BAM’s updated FDD admits that its case against Reckless Ben and “the facts surrounding it” are “material to the decision to enter into a Bricks and Minifigs franchise agreement.”

On September 9, Ammon McNeff signed a certification, under penalty of law, that BAM’s amended disclosure document was accurate and left nothing material out. The document had gone to Wisconsin the day before, the same day BAM’s chief operating officer swore the first takedown notice against this site, and Minnesota made it effective on September 18. Eight of its sentences are set beside the public record below. The record contradicts seven of them.

PRIMARY SOURCEMinnesota Department of Commerce, franchise file 9006, submission 37254-202609. Wisconsin Department of Financial Institutions, file 640999. California Department of Financial Protection and Innovation, entity 655305. USPTO Assignment Center, reel/frame 9331/0033. The federal docket in 2:26-cv-00593 and the Clackamas County register in 24CV06902. All pulled September 25 and linked below.

CONFIRMEDEvery Item of the September document was compared with the April 8 document as filed in Wisconsin and Minnesota. The changes are in Items 3, 5, 6, 13, 19 and 21 and Exhibits H and K. The outlet tables and franchisee lists are unchanged, still dated December 31, 2025.

Eight sentences, beside the record

Each quotation is from the amended document as BAM filed it with Minnesota, linked in full below. After each one, what the public record shows.

CONFIRMEDBAM’s own words, and they bind BAM. Every prospective franchisee in every state now gets a document from the company that names Reckless Ben and says the case and its facts matter to the purchase. The day after Minnesota made the document effective, Matthew McNeff told BAM’s franchisees the plan was to become “more boring and less interesting” and give “no more oxygen,” as reported September 20.

REFUTEDNo court has entered a permanent injunction against Bryan Mansell. The injunction on the docket is the preliminary one of July 7, entered on the parties’ joint motion, which binds all four defendants for the life of the case. On August 27, BAM and Mansell jointly asked Judge David Barlow to enter a permanent consent injunction they had written and to dismiss Mansell from the case, reported here that day. The proposed orders were unsigned when filed, and the docket shows no order through September 22. On August 31, the motion was four days old.

REFUTEDThe complaint BAM describes is the one from April. On August 14 the plaintiffs filed an amended complaint that names Ammon McNeff and Matthew McNeff personally, adds Brandon Best, Josh Johnson and their companies, and pleads racketeering under Utah’s Pattern of Unlawful Activity Act. The rule requires Item 3 to cover suits against the officers listed in Item 2, 16 CFR 436.5(c)(1). McNeff signed the certification 26 days after he was named, and the paragraph does not mention it.

REFUTEDPlastic Palette LLC and Christina Cooper v. BAM Franchising, Clackamas County 24CV06902, filed February 7, 2024: $1,450,000, pleaded as financial abuse of a vulnerable person, over the taking of the Canby store, reported here in August. The court sent it to arbitration and stayed it on May 14, 2024. The register printed July 16, 2026 shows nothing since. A stayed case is a pending case. It is in no edition.

REFUTEDOn June 30, 2026, BAM Franchising assigned “the entire interest” in all thirteen of its marks and applications, the four registrations in Item 13 included, to BAM IP Holdings, LLC. The Patent and Trademark Office recorded it on July 8, reel/frame 9331/0033. BAM Franchising does not own the marks it certified as its own, and whatever lets it license them is an agreement Item 13 says does not exist.

REFUTEDThe interim statements attached to the April document were a “Management Report” for the quarter ended March 31, 2025, prepared April 8, 2025, the same pages the 2025 edition carried. The amendment replaces them with a report through May 31, 2026 and changes the date in Item 21 without noting that anything had been wrong.

REFUTEDCalifornia’s regulator shows BAM’s last application filed April 23, 2025, classed a late renewal, effective July 21, 2025, and nothing filed in 2026. A California registration expires 110 days after the fiscal year ends, 10 CCR 310.120. For BAM that was April 20, 2026.

REFUTEDItem 20 of the same document counts “the unit franchise owned and operated by our subfranchisor in Labrador, Canada.” The May 31 balance sheet carries “BAM Canada Investment, $89,455.05.” The rule requires “separate financial statements for the franchisor and any subfranchisor,” 436.5(u)(1)(v). Exhibit H contains BAM’s alone.

