BILL ANALYSIS �
SB 610
Page 1
Date of Hearing: August 13, 2013
ASSEMBLY COMMITTEE ON BUSINESS, PROFESSIONS AND CONSUMER
PROTECTION
Susan A. Bonilla, Chair
SB 610 (Jackson) - As Amended: June 24, 2013
SENATE VOTE : 22-12
SUBJECT : Franchises.
SUMMARY : Revises the California Franchise Relations Act (CFRA)
to explicitly require franchisors and franchisees to deal with
each other in good faith, as defined, in the performance and
enforcement of a franchise agreement; prohibits a franchisor
from restricting the right of a franchisee to join or
participate in an association of franchisees; and authorizes a
private right of action for violation of these provisions that
may be remedied by injunctive relief, damages, rescission,
reasonable costs and/or attorneys' fees. Specifically, this
bill :
1)Requires that franchisors, subfranchisors, and franchisees
deal with each other in good faith in the performance and
enforcement of the franchise agreement.
2)Defines good faith to mean honesty in fact and the observance
of reasonable commercial standards of fair dealing in the
trade.
3)Prohibits a franchisor or subfranchisor from restricting the
right of a franchisee to join or participate in an association
of franchisees to the extent the restriction is prohibited by
existing law.
4)Authorizes a franchisee to file suit against a franchisor or
subfranchisor who offers to sell, sells, fails to renew or
transfer, or terminates a franchise in violation of this bill
for temporary and permanent injunctive relief, and for damages
caused thereby or for rescission or other relief deemed
appropriate by the court; further authorizes the court to
award, in its discretion, reasonable costs and attorney's fees
to a prevailing plaintiff.
5)Permits a franchisor or subfranchisor who becomes liable as a
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result of a lawsuit by a franchisee to make payments to
recover contributions from any person who, if sued separately,
would have been liable to make the same payments.
6)Prohibits a franchisor or subfranchisor from requiring that
the franchisee waive any right provided by this bill as a
condition of doing business with the franchisor or
subfranchisor.
7)Requires that any waiver by the franchisee of a right under
this bill be knowing and voluntary, and not made a condition
of doing business with a franchisor or subfranchisor.
8)Requires that any waiver that is required as a condition of
doing business with a franchisor or subfranchisor be presumed
involuntary, unconscionable, against public policy, and
unenforceable.
9)Authorizes the franchisor or subfranchisor to enforce an
agreement regarding any waiver of rights under this bill if
the franchisor or subfranchisor shows that the agreement was
knowing, voluntary, and not made a condition of doing business
with the franchisor or subfranchisor.
EXISTING LAW:
1)Creates CFRA which:
a) Defines a franchise as a contract between two or more
persons by which:
i) a franchisee is granted the right to offer, sell or
distribute goods or services under the plan or system of
the franchisor;
ii) operation of the business is substantially
associated with franchisor's trademark, advertising or
other symbol; and,
iii) a franchise fee is paid by the franchisee. (Business
& Professions Code (BPC) Section 20001)
b) Excludes from the definition of a franchise those
governed by the Petroleum Marketing Practices Act; lease
departments, licenses, or concessions at or with a general
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merchandise retail establishment; and, a cooperatively
operated nonprofit organization. (BPC 20001)
c) Provides that any condition, stipulation or provision
waiving compliance with the CFRA is contrary to public
policy and void. (BPC 20010)
d) Prohibits termination of a franchise agreement prior to
the end of the term, except for good cause, which includes
failure to comply with any lawful requirement of the
franchise agreement after written notice and a reasonable
opportunity (no more than 30 days) to cure. (BPC 20020)
e) Authorizes the immediate termination of a franchise
agreement without notice or an opportunity to cure in cases
of bankruptcy, abandonment, mutual agreement, material
misrepresentation, failure to comply with the law after
notice, repeated noncompliance after cure, seizure of the
premises by a governmental entity or creditor, conviction
of a felony or relevant misdemeanor, failure to pay
franchisee fees within five days of overdue notice, and
imminent danger to public health or safety. (BPC 20021)
f) Requires a franchisor to notify the franchisee of its
intention not to renew a contract at least 180 days prior
to the expiration of the franchise in specified
circumstances, during which time the franchisee may attempt
to find a buyer acceptable to the franchisor. (BPC 20025)
g) Requires a franchisor that terminates or fails to renew
a franchise without complying with the CFRA to offer to
repurchase the franchisee's resalable current inventory at
the lower of the fair wholesale market value or the price
paid by the franchisee. (BPC 20035)
2)Creates the California Franchise Investment Law (CFIL), which:
a) Makes it a violation of the CFIL for any franchisor,
directly or indirectly, through any officer, agent or
employee, to restrict or inhibit the right of franchisees
to join a trade association or to prohibit the right of
free association among franchisees for any lawful purposes.
