On the June 5th, 2018, the lawyers for Douglas Schoninger the proprietor of the defunct PRO Rugby USA rugby competition filed suit against the United States of America Rugby Football Union, RIM, Former(FMR) Chair Will Chang, FMR Director Chad Keck, FMR CEO Nigel Melville, and FMR CEO Dan Payne. The attached document in response to our Public Record Request on June 6th, 2018, is the Full Complaint filed in the District Court located in Boulder County, Colorado: NA American Rugby LLC/Doug Schoninger V. USARFU Et Al Complaint ~Aaron Castro