What the admission does

The federal rule lists what a franchisor has to put in Item 3: suits alleging fraud or a franchise-law violation, suits that are material given the size of the system, and suits about the franchise relationship. BAM wrote that its case against Reckless Ben is none of those, then disclosed it anyway, on the ground that the case and the facts around it matter to anyone deciding whether to buy. A franchisor has to hand its disclosure document to a prospect at least fourteen days before the prospect signs. From now on, that document names Reckless Ben. It gives BAM’s reason for suing, “to protect its business interests, brand reputation, and franchise system.” It does not say what the facts are, and it does not say who BAM’s co-plaintiffs are: two of its franchisees, a company of theirs, and both McNeffs. One of the franchisees, Josh Johnson, verified the complaint. The same document’s receipt page lists him as one of BAM’s franchise sellers.

In public, no oxygen. To regulators, material to every sale.

The permanent injunction that was not there

The motion asking for the permanent injunction was filed by Justin Rich of Dentons Durham Jones Pinegar in Salt Lake City. The application that told Minnesota the injunction had been acquired names Manal Hall of the same firm and office as its contact. The Minnesota Franchise Act bars “any untrue statement of a material fact” in a document filed with the commissioner, 80C.13. Wisconsin’s bars a statement “false or misleading in any material respect” in a document filed with its division, 553.41(1). Whether the status of this case is material is a question BAM answered one sentence earlier. The rest of the sentence settles something BAM’s August 19 statement had left open: Mansell’s claims, assigned to BAM that day to be used against “those responsible,” were acquired “against the former franchisee.” The only former franchisees named in Item 3 are the people suing BAM over the Salem store.

It certified the case as material, then misstated its status in the next sentence.

Thirty days

The Salem suit was filed on April 16. On April 17, in Provo, Ammon McNeff certified BAM’s Minnesota renewal, under penalty of law, as free of material omissions; the notary’s stamp is on the page. Minnesota renewed the registration on July 1 and printed an instruction on the order: “Any franchise registration must be amended within 30 days after the occurrence of any ‘material change.’” The statute says the same, 80C.07, and Wisconsin’s says it in 553.31(1). The amendment reached Wisconsin 145 days after the suit was filed and Minnesota 147 days after. It describes the suit as it stood in April, and the Salem store turns up again on the May 31 balance sheet, as “BAMF Salem - Corporate Store Costs, $78,081.94.” Item 3 says BAM denies the seizure. Exhibit H books the cost of running the store. The amendment adds the two cases a buyer finds by searching Reckless Ben. It does not add the one a buyer would not.

It describes the complaint served in April, not the one that names the man who signed.

Where the marks went

BAM IP Holdings, LLC was formed on July 16, 2025, at the franchisor’s own address, with the two McNeffs as its managers, and held nothing for eleven months. The assignment was signed four days after BAM’s case against Reckless Ben was removed to federal court. The rule requires a franchisor to disclose “any currently effective agreements that significantly limit the franchisor’s rights to use or license the use of trademarks,” 436.5(m)(7). Either BAM Franchising has a license from the holding company that its document says does not exist, or it has none and is selling the use of marks it does not own. The one mark not on the reel is the “BAM Franchising” retail-store application of July 15, filed after the assignment.

The franchisor certified as its own a portfolio it had signed away ten weeks earlier.

The money

The new interim report is headed “For management use only.” It covers January through May 2026 and shows a profit. The rest of the balance sheet is below it, to the same scale.

Exhibit H, Management Report for the period ended May 31, 2026, prepared July 22, 2026. Bars are to the same scale.

The cover of the same document still carries the warning the states require, that BAM’s financial condition “calls into question the franchisor’s financial ability to provide services and support you.” California, Illinois, Hawaii and Minnesota make BAM wait for its fee until a store opens, Illinois “due to Franchisor’s financial condition,” and the amendment extends that to area developers. Accounts receivable have grown from $545,676 at the end of 2024 to $1,338,842.82. Three other lines are worth reading. “BAM Orem Store (Kragle Inc), $168,469.54” is a store that Item 2 calls the McNeffs’ own franchisee and Exhibit F calls a BAM-operated store. “Loan from Matt Thomas, $12,050.91” is money BAM owes the man Ammon McNeff testified in 2023 was its director of operations. “BAM Canada Investment, $89,455.05” sits beside a subfranchisor that Item 1 never mentions.

