November, 2005 ("Effective Date"), by and
between Grandmaster S. Henry Cho on behalfof the SHC Associates, Inc., with a mailing
address at P.O. Box 495, Tappan, New York 10983, U.S.A. ("Headquarters"); and Behdad David
Moradi, 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 nationally
recognized martial arts tournament known as the All American Open Tae Kwon Do Karate
Kung-Fu Championship Tournament ("All American Open") which has been promoted for more
than 40 years;

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

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

1. Grandmaster S. Henry Cho shall license the exclusive rights to promote and operate the
All 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 of past martial arts competitors, schools, clubs and/or
organizations;
1. Student shall grant Grandmaster Cho the right to use the database
once the ownership therein is transferred;
iv. use the "know-how" required to organize, plan and run the All American
Open; and
v. use the "goodwill" that have been developed and associated with the All
American Open during the past 40 years.
2. As consideration for the rights granted in paragraph 1, Student shall pay the sum of
iollars to Grandmaster Cho.

For convenience, Student may pay five installments of4

dollars 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 no

later than December 31, 2005, and the second payment of

gmmmnll be due seven days before the scheduled 2006 tournament date. The
remaining 4installments may be paid at the end ofthe year and one week before
the event accordingto the same schedule.

b All Entry Blanks will be maintained by Grandmaster Cho until the entire amount
in paragraph 2above is received from Student. After the entire consideration is

paid the Student will then have the rights and licenses set forth in Paragraph 1but
will continue to provide copies ofthe Entry Blanks to Grandmaster Cho so that
Grandmaster Cho may update and use the database ofcompetitors, schools, clubs
and/or organizations.

3 Grandmaster Cho will use his reasonable efforts to invite and encourage other Marial arts
masters and schools to participate in the All American Open and also encourage the

participation offoreign branch schools. To the extent possible, Grandmaster Cho will try
to attend the Opening Ceremony at the All American Open and, ifpossible, the dinner at
the conclusion of the event.

4 Student shall be liable for all expenses associated in planning, promoting and operating
the All American Open including but not limited to rental fees for the venue, printing

charges 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 an

expense and such expense shall be reimbursed back to Grandmaster Cho by

Student uponpresentation of thereceipt.

5 Student acknowledges that there are "goodwill" and intangibles associated with the All
American Open and Grandmaster Cho's reputation, and Student agrees to uphold these
values, traditions and good sportsmanship.

6 In the event ofan incapacitating illness ordeath ofGrandmaster Cho, then this agreement

will remain binding between Student and Grandmaster Cho's surviving spouse or heirs
and 10% ofnet proceeds from the All American Open shall be paid to Grandmaster
Cho's surviving spouse or heirs solong as shesurvives.

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

8 Student will have no rights to the video and photographic footage from the first forty

years ofthe All American Open and for those All American Open tournaments held while
Student is making payments pursuant to Paragraph 2(a). Grandmaster Cho will own or
continue to own these rights. After the entire consideration inParagraph 2 ispaid, then
Student 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 is paid infull.
Once Student has paid the consideration in full, then Student shall provide Grandmaster
Cho with copies ofany and all video and photographic footage requested byGrandmaster
Cho, along with alllegal rights and permissions to usethis footage.

9. Ifthe All American Open isnot held for three consecutive years during the 15 year period
starting from the Effective Date, then the rights granted inthis Agreement will revert
back 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 all
moneys from sponsorships, television rights or movie rights that are provided for or based
on the All American Open.

a. The remaining 80% ofthe moneys from sponsorships, television rights ormovie

rights will be shared equally between Grandmaster Cho and Student (i.e.,
Grandmaster Cho shallreceive 40% and Student shall receive 40%).

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

11. The Student willnothave anyrights to thename, likeness, trademarks, goodwill or the
like of Grandmaster S. Henry Cho or SHC Associates, Inc.

12. The Student agrees tobe subject to personal jurisdiction inthe State ofNew Jersey, the
United States of America, and accepts and acknowledges thejurisdiction of theUnited
States courts pertaining to anydispute, which may arise under this agreement.
13. The Student shall indemnify and hold harmless Grandmaster S. Henry Cho, his

representatives, SHC Associates, Inc, the World Council ofMartial Arts organization and
any other Branch Schools from any and all losses, claims or causes ofaction including
but not limited to any incidental and consequential damages arising outofor in any way
associated with the Student engaging inMartial Arts training and business, and operating

and promoting the All American Open mcluding, but not limited to, the reasonable costs
and attorney's fees.

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

15. Student acknowledges that the terms ofthis Agreement areConfidential and that any

disclosure by Student ofthe terms ofthis Agreement requires the prior written consent of
Grandmaster Cho.

