# What successive filings reveal

One FDD is a snapshot. Two are a plot. The current filing is written to describe
the offer today, not to annotate what it used to say and no longer does. The
only way to see an Item 19 that arrived, narrowed to one mall unit, and then
vanished is to put last year's packet next to this year's.

Four brands here have more than one filing. A fifth is a baseline with nothing
yet to compare. None of that is a morality play. It is what a reader holding a
single PDF is not being shown.

State franchise registries are searchable and free. Wisconsin's Department of
Financial Institutions is the one used for the 2025 German Doner Kebab document
below. A conclusion about what changed is only as good as the newest filing
actually in hand.

## Before comparing, establish that it is the same offering

The first move is a check that the two documents describe the same thing, and
[Atomic Wings](/franchises/atomic-wings/) is the case that makes the point.

Two Atomic Wings documents have been read here, issued 30 April 2024 and 29
April 2025. The 2024 one is an area representative offering, and its Item 20
counts an outlet type called “Area Representatives”: one in 2021, one rising to
five across 2022, five in 2023, with company-owned outlets at zero, one, two and
three. The 2025 document counts “Franchised” outlets: nine rising to fifteen
across 2022, fifteen to eighteen across 2023, eighteen to twenty across 2024,
with company-owned at zero throughout.

Put those two tables side by side and the totals appear to leap. They do not. An
area representative is a party with development rights over a territory, and a
franchised outlet is a restaurant. Subtracting one from the other produces a
growth rate for a quantity that does not exist. It is why no series is built
across those two documents here, and the same caution applies to anyone
assembling a unit count from whatever filings they happen to have.

The other half of the Atomic Wings pair is a non-event worth naming, because it
looks like an event. Neither filing makes a financial performance
representation. The 2024 one states that the franchisor “does not make any
financial performance representations”; the 2025 one states that “We do not make
any representations about a franchisee's future financial performance or the
past financial performance of company-owned or franchised outlets.” Nothing was
withdrawn between them. A reader who noticed only that the current document has
no Item 19 might assume one had been removed; the pair shows there was never one
to remove.

What did change between those two documents is in Item 21, and it changed for
the better: the 2024 filing carried a going-concern qualification and the
matching cover-page special risk, and the 2025 filing carries neither and
reports two profitable years. [What the filings say about the
franchisor](/what-the-filings-say-about-the-franchisor/) sets out both sets of
figures. It is the clearest case here of a serious finding that a later
document lifts, and it is only visible as a change if both documents are read.

So the sequence is: identify the offering each document describes, identify what
its Item 20 rows are counting, and only then compare. Two filings from one brand
can still describe two different offerings.

## An Item 19 can arrive, narrow to one restaurant, and then disappear

[German Doner Kebab](/franchises/german-doner-kebab/) has five filings on file:
7 February 2018, 19 August 2021, 20 July 2023, 3 September 2024, and the
document registered with the Wisconsin Department of Financial Institutions on
24 September 2025 as filing number 639752. Read in order they answer a question
no single one of them can, and the answer reverses twice.

The 2018 and 2021 filings make no financial performance representation at all.
The 20 July 2023 filing introduces one. The 3 September 2024 filing keeps it.
**The 2025 filing removes it entirely.**

| Filing | Item 19 | Outlets covered | Period | Disclosed |
| --- | --- | --- | --- | --- |
| 7 February 2018 | None | — | — | — |
| 19 August 2021 | None | — | — | — |
| 20 July 2023 | Yes | 1 franchised | FY2022 | $1,491,322 gross revenues, 58,674 transactions, $25.42 average ticket |
| 3 September 2024 | Yes | 1 franchised | FY2023 | $1,383,053 gross revenues, 64,721 transactions, $21.37 average ticket |
| 24 September 2025 | None | — | — | — |

The 2025 Item 19 is worth quoting because of what it leaves behind. It consists
of the standard explanatory paragraph the Franchise Rule prescribes, followed
directly by the sentence “Other than the preceding financial performance
representation, we do not make any financial performance representations.” There
is no preceding representation. No table, no measurement period and no figures
appear anywhere in the Item. The sentence is vestigial wording carried over from
the previous year's document, which did contain one, and it is the kind of
residue that only a reader holding both documents can identify as residue.

