# Ranked by Item 19

Item 19 is the part of a Franchise Disclosure Document that may include a
financial performance representation. It is optional. A franchisor may make
one, with the substantiation the Franchise Rule requires, or may state that
no representation is made. This ranking splits the live US offerings in the
set along that line: filings that make an Item 19, and filings that do not.

A “Yes” is not a typical-store number. It is a prompt to read which outlets
are in the sample, which period is measured, whether the figures are revenue
or profit, and how many units were excluded. A “No” is not a finding that the
restaurants lose money. It is a finding that the dated source does not
authorize a performance claim of that kind. The
[FTC's franchise guide](https://www.ftc.gov/business-guidance/resources/consumers-guide-buying-franchise)
treats Item 19 as one item among twenty-three, not as a substitute for the
rest of the document.

The [field guide's Item 19 chapter](https://qsrfieldguide.com/item-19/) is the
method for reading a sample. This page only shows which brands in the
directory have one on file.

## What “makes a representation” covers in this set

Nine live offerings have Item 19 marked yes in the dataset: Döner Haus,
German Doner Kebab, The Great Greek Mediterranean Grill, Dog Haus, Pepper
Lunch, Capriotti's, Wienerschnitzel, Mad for Chicken and 375° Chicken 'n
Fries. Four live offerings do not: The Halal Guys, Shah's Halal Food, Crave
Hot Dogs and BBQ, and bluTaco.

Where the brand record includes a note on the population, the table prints
that note. Where it does not, the table only records that a representation is
made. Dog Haus, Pepper Lunch, Capriotti's and Wienerschnitzel fall in that
second group in the May 2024 comparative study of published FDDs: Item 19 is
present, and this desk does not invent the sample those study rows omitted.

The notes that do exist describe very different samples. Döner Haus's 2026
Franchise Disclosure Document covers a system with a short operating history,
corporate stores and early franchised units. German Doner Kebab's FDD issued
3 September 2024 covers one franchised outlet at American Dream Mall in East
Rutherford, the only unit open for the full reported year. Those are not
interchangeable evidence. One is a young mixed-ownership set; the other is a
single mall restaurant.

The Great Greek's FDD issued 17 August 2023 goes further on cost: gross
revenues, cost of goods and payroll for six affiliate restaurants, plus the
highest and lowest of six franchise restaurants open two years. That is still
a defined subset of a 31-outlet system, not every store and not a promise
about a new site.

Mad for Chicken's FDD issued 3 May 2024 presents unaudited 2022 and 2023
gross revenue for twelve affiliate outlets and three franchised outlets.
Revenue only: no costs and no profit, and the affiliate group is larger than
the franchised group. 375° Chicken 'n Fries, FDD issued 30 April 2024, uses
an unaudited income statement for the affiliate that operates the restaurants,
covering 2020 through 2023, and states 2023 results across two corporate
shops. Corporate-affiliate figures are not franchisee results.

<div class="checklist" markdown="1">

When Item 19 is “Yes”

- Record the metric: revenue, selected costs, net, or an income statement.
- Record the population: franchised, company, affiliate, or a named subset.
- Record the period and whether figures are audited.
- Record how many outlets were open for the full period and how many were left out.
- Do not average two brands' samples, and do not treat a one-store year as a system forecast.

</div>

## What “No” covers in this set

Shah's 10 April 2024 FDD states that no financial performance representation
is made. The Halal Guys, Crave and bluTaco have no Item 19 in the May 2024
study rows. Absence is especially easy to misread on a well-known brand.
Halal Guys records 93 outlets in that study, 88 of them franchised. Scale
does not create an Item 19. Crave records 26 franchised outlets and a public
franchise page that promotes several physical formats; none of that substitutes
for a representation the study row does not contain. bluTaco records 34
outlets, no ranked royalty and an agreement that runs until either party
terminates it. Missing performance figures sit beside missing percentage
inputs; neither gap is a zero.