(Corporations (CORP) Code Section 31220)
b) Provides that any person who offers or sells a franchise
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in violation of specified sections of the CFIL or in
violation of any provision that provides an exemption from
the requirements of the CFIL, as specified, shall be liable
to the franchisee or subfranchisor, who may sue for damages
caused thereby, and if the violation is willful, the
franchisee may also sue for rescission, unless, in
specified cases, the defendant proves that the plaintiff
knew the facts concerning the untruth or omission, or that
the defendant exercised reasonable care and did not know,
or, if he/she had exercised reasonable care, would not have
known, of the untruth or omission. (CORP 31300)
c) Allows any person who violates the right to free
association to be sued in the superior court in the county
in which the defendant resides or where a franchise
affected by the violation does business, for temporary and
permanent injunctive relief and for damages, if any, and
the costs of suit, including reasonable attorneys' fees.
Further provides that a plaintiff shall not be required to
allege or prove that actual damages have been suffered in
order to obtain injunctive relief. (CORP 31302.5)
d) Prohibits an action from being maintained to enforce any
liability for violation of the right of free association
unless it is brought within two years after the violation
upon which it is based or within one year after the
discovery by the plaintiff of the facts constituting such
violation, whichever occurs first. (CORP 31302.5)
e) Except as explicitly provided, prohibits civil liability
in favor of any private party against any person by
implication from or as a result of the violation of any
provision of CFIL or any rule or order thereunder. (CORP
31306)
FISCAL EFFECT : None. This bill has been tagged non-fiscal by
the Legislative Council.
COMMENTS :
1)Purpose of this bill . This bill aims to shift the balance of
power in franchisor-franchisee relationships by creating a
'right to good faith' in performance and enforcement of the
franchise contract, and providing a private right of action
with explicit remedies to enforce these and other rights. This
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bill is sponsored by the American Association of Franchisees
and Dealers.
2)Author's statement . According to the author, "Franchisees
strongly believe that their business relationship is one-sided
in favor of franchisors?Franchisees suggest that this
disparity could be significantly lessened by several revisions
to the [CFRA]. SB 610 would implement two of their reform
proposals: 1) allowing franchisees to associate freely with
fellow franchisees in their system, and 2) by assuring that
each of the parties deal in good faith. This bill allows
franchisees a limited private right of action to seek
temporary and permanent injunctive relief and damages for
violations of these provisions."
The author also cites an excerpt from a court decision by the
California Court of Appeal (2nd Dist.), which described the
franchise dynamic as follows:
"The relationship between franchisor and franchisee is
characterized by a prevailing, although not universal,
inequality of economic resources between the contracting
parties. Franchisees typically, but not always, are small
businessmen or businesswomen or people seeking to make the
transition from being wage earners and for whom the
franchise is their very first business. Franchisors
typically, but not always, are large corporations. The
agreements themselves tend to reflect this gross bargaining
disparity. Usually they are form contracts the franchisor
prepared and offered to franchisees on a
take-it-or-leave-it basis. (Emerson, Franchising and the
Collective Rights of Franchisees (1990) 43 V and L. Rev.
1503, 1509 & fn. 21.) . . . Some courts and commentators
have stressed the bargaining disparity between franchisors
and franchisees is so great that franchise agreements
exhibit many of the attributes of an adhesion contract and
some of the terms of those contracts may be unconscionable.
Postal Instant Press v. Sealy, 43 Cal. App. 4th 1704,
1715-1717 (1996.)"
3)Current law regulating the franchisor/franchisee relationship .
A substantial part of California franchise law as a whole is
largely embodied in CFIL and CFRA, although certain specific
industries (i.e., filling stations) have their own unique
provisions as well.
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CFIL was enacted in 1970 to regulate franchise investment
opportunities in order to protect California investors from
potentially fraudulent franchise investments. CFIL generally
requires franchisors to disclose to prospective franchisees
the information necessary to make an informed decision about
franchise offers, and prohibits the sale of franchises that
would lead to fraud or the likelihood that a franchisor's
promises would not be fulfilled. CFIL contains explicit
provisions for enforcement generally through damages (payment
for economic losses) and rescission (cancellation of the
contract). It also provides for injunctive relief (to require
or prohibit a specific action), reasonable costs and
attorneys' fees in certain circumstances.