## One mall unit, two measurement periods, then nothing

Both of the representations that did exist cover the same single outlet: the
franchised restaurant at F1 American Dream Way, East Rutherford, New Jersey,
described in the 2024 filing as having opened on 21 August 2021 and as “the only
open GDK Outlet for the entire 12 months ended December 31, 2023.” Each filing
states that because only one outlet is disclosed it has given no high, low,
median or average figure — there is nothing to take a median of.

Set the two full years beside each other and the arithmetic is the franchisor's
own. Gross revenues fell by roughly $108,000, transactions rose by roughly
6,000, and the average ticket fell by about $4. A single revenue line would have
shown a decline and a single transaction count would have shown growth; it takes
both tables to see that a mall restaurant served more customers for less money
per visit. The 2024 document also restates the fourth quarter of 2021 for the
same unit at $409,279 in gross revenues on 17,612 transactions, a $23.24 average
ticket.

Then the third data point is withdrawn. A buyer holding only the 2025
document sees a franchisor that makes no performance representation and has an
Item 19 sentence referring to one; a buyer holding all three sees two years
of one restaurant and a decline between them. No filing explains why the
representation was dropped. Reports under the 2025 document are directed to
Daniel Bunce in Dallas, Texas, at the franchisor's current address of 11015
Beauty Lane — a different city from the Concord, Massachusetts address that the
2023 filing gave for the same purpose, and from the Auburn Hills, Michigan
principal business address in the 2024 one.

## A plan in one filing, an outcome in a later one

The 2021 filing contains something more unusual than a performance
representation: a stated plan, with numbers. The going-concern note in that
document says the company “has two franchised locations in operation as of
December 31, 2020,” that it “plans to have an additional five franchised stores
opened by December 31, 2021,” that it is “actively working with existing
franchisees on the development of 66 additional stores,” and that after year end
it signed a development agreement for 15 stores in the Houston metropolitan
area.

Item 20 of the 2025 filing puts US franchised outlets at seven at the end of
2024. Sixty-six in development and a fifteen-store metropolitan agreement in
2021, against seven outlets four years later. No adjective is required: a
development plan is a plan, plans are not disclosures of fact, and a filing that
states one is being more forthcoming than a filing that does not. But the pair
is the reason older documents belong in the file. A projection made in a
superseded filing is the only place where what a franchisor expected can be
compared with what a later filing records.

## Two tables in one document, disagreeing

The 2021 filing also contradicts itself, and the contradiction is instructive
about which item to trust. Item 20's Table 1 reports zero franchised outlets at
both the start and the end of 2018, 2019 and 2020. The note to the audited
financial statements bound into the same document says two franchised locations
were in operation as of 31 December 2020. One of those is wrong, or the two use
different definitions of an outlet, and the document does not say which.

That is the single best argument in this evidence base for reading Item 20 and
Item 21 against each other rather than trusting either alone. The unit table and
the financial statements are prepared by different people for different
purposes, and where they disagree the disagreement is the finding.

The 2025 filing has an arithmetic defect of its own in the same item. Table 1's
“Franchised” row shows 2024 starting at seven and ending at seven, a net change
of zero, and company-owned outlets at zero throughout — while the same table's
“Total Outlets” row, and Table 3, show seven rising to nine, a net change of
plus two. A total that moves while every component holds still cannot be right,
and a reader who takes the headline total from one row and the movement from
another will assemble a system history that the document does not support.
Elsewhere the 2025 tables report US franchised outlets of one for 2022, seven
for 2023 and nine for 2024, zero terminations, non-renewals, reacquisitions and
ceased operations throughout, and one signed but unopened agreement in New York
as of 31 December 2024.