Five months of profit. Three hundred thirty-nine thousand dollars in checking.

California

California is BAM’s largest state: 20 stores at the end of 2025 by Item 20, 24 open and five “coming soon” on the locator today, one of them added on September 17. Under California’s franchise law it is unlawful “to offer or sell any franchise in this state unless the offer of the franchise has been registered,” Corporations Code 31110, and a franchisee sold in violation “may sue for damages” and, if the violation was willful, “for rescission,” 31300. BAM’s franchise-sales site takes inquiries from every state and says nothing about where the company is registered.

Its biggest state is the one where its own document cannot say whether it is registered.

The date

Minnesota’s examiner found one deficiency in the filing: the certification page gave an issuance date that did not match the first page of the document, and the state told BAM to make them agree. The corrected certification says April 8, 2026. So does the cover of the amended document, and the receipt a buyer signs. The receipt is the franchisor’s proof of what it disclosed and when. With two different documents carrying the same date and the same receipt, it no longer proves either. The amendment leaves the outlet tables and the franchisee lists at December 31, 2025 and the fees unchanged. Item 13 adds the two registrations issued May 5 and says nothing about the retail-store mark BAM applied for on July 15 or the brand change it announced to franchisees on September 22, four days after Minnesota’s order. A buyer who signs on this document orders $10,000 to $25,000 of signs under Item 7, “not refundable,” and finds out at BAMcon in October that the brand is changing.

Amended in September. Dated April 8.

The year, in order

The record

The takedown notices BAM has sent this site name pages that reproduced its documents. Everything in this update is published by a state, a court or the Patent and Trademark Office. A prospective franchisee can download the amended document from Minnesota without asking the company for it.

Minnesota, file 9006. Application and certification, September 9 (hosted here). The marked disclosure document, 395 pages. Deficiency notice (hosted) and order (hosted), September 18. The April 17 certification (hosted) and the July 1 order (hosted). The whole file: the department’s search page. Wisconsin, file 640999: the filing details, “File uploaded on 09/08/2026 at 12:41:09,” a clean copy created September 2 by its own metadata. California: the department’s record. The trademark assignment: reel/frame 9331/0033 at the USPTO Assignment Center. The federal docket: 2:26-cv-00593, entries 33 to 40. The April 8 document, Item by Item, at the disclosure document, read against itself.

Sources. Minnesota Department of Commerce, franchise file 9006, submissions 36508-202605 and 37254-202609, downloaded September 25, 2026. Wisconsin Department of Financial Institutions, file 640999, and the document uploaded September 8. California Department of Financial Protection and Innovation, entity 655305, captured September 25. BAM Franchising, Inc., Franchise Disclosure Document issued April 8, 2026, as filed in Wisconsin April 15 and Minnesota May 1, and as amended: the state cover page, Items 1, 2, 3, 5, 6, 7, 13, 19, 20, 21 and 23, Exhibits F, H and K, the state addenda. 16 CFR 436.5 and 436.7; Minn. Stat. 80C.07 and 80C.13; Wis. Stat. 553.31 and 553.41; California Corporations Code 31110 and 31300; 10 CCR 310.120. BAM Franchising, Inc. v. Schneider, 2:26-cv-00593 (D. Utah), docket as mirrored by CourtListener through September 22. BAMF Salem 1, LLC v. BAM Franchising, Inc., No. 260200029, first amended complaint of August 14, 2026. Plastic Palette LLC and Cooper v. BAM Franchising, Inc., Clackamas County No. 24CV06902, register of actions printed July 16, 2026. Deposition of Ammon McNeff, September 21, 2023, in Clackamas County No. 23CV36974. USPTO Assignment Center, reel/frame 9331/0033 and the abstract of title for registration 8,238,024, read September 25. Utah Division of Corporations, BAM IP Holdings, LLC, entity 14592179-0160. BAM’s store locator and franchise-sales site, captured September 25. The right of reply is open to everyone named here.

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