CFRA (which excludes petroleum-related franchises, like gas
stations) was subsequently enacted in 1980 to govern
relationships between franchisors and franchisees after they
have entered into contract with each other. CFRA is designed
to prevent unfair practices in the termination, renewal or
transfer of a franchise. CFRA prohibits termination of a
franchise agreement except for good cause and only after
notice and an opportunity to fix the problem. It also lays
out certain circumstances where immediate termination is
permitted, for example: bankruptcy, abandonment, mutual
agreement, material misrepresentation, illegal activity,
noncompliance with the franchise agreement, failure to pay
franchise fees, and imminent danger to the public. CFRA
prohibits nonrenewal of a franchise agreement without 180 days
prior notice, and with certain additional protections for the
franchisee. It also provides for the transfer of ownership to
surviving spouses or heirs. CFRA does not contain explicit
enforcement provisions except for the buyback of inventory
when a franchise is improperly terminated or nonrenewed,
although general contract remedies may still be available.
In 2012, AB 2305 (Huffman) was introduced to amend both the
CFIL and CFRA to add multiple protections for franchisees and
prohibitions against unfair practices by franchisors. Those
provisions included the same rights of good faith and free
association, as well as the private right of action, contained
in SB 610. It would also have provided protection against
distant legal venues, prohibition of termination without good
cause, time to cure defects in franchise agreement compliance,
12 months' notice of nonrenewal, greater selection of vendors,
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a cause of action for dilution by placement of competing
franchises in close proximity, a duty of competence on the
part of the franchisor, inheritance provisions, requirement of
cause for denial of transfer, a relaxation of standards for a
cause of action, and the potential award of reasonable court
costs and attorney's fees in legal action. That bill died in
the Assembly Business, Professions and Consumer Protection
Committee.
4)Justification for SB 610 . Supporters of this bill point to
both a systemic problem as justification (an imbalance in
bargaining power between the franchisor and the franchisee),
and a host of specific abuses of that power which make this
bill necessary.
As noted above, supporters argue that the inherent asymmetry in
bargaining power enables franchisors to take unfair advantage
of franchisees. Quoting a 1969 treatise on franchises,
entitled "Franchising: A Trap for the Trusting", supporters
say "At the core of the franchise relationship is the
contractual control exercised by the franchisor over every
aspect of the franchisee's business?The franchisor controls
the site, commissary purchases, purchases from other vendors,
methods of business operations, labor practices, quality
control, merchandising, and even record keeping. This control
is buttressed by the contractual requirement that the
franchisee must obey the commands of the Operating Manual as
unilaterally amended from time to time and as expounded by the
franchisor's supervisor, on pain of losing the franchise if he
disobeys them and under constant threat of such termination.
And upon termination, or failure to renew, the franchisee is
confronted with the covenant not to compete and forfeiture of
his equity in the business."
Examples of specific abuses alleged by supporters include:
refusal to communicate with franchisees; putting new and
competing stores in close proximity to the franchisee causing
a unreasonable dilution of profits; unfair terms for renewal,
including expensive investments in facility upgrades and
remodeling; excessive control over advertising rates, building
and equipment standards, and franchisee behavior through
franchisor-sponsored organizations; excessive, compulsory and
distant meetings with heavy associated costs; requirements to
use specific and expensive point of sale software; little
flexibility in changing prices; use of arguable building and
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equipment valuation methods which can reduce the value of a
franchise when being sold back to the franchisor; and the
continued exaction of royalty payments even after a franchise
has gone bankrupt.
The counter argument, of course, is that the franchise agreement
was freely entered into by both parties, and after extensive
disclosures to the franchisee, as required by CFIL.
5)Key components: good faith, free association, private right of
action, waiver protections . This bill contains four key
provisions: creation of a good faith standard; creation of a
right of free association; creation of a right of private
action for franchisees coupled with explicit legal remedies;
and protections against the mandatory waiver of rights.
a) Right of good faith in performance and enforcement . SB
610 requires that parties to a franchise agreement "deal
with each other in good faith in the performance and
enforcement of the franchise agreement." "Good faith" is
defined in this bill as "honesty in fact and the observance
of reasonable commercial standards of fair dealing in the
trade." What actually constitutes good faith in such
relations can be a complex legal question.