Page 3 of4

16. Any provision or provisions of this Agreement which in anyway contravenes thelaws of
New Jersey or theUnited States of America shall be deemed separable and shall not
affect any other provisionor provisions ofthis Agreement.

IN WITNESS WHEREOF, theparties hereto havecaused this agreement to be executed

as of the date and year first above-written.
S.Henry
Signed in the presence of:

Behdad David Moradi

Westchester Tae Kwon Do Academy, Inc

10RyeRidgePlaza, #32
Rye Brooli

Page 4 of4

EXHIBIT 6

Estate of Sihak Henry Cho

423 Wildwood Road
Northvale, NJ 07647

February 10, 2014

viaemail (westchestertkd@aol.com) and U.S. Mail

Behdad David Moradi
Westchester Tae Kwon Do Academy, Inc.
116 North Main Street, 2nd Floor

Port Chester, NY 10573

Re: November 4,2005 License Agreement

Dear David:

We are hereby providing you with notice ofyour breach ofthe November 4,2005 license

agreement between Westchester Tae Kwon Do Academy, inc., and SHC Associates, Inc. (hereinafter
referred toas the"AAO Agreement") and, on behalf ofthe Estate ofSihak Henry Cho, we terminate all
licenses 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 iin
the amount of$ 495.00 made out to Myung Sook Cho purportedly for10 percent ofthe net proceeds
from the March 16,2013 All American Open Karate tae Kwon Do Kung-Fu Tournament (hereinafter
"2013 All American Open"). We are also in receipt ofthe copies ofthe Entry Blanks from the 2013 All
American Open which you hand-delivered to Kenneth Cho on January 17,2014in Puerto Rico. We note
that all these actions evidenceyour continued acknowledgement and acceptance of your ongoing
obligations 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 profit
amount issignificantly lowerthan previous years and is lessthan 50 percent of the net profits when the
tournament was run at Manhattan or Queens College. The numbers that you provided don't make

sense basedon the 48 year history of this tournament. Weare not able to reconcile the fact that while
you have a lower expense profile running the tournament at LIU's Brooklyn Campus (no rental fee to use
the gym), more net profit was made when the tournament was held at Manhattan College (Draddy Gym
with a gym rental fee of around$ 5,000) with a higher expense profile. We are unable to ascertain
whether this decrease in net profits isa result of underreportingor mismanagementof the All American
Open. We formally request an accounting of all the income and expenses (in more detail than
previously provided inyour AAO Settlement letter) for the last five years, 2009- 2013,of the All
American Open tournaments.

Yourfailure to hold the tournament at a more high-profile venue (like Manhattan or Queens

College), the continued erosion of profitsand your mismanagement of the All American Open are

Behdad David Moradi

February 10,2014
Page 2 of 3

damaging Grandmaster Cho's reputation and damaging the goodwillassociated with the trademark ALL
AMERICAN OPEN KARATE TAE KWON DO KUNG-FU CHAMPIONSHIPS.

Furthermore, your breach of the June 22,2004 agreement between Westchester Tae Kwon Do

Academy, Inc. and SHC Associates, Inc. (the "Grade Promotion Agreement"), as outlined in our letter of
January 30, 2014, hasalsodamaged the reputation of our late father. Grandmaster S. Henry Cho and S.
Henry Cho Tae Kwon Do; and the goodwill inthe All American Opentournament and trademark which
our father actively promotedfor morethan 4 decades. More specifically, with respect to at leastthe
October13,2012 and October27,2013 Grade Promotion Tests,you misled GrandmasterGiordano and
Masters Schiff, Kimmel and Arteri into convening S. Henry Cho Tae Kwon Do Grade Promotion/test
committees, misused the resources of S. Henry Tae Kwon Do and failed to submitthe appropriate
documentation andfees. Such actions are damaging our father's reputation and the goodwill that is
associated with the ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU CHAMPIONSHIPS trademark

and tournament in a very public way in frontofyour students and the studentsof Grandmaster S. Henry
Cho. These actions are not consistent with being a martial artistandstudentof Grandmaster S. Henry
Cho.

You havefailed to comply with paragraph 5 of the AAO Agreement, which requiresyouto
uphold 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 of
GrandmasterCho and his reputation isthat a student remainsa student ingood standing with
Grandmaster Cho and SHC Associates. This important ethical tenet iseven reinforced inyourblack belt
agreement which you executed in 2009, and which all black belts in S. Henry Cho Tae Kwon Do honor.

