Selected excerpts from the extensive ruling issued yesterday by Judge Beth Bloom (S.D. Fla.) in Rudnitsky v. Int’l Checkers Ass’n of N. Am. Inc.:
From 2002 through 2024, Rudnitsky accumulated five United States National titles and two World Veterans Championships in the game of checkers. During this period, he stood out as one of ICAONA’s most active participants. In fact, between 2022 and 2025, Rudnitsky carried out the duties of Vice President of ICAONA. Over those years, ICAONA functioned in practice as the only organization of its kind within the United States.
In 2005, ICAONA joined the World Draughts Federation (“FMJD”) and gained the authority to oversee U.S. qualifying events for FMJD’s international competitions. As a result, every American player had to pass through ICAONA to reach FMJD national and international tournaments. That arrangement allowed ICAONA to set admission criteria for tournaments, as well as rules governing participant behavior, including mandatory membership and required financial contributions. One of the regulations prohibited any discussion or promotion of alternative organizations during tournaments.
In 2024, Rudnitsky and his colleagues launched an alternative nonprofit—the National Draughts Federation of the USA (“NDF”). The principal objectives of NDF were to promote international draughts in Florida and across the United States by (1) creating and growing an annual international event, the MIAMI OPEN, (2) initiating new social projects related to draughts, (3) fostering youth and junior programs, and (4) raising the game’s profile at the local community level in Florida. After its formation, NDF announced plans for the 2025 MIAMI OPEN, which was intended to take place in Florida. The tournament also appeared on the FMJD calendar.
On November 13, 2024, Lyublyana Turiy (“Turiy”), ICAONA’s Executive Director, sent a publicly released letter to FMJD demanding the removal of the MIAMI OPEN from the FMJD’s 2025 calendar. In that letter, Turiy asserted that the signature attributed to ICAONA President R. Azimullah was “likely forged,” that the event itself was misrepresented, and that statements about player accommodations and prize funds were probably untrue. Following this, the 2025 MIAMI OPEN was kept off the FMJD calendar for more than a month. ICAONA understood that by addressing FMJD at the highest level with a public letter, it was causing substantial harm to the reputations of NDF and Rudnitsky.
In January 2025, the MIAMI OPEN again appeared on the FMJD 2025 calendar. Also in January 2025, Rudnitsky learned of communications between Turiy and other individuals in which his disqualification was explicitly discussed—the aim being to prevent his participation in the 2025 World Championship, to halt the growth of the “illegitimate” NDF, and to organize efforts to spread information discrediting NDF. Those communications described Rudnitsky as corrupt. Around that same period, ICAONA discussed potential measures to influence or sanction players and ICAONA members who recognized, supported, or took part in NDF tournaments. Turiy and others contacted players in the United States and abroad, urging them not to participate in the 2025 MIAMI OPEN and to continue backing ICAONA against NDF….
There is much more to the story, yet the gist is that the court allowed the plaintiff’s defamation and interference-with-business-relations claims to proceed, based on allegations that referenced “fraud, forged signatures, and submission of false information.” The court also permitted a FDUTPA claim to go forward, a provision prohibiting “[u]