September 21, 2017

Tim Hortons
Operated by The TDL Group Corp.
Attention: Mr. Jon Domanko, Head of Legal
226 Wyecroft Road
Oakville ON
L6K 3X7


Re :     Notice of Default in relation to The Globe and Mail News Article dated September 15, 2017

We would confirm that TDL Group Corp. (“TDL”) has served Default Notice on all GWNFA Board Members dated September 18, 2017.

It is alleged that Board Members have directed, authorized and/or permitted the provision of confidential information to Don Schroeder who in turn communicated confidential information to The Globe and Mail.  That is false and we know of no facts to support the same.

We acknowledge that Mr. Schroeder may have communicated with The Globe and Mail but he did not provide any confidential information to them.  We have no knowledge as to how The Globe and Mail came into possession of any confidential information, assuming that it did.

In our view, the sole purpose of the Notices of Default is to continue the pattern of conduct of TDL to intimidate GWNFA and the efforts of the franchisees to associate in order to advance their interests consistent with their rights under the Arthur Wishart Act.  In doing so, TDL is actively and in bad faith interfering with franchisees’ right to associate and directly or indirectly penalizing or threatening franchisees who choose to associate.  That pattern of conduct will no longer be tolerated and we are in the process of directing our counsel, Himelfarb Proszanski, to take appropriate legal action to restrain such conduct including a claim seeking damages.

Our counsel will be in touch with you shortly.


Yours truly,

Great White North Franchise Association (GWNFA)

David Hughes

President, GWNFA