Good faith is an implied covenant in contract law, which
means that it is assumed that both parties enter into the
agreement without malicious intent and with a desire for
each party to benefit fairly.
Generally speaking, legal remedies in a contract law
setting are focused on economic compensation that provides
the injured party with the nearest equivalent of the
benefit of the contract, had it been performed.
The Restatement of Contracts, 2d, describes good faith and
fair dealing this way: "Subterfuges and evasions violate
the obligation of good faith in performance even when the
actor believes his conduct to be justified. But the
obligation goes further: bad faith may be overt or may
consist of inaction, and fair dealing requires more than
honesty. A complete catalogue of types of bad faith is
impossible, but the following types are among those which
have been recognized in judicial decisions: evasion of the
spirit of the bargain, lack of diligence and slacking off,
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willful rendering of imperfect performance, abuse of a
power to specify terms, and interference with or failure to
cooperate in the other party's performance." (Rest.2d,
Contracts Section 205, comment (d).)
Presumably, a court wishing to construe the meaning of
'good faith' contained in this bill would look to
California's own Uniform Commercial Code (UCC) for
guidance. The UCC recognizes an obligation of good faith in
the performance and enforcement of every contract or duty,
and defines good faith in a merchant context as "honesty in
fact and the observance of reasonable commercial standards
of fair dealing in the trade." (UCC Section 2-103(1)(b))
Conversely, "bad faith" generally describes behavior that
violates community standards of decency, fairness or
reasonableness.
Despite the existence of this implied obligation under
current law, supporters argue that the covenant is usually
beat out by explicit provisions in the contract. In other
words, supporters argue that franchise contracts are
written primarily to benefit the franchisor, and that the
covenant of good faith and fair dealing is often little
help against the explicit language of a valid contractual
agreement. However, that subordination is undermined if
the covenant is no longer implied in common law but
commanded in statute.
The key element of the good faith requirement is its
breadth - it could be applied to any number of situations
(as the Restatement 2d noted above, "a complete catalogue
of types of bad faith is impossible"). This is viewed as an
advantage to supporters, who view it as a kind of
all-purpose requirement for franchisors to act properly,
giving franchisees new leverage in the context of a
franchise agreement where the written terms can be very
open-ended and quite one-sided. In conjunction with the
newly added private right of action and legal remedies, a
franchisee that feels unfairly treated would have a new
legal tool to seek redress in situations where the
franchise agreement itself provides no obvious remedy.
Supporters note that the states of Iowa, Hawaii and
Washington have enacted similar laws requiring parties to
franchise agreements to deal with each another in good
faith, although it is not known how those statutes have
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been applied or construed.
Unfortunately, opponents view a statutory application of
the same principle as an invitation to contractual anarchy.
It is unclear, they contend, how a court will go about
making a decision when an allegation of bad faith is
brought because of conduct that was specifically authorized
in a valid franchise agreement - does that mean that the
good faith requirement trumps the express language of the
agreement? What standard, for example, would a court apply
to determine a 'good faith' number of required weekly
bathroom cleanings under the Operations Manual, if a
franchisee chose to dispute it? Would a judge be empowered
to rewrite or suspend terms of the contract, whether
directly or indirectly, and then hold the parties
accountable to the new standards for the life of the
contract? This breadth and the uncertainty it introduces,
is a constant theme in opponent communications.
b) The right of free association . This bill prohibits
franchisors from restricting the right of a franchisee to
join or participate in an association of franchisees.
However, such a restriction already exists in the CFIL
(CORP 31220). The only practical difference this provision
may have is that the new remedies created by this bill,
which are slightly broader than those in the CPIL for this
right, would be applicable.
c) A private right of action . The third major component of
this bill is the creation of a private right of action for
the franchisee. This would permit the franchisee to file a
lawsuit against the franchisor alleging a violation of law
and seeking a legal remedy from the court if the franchisor
offers to sell, sells, fails to renew or transfer, or
terminates a franchise in violation of the rights to good
faith and association. The remedies available include an
injunction (an order of the court to require or prohibit a
particular action), monetary damages, rescission
(cancellation of the contract), or "other relief deemed
appropriate by the court." A prevailing franchisee could
also seek reasonable court costs and attorney's fees, at
the court's discretion.
Under contract law, the injured party usually should not end
up in a better financial position after the breach. This
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is different from tort law, which is applied in other types
of relationships where one individual may breach a duty of
care to another, causing them to be personally injured and
thereby creating a cause of action to seek economic damages
(health care costs, lost wages, etc.) and noneconomic
damages (pain and suffering, punitive damages, etc), among
other things. The law of torts exists to compensate a
victim for an injury, but also serves to punish the
defendant and discourage others from negligent or
intentionally harmful behavior in the future.