However, onJanuary 17and 18,2014, you admitted and acknowledged your breach ofparagraphs 1013 and 16oftheGrade Promotion Agreement by intentionally testing, promoting and issuing your own
diplomas toyour students without theknowledge orconsent ofSHC Associates, Inc., S. Henry Cho's
estate or heirs. You have openly and expressly declared in front ofmasters and students ofS. Henry Cho
Tae Kwon Do thatyou have not been and will not remain a student in good standing with S. Henry Cho
Tae Kwon Do.

We have attached a copy ofanInformation Sheet for the2014 All American Open and note that

it 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 FU

CHAMPIONSHIPS and the Estate did not give Way ofAction, Inc. permission touse the mark, if you
have licensed orgiven Way ofAction, Inc. permission to use the mark ALL AMERICAN OPEN KARATE TAE
KWON DO KUNG FU CHAMPIONSHIPS, then you are also in breach ofparagraph 14ofthe AAO
Agreement by attempting to transfer"... rights orobligations under [the AAO Agreement] without the
prior written consent ofGrandmaster S. Henry Cho" for the2014 All American Open Tournament. Your
attempt to openly advertise that "Way ofAction, Inc." is promoting the March 15, 2014 tournament is

an attempt toeither sublicense ortransfer rights orobligations, orboth, under the AAO Agreement, a
right which you do not have under the AAO Agreement. The Estate of Sihak Henry Cho does NOT
consent to Way ofAction, Inc's use ofthemark. We have notified Way ofAction, Inc. that it has no
rights to use thetrademark ALL AMERICAN OPEN KARATE TAE KWON DO KUNG FU CHAMPIONSHIPS
andthat your actions are in breach ofthe AAO Agreement which hasbeenterminated.

Behdad David Moradi

February 10,2014

Page 3 of 3

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

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

2 The license to use copyrighted materials for the All American Open including but not
limited to posters, handbills, information sheets, contest cards, tickets and the like;
3. The license to use the know-how from theAll American Open; and
4. 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 KUNGFU
CHAMPIONSHIPS or the likeness of Grandmaster S. Henry Cho.

Sincerely,

Kenneth K. Cho

Javia^j
Co-Executors of the Estate of Sihak Henry Cho

EXHIBIT 7

March 5. 2014

Edited

Michael Miller

People

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It's a shame that me and my son Matthew will not attend the 49th Annual
Henry Cho Martial Arts Tournament. For reason(s)we will not attend.Master
David David Moradi,has been an honorable highly qualified director of the
tournament and worked closely with the late founder Master Henry Cho
over the years;and in many people's view, was removed very unjustly from
this position ! For this reason and others.many of us are boycotting the
event Saturday March 15th and won't return if it continues afterwards; and
unless Master David Moradi is put back in his rightful directorship of the
tournament! GREED is a killer of relationships and of excellent programs
established. Me and my son Matthew WAS looking forward to attending
and Matthew competing and now we won't! Shame on GREED!

Posts

James on group's career sccnnl

Association Student passes u

/v* Ohio High School Athletic

wife after her alleged ultimatuml

newborn son with genetic condtl

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character going on dry land

of Wafer Animated film release

-v" The SpongeBob Movie: Sport|

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daily to y./ork given brand new/ c|

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nude with boa constrictor

publishes 20 54 photo of act

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TRENDING

EXHIBIT 8

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

WESTCHESTER TAE KWON DO ACADEMY

HOME OF TRADITIONAL MARTIAL ARTS FOR CHILDREN AND ADULTS

HOME

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Westchester Tae Kwon Do Academy

Martial Arts for Children and Adults

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We are a traditional Tae Kwon Do (Martial Arts) School for children and adults

dedicated to preserving a noble purpose: To develop and serve the Individual, the
Special Event!
American Open
Martial Arts

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

Gaucho Gym

Community and the Arts.

This is accomplished by a disciplined and rigorous regimen of training which brings

together the student and the instructor in an atmosphere of mutual respect. We help
our students achieve a high sense of Self Confidence, Mental Preparedness and
Physical Fitness.

As a center for learning (Do-jang), Westchester Tae Kwon Do Academy provides a

place where students of ALL ages ranging from young children to adults and all walks
of life come together under one roof in an atmosphere of EQUALITY and develop a
sense of community and camaraderie.

478 Gerard Avenue

Bronx, NY 10451

Saturday
February 28, 2015
10:00AM to 8:00PM

2008 Westchester Tae Kwon Do Academy

116 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

yiojruucuuoK

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Heyeveryone!Comejoinme at Ihe OPENMARTIAL ARTSTournament

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Master David Moradi isdoing what ourgreat Grandmaster S.Henry Cho

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thatthiswould be ourGrandmaster's 50thyrand celebrate allthathe

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Master Lemonon February28th. Peace.

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