## What Item 20 cannot answer

One caution belongs with all of the above, because a run of zeros in a closure
column invites a conclusion it cannot carry. Item 20 covers outlets of the **US**
franchisor through the **last completed fiscal year**. As of the 2025 filing it
therefore says nothing about calendar 2025 or 2026, and it says nothing at all
about the United Kingdom, Ireland, Canada, the Gulf or Sweden, where the parent
and its affiliates operate the large majority of the estate. A brand can close
units steadily and still present a clean US Item 20.

Closures are answered by other evidence, cited individually. The Courier
reported that the Stirling GDK on Murray Place, opened in 2022, shut permanently
after a “temporary” closure, was delisted from the company's website and was
being marketed to let by TSA Property Consultants, with GDK's chief operating
officer Sofia Dimen quoted apologising for the closure and saying the company
was working with the landlord. That is a named, dated, attributable closure, and
it sits against third-party directories describing the system as “over 140” and
“147” locations in the same period. A second reported closure, at Brighton, was
checked and **not** substantiated — the North Street unit was still listed with
current hours in mid-2025 and carried a customer review dated July 2026 — and it
is therefore not treated as a closure here.

## A performance table can be a table of survivors

[Mad for Chicken](/franchises/mad-for-chicken/) has three filings on file, issued
13 September 2023, 3 May 2024 and 12 March 2025, and each makes a revenue-only
representation covering affiliate-owned and franchised outlets. The affiliate
estate across those documents runs 4 outlets for fiscal 2021, 6 for 2022, 12 for
2023 and 10 for 2024, with franchised outlets at none, two, three and two.

The 2025 filing explains the shape inside Item 19 itself. “Four (4) affiliate
outlets have been excluded from the table below because they closed and did not
operate the full year,” it says, and “two (2) Franchise outlets have been
excluded because they closed and did not operate the full year.” The excluded
outlets “were open only two (2) to eleven (11) months during our most recent
fiscal year.”

Six restaurants closed during that year and the revenue table shows the ones
that did not. This is very probably the right treatment. A full-year table that
included a restaurant open for two months would understate that unit and corrupt
every comparison drawn from the column, and the franchisor disclosed the
exclusion in the document rather than performing it quietly, with counts on both
sides of the ownership line. It is also the single easiest thing on this table
for a reader to skip, because the sentence sits above the numbers and the
numbers are what the eye goes to.

The same-unit figures across the last two filings are what a reader gets in
exchange for keeping both. From the 3 May 2024 filing, fiscal 2022 to fiscal
2023: Flushing $3,333,431 to $2,885,923, Bayside $3,591,148 to $3,240,511,
Brooklyn $1,392,756 to $1,097,591, Astoria $1,035,433 to $1,062,335, Chelsea
$755,182 to $1,037,237, Sunnyside $753,334 to $2,150,959. From the 12 March 2025
filing, fiscal 2023 to fiscal 2024: Bayside $3,240,511 to $3,272,236, Flushing
$2,885,923 to $2,845,751, Williamsburg $1,097,591 to $963,955. Two documents
give three or four points per restaurant where one gives two, and the two
largest units turn out to be roughly level after a decline rather than headed in
either direction.

## The window rolls, and a year leaves it

[375° Chicken 'n Fries](/franchises/375-chicken/) shows the plainest version of
the problem, and the one that involves no judgement call at all.

Its Item 19 is a single aggregate income statement for the corporate outlets in
both documents — not per-unit figures, so no unit economics can be derived from
it in either year. The FDD issued 24 February 2023 covers calendar 2019 through
2022. The FDD issued 30 April 2024 covers 2020 through 2023. Four years wide in
both cases, rolled forward by one.

The year that rolled out is the only loss year in the series: fiscal 2019, sales
of $701,815, a net loss of $42,106, a margin of negative six percent. It is in
the older document and absent from the newer one. A buyer holding the
current filing alone sees the series open in profit at 5.8% on $809,425 of sales
in 2020 and climb to 32.8% on $2,355,698 in 2021. A buyer holding both sees
a business that lost money first. Nothing improper occurred: a four-year window
is normal, and moving it forward each year is what a current document does. The
loss year did not disappear. It scrolled off the top of a table.