According to one franchise attorney, the remedies currently
available under CFRA are limited. Other supporters have
said that standard contract remedies can be sought, but
those are often limited and do not encompass noneconomic
damages more commonly found in tort law (i.e., emotional
distress). One federal court decision limited the amount of
damages of a wrongly terminated franchisee to requiring a
buyback of the franchisee's inventory. In comparison, the
CFIL already contains a private right of action, although
the available remedies are narrower. This bill provides
CFRA with broad, clear remedies.
Supporters contend that these remedies make enforcement of
the entire CFRA far more effective, and help rectify the
imbalance of bargaining power and resources between the
franchisor and franchisee. They also argue that franchisors
already have multiple enforcement mechanisms at their
disposal, often within the franchise agreement itself.
Opponents argue that the private right of action, and even
the attorney's fees provision, are unfairly constructed to
be available only to the franchisee, which is illogical
given that the underlying right of good faith applies
equally to both parties.
d) Waiver provisions . Finally, this bill makes clear that
franchise agreements cannot require franchisees to waive
any of their rights under CFRA as a condition of doing
business with the franchisor, unless the franchisee does so
knowingly and voluntarily. Any such waivers would be
presumed involuntary unless proven otherwise. A similar
prohibition on mandatory waivers exists in the CFIL.
6)Arguments in support . According to the American Association
of Franchisees & Dealers, "Modern franchise relationships are
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most always governed by one-sided 'take it or leave it'
adhesion contracts that elicit substantial monetary investment
from franchise owners, but severely limit a franchisees'
rights in the franchise relationship. Creating a statutory
affirmative duty of good faith in franchise relationships will
inhibit the enforcement of one-sided franchise agreements in
an abusive manner. Long term, the best opportunity to create
a level playing field in franchise relationships is to
encourage effective franchisee associations with sufficient
leverage to negotiate franchise agreements and relationships
that respect the legitimate interests of both franchisors and
franchisees. The two prongs of [SB 610], and the included
remedies for violations, will provide significant safeguards
against abuse in franchise relationships."
According to the Pacific Management Consulting Group, which
provides chain restaurant analysis and consulting, "SB 610
creates an affirmative right for franchisees to freely
associate via associations but most crucially, allows for
defined franchisee remedies at law should the relationship run
aground. It creates an affirmative duty of good faith for
both franchisees and franchisors. This is needed because
franchise contracts have become one sided contracts, and
franchisees have few rights. California's franchise code was
last updated in 1986 and needs updating.
"?The opponents of SB 610 have noted that any regulation is too
much, and that SB 610 would destroy the ability of the
franchisor to maintain brand strategies. That is simply not
true?They also maintain that California franchise development
would come to a halt, but they can't answer why then Dunkin
Donuts is now marching into California with a hoped for one
thousand (1000) franchise stores. And they can't answer why
franchising hasn't come to a halt in Iowa, Washington and
Hawai'i, which have [a] similar good faith franchising law on
the books."
The Coalition of Franchisee Associations also contends that
"This will not 'unravel' franchise agreements or weaken brand
standards as opponents claim. In fact, similar language
exists today in Iowa (Sec. 523H.10), Hawaii (Sec 482E-6), and
Washington (Section 19.100.180) Franchising continues to grow
in those states, brand standards are enforced the same, and
there is no increase in lawsuits."
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7)Arguments in opposition . A broad coalition of opponents
writes: "SB 610 seeks to introduce ambiguity into the
franchise contractual relationship by layering on an amorphous
concept of 'good faith' and 'commercial reasonableness in the
trade'. The concept of 'good faith' was created in the [UCC]
to fill in the blanks on short form contracts for the sale of
goods. However, in the context of detailed franchise contracts
which govern complex and ongoing business relationships, it
provides no benefit and creates uncertainty as to the
enforceability of the contracts and standards.
"This, coupled with the one-sided attorney's fees provision,
make this bill a lucrative option for a non-performing
franchise to sue a franchisor if the franchisee later does not
want to abide by the contract and the terms to which they
knowingly agreed. This will lead to costly litigation and
reduce the ability to settle disputes between the parties, and
inferior products and services being delivered to consumers.