Shah's adds an ownership distinction. The 2023 year-end count is 58 outlets,
14 company-owned and 44 licensed, with no franchises operating as of the
filing. A brand footprint that large can still have no franchised P&L to
disclose. Calling existing licensees is a different exercise from reading an
Item 19 that is not there.

## Presence is not a quality score

A young system can include an Item 19 because it has a handful of corporate
shops and chooses to show them. An older system can omit one. In this set,
Wienerschnitzel is the 1961, 323-unit benchmark and does make a
representation, while Halal Guys is a 1990, 93-unit system in the study and
does not. 375° began franchising in 2023 with five outlets and does make one.
Great Greek, founded 2017, makes one that includes cost lines. The pattern is
the franchisor's disclosure choice plus whatever operating history the sample
actually contains.

Consultants who screen on “has Item 19” will keep Döner Haus, GDK and the
chicken pair and drop Halal Guys and Shah's. That screen is a documentation
filter, not a food filter and not a profitability filter. It also keeps
samples that a validation call would immediately qualify: one mall year, two
corporate shops, twelve affiliates and three franchisees, six affiliates plus
a high-low franchise pair. The
[emerging versus established essay](/emerging-vs-established/) is the place
to keep age and unit count from being mistaken for that documentation filter.

## How to use these two tables

Use them to decide which packets require a sample-methodology memo and which
require a written acknowledgment that no representation was made. Then stop
using the badge. Read the current FDD. If a broker, portal or pitch deck
quotes a sales figure that is not in Item 19, treat that quote as marketing
until it is matched to the disclosure. If Item 19 exists, copy the population
into the comparison sheet before copying any result.

Head-to-heads that turn on this distinction include
[Döner Haus versus GDK](/compare/doner-haus-vs-german-doner-kebab/),
[Halal Guys versus Shah's](/compare/halal-guys-vs-shahs-halal/) — both
without a representation in the source rows — and
[375° versus Mad for Chicken](/compare/375-chicken-vs-mad-for-chicken/),
where both sides have samples that are not franchisee averages.

The generated tables print the note on file where one exists. Notes describe
populations: short mixed-ownership history, one mall year, six affiliates plus
a high-low franchise pair, twelve affiliates and three franchisees on revenue
only, an affiliate income statement covering 2020–2023 for two corporate
shops in the 2023 note. Where the May 2024 study only records that a
representation is made, the table says that and no more. Inventing a sample
for Wienerschnitzel, Dog Haus, Pepper Lunch or Capriotti's would be a new
fact this desk does not have.

A consultant's comparison sheet should have two columns after this page:
“sample in words” or “no representation.” Dollar results, when they exist,
belong in the current FDD the candidate actually received, tied to that
document's population, not copied between brands and not treated as a
system average. This page ranks presence. It does not rank earnings.

Halal Guys at 93 outlets without a representation and 375° at five outlets
with an affiliate sample are the pair that breaks “bigger brands disclose
more.” Great Greek at 31 with cost lines and Shah's at 58 with an explicit
non-representation are the pair inside one aisle. Use those contrasts, then
read the current document. The badge is the sort. The population is the
fact.

Dog Haus, Pepper Lunch, Capriotti's and Wienerschnitzel remain yes-without-a-
note in this dataset. That is a prompt to open the current FDD, not a prompt
to paste another brand's sample into those rows. Absence of a note is not
absence of a representation.

Crave at 26 franchised outlets without a representation and GDK at seven
franchised outlets with a one-store mall year are the other mismatch: more
franchisees does not mean more Item 19. Write the sample or the absence on
the comparison sheet, then stop using the badge as a score.

Döner Haus's 2026 Item 19 is present for a short mixed-ownership history.
That is a young-system sample, not a reason to skip the current document,
and not a reason to treat six outlets as a mature P&L.

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HTML: https://franchiselandscape.com/by-item-19/