The newer filing carries its own small lesson in the same column. Sales fell
slightly from $3,879,935 in 2022 to $3,782,437 in 2023 while net income rose
from $682,480 to $804,218, a margin moving from 17.5% to 21.3%. Top line and
bottom line can go opposite ways in an aggregate statement, and the filing
does not say why.

One more identity check belongs here. The income statement is headed 375
Ventures LLC in the 2023 filing and 375 Enterprises LLC in the 2024 filing, with
identical figures in the overlapping years. Matching numbers are what establish
that this is one lineage renamed rather than two entities being confused for
each other — which is precisely the check to perform before stitching two series
together, in any brand. The audited franchisor in that same document is a third
company again, 375 Global Franchise LLC, whose own results are on the
[Item 21 ranking](/by-financial-condition/) and are not the figures in its Item
19.

## A first filing is a baseline for the next one

[Doner Shack](/franchises/doner-shack/) has one document on file, the FDD
issued 29 April 2025, and it is included in this essay because it shows what a
baseline looks like before there is anything to compare it with.

That document states that the franchisor “began offering franchises as of
September 5, 2024,” and its Item 20 records zero franchised and zero
company-owned outlets at both the start and the end of each of 2022, 2023 and
2024, footnoted with the statement that there are no US operations while
affiliates operate three restaurants in the United Kingdom with four more UK
franchises in development. There is no Item 19. Item 13 discloses that the
principal mark has no federal registration and that an application is pending,
filed 3 May 2024 under serial 79/411,340, together with the franchisor's own
risk language: “If our right to use the trademark is challenged, you may have to
change to an alternative trademark, which may increase your expenses.”

That last field has already moved, and it moved on a record outside the FDD
rather than inside one. The USPTO's public status view for that serial shows
registration 8,290,085 issued on the Principal Register on 9 June 2026, with the
words “DONER SHACK” disclaimed. The filing's statement was accurate on 29 April
2025 and the registration is accurate now; both carry their dates, and the
[brand profile](/franchises/doner-shack/) sets out the prosecution history and
what the disclaimer does to the scope of the right. The general lesson is the
one this page exists for: some fields in a disclosure document are snapshots of
an external register that keeps moving between filings, and the next document
will restate the field rather than narrate the change.

Every other item in that filing is a baseline in the same way. Whether three
years of zeros becomes four, whether a first US restaurant appears in a year-end
column, whether an Item 19 appears once there is something to report — those are
questions a second filing answers by existing.

Two filings only compare if they describe the same offering and count the same
kind of outlet. An Item 19 that was added, kept, narrowed or withdrawn is a
disclosure history, not a quality score. Exclusion language above a performance
table is part of the table. A reporting period that rolled left something
behind. Item 20 and the notes to the financial statements in the same document
can disagree, and when they do the disagreement is the finding. A total that
moves while every component holds still is a defect, not a growth rate.

## Two disclosure moments, not a contradiction

None of the cases above is a franchisor behaving badly. An Item 19 that appears
and then disappears is a disclosure choice the Franchise Rule leaves open in
both directions. An exclusion note is arguably the correct accounting treatment
for a full-year table, disclosed in the document rather than hidden. A rolling
four-year window is how the form works. A renamed reporting entity with matching
figures is housekeeping. An area representative offering counting area
representatives is counting the right thing. A first filing with three years of
zeros is a company saying accurately that nothing has happened yet. Even the two
defects — a note that contradicts an outlet table, a total that moves while its
components do not — are more likely drafting than design.

What they have in common is narrower and more practical: in each case the
current document, read alone, supports a conclusion the pair does not. That is
why document dates sit on every figure, why the
[methodology](/methodology/) refuses to blend a 2023 filing with a 2026 one, and
why [by Item 19](/by-item-19/) records presence and population rather than
converting either into a projection. [What the filings leave
blank](/what-the-dataset-does-not-know/) inventories the blanks in a single
disclosure year. This page is the other half of that: what a single disclosure
year cannot show even when every one of its cells is full.

The request that follows is short enough to make on a first call. Ask for the
current FDD, and ask for the one before it.

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HTML: https://franchiselandscape.com/successive-filings/