Further, the sweeping liability provisions in SB 610 has the
potential to create unlimited damages, not only contract
damages, but tort damages that could mean punitive or other
damages as well. The duty of good faith is so ill-defined that
any kind of claimed violation or minor problem could result in
substantial damages for franchise businesses, ultimately
harming the brand equity for franchisors and franchisees
maintaining the brand standards. On top of all that, the
attorney's fees provision provides an instant incentive to
file suit and ask questions later.
"California law and the Federal Trade Commission require
extensive disclosure documents be provided to franchisees
before entering into a franchise agreement, so both parties
know what is expected of each other. Allowing substandard
franchisees the ability to allege the franchisor's failure to
follow some amorphous standard instead of adhering to their
contractual terms will have a significant negative impact on
franchisors and franchisees who work hard every day to ensure
the integrity of the brands they represent."
8)Related legislation . AB 1141 (Dahle) would enact the Small
Business Investment Protection Act of 2013 to incorporate some
of the good faith and rights association provisions of SB 610
as well as changes to the right to terminate a franchise
agreement. AB 1141 was held in the Assembly Judiciary
Committee.
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9)Previous legislation . AB 2305 (Huffman) of 2012 would have
enacted The Level Playing Field for Small Business Act of 2012
to revise the rights and responsibilities of franchisors and
franchisees as well as the rules that govern the franchise
relationship in California. AB 2305 was held in the Assembly
Business, Professions and Consumer Protection Committee.
10)Double-referral . This bill was heard in the Assembly
Judiciary Committee on June 18, 2013, and was passed out on a
7 to 2 vote.
REGISTERED SUPPORT / OPPOSITION :
Support
American Association of Franchisees and Dealers
C & S Restaurants, Inc.
Coalition of Franchisee Associations
(Asian American Hotel Owners Association, Buffalo Wings
National Franchisee Association, Domino's Franchisee
Association, Dunkin' Donuts Independent Franchise Owners,
Edible Arrangements Independent Franchise Association,
Independent Association of Massage Envy Regional
Developers, Independent Coalition of Franchise Owners,
Independent Hardee's Franchisee Association, Independent
Organization of Little Caesars Franchisees, Long John
Silver's Franchisee Association, Meineke Dealers
Association, National Coalition of Associations of 7-Eleven
Franchisees, National Franchisee Association, North
American Association of SUBWAY Franchisees, Pharmacy
Franchisees and Owners Association, San Francisco -
Monterey Bay 7-11 Franchise Owners Association, Service
Station Franchise Association, Supercuts Franchisee
Association)
Lagarias Law Offices
Pacific Management Consulting Group
Perris Valley Chamber of Commerce
Pinnacle Real Estate Holdings, Inc.
QSR Express, Inc.
Service Station Franchise Association
712 individuals
Opposition
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AAMCO
ACFN Franchised, Inc.
Allied PRA
Always Best Care Senior Services
AmeriSpec & Furniture Medic
Aussie Pet Mobile, Inc.
Bottle & Bottega
BP America (AM PM)
BrightStar Care
California Chamber of Commerce
California Closets
California Grocers Association
California Manufacturers & Technology Association
California Retailers Association
Civil Justice Association of California
FASTSIGNS International
Fatburger
FirstService Brands
FOCUS Brands
(Auntie Anne's, Carvel, Cinnabon, Moe' Southwest Grill,
Schlotsky's)
Franchise Services, Inc.
FranNet
Go Mini's Moving & Portable Storage
Golden Corral - Tracy, CA
Home Instead Senior Care
Interim Health Care
International Franchise Association
Jani-King
Keepsake Companions Inc.
KidsPark
Max Muscle Sports Nutrition
menchie's
Merry Maids
Mr. Rooter of Sonoma County
MSA Worldwide
No Frill Franchising, Inc. - Instant Imprints
Postal Instant Press
Renaissance Executive Forums
Right At Home
Round Table Pizza
Scooter's Jungle
ServiceMaster Clean
Sizzler USA
Sky Zone Franchise Group, LLC
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Star Franchise Association
The Dwyer Group
(AirServ, Glass Doctor, The Grounds Guys, Mr. Appliance,
Mr. Electric, Mr. Rooter, Portland Glass, Rainbow
International)
The Entrepreneur Authority, Auburn CA
The Johnny Rockets Group, Inc.
The UPS Store, Inc.
Two Men And A Truck
West's Insurance Agency
2 individuals
Analysis Prepared by : Hank Dempsey / B.,P. & C.P. / (916)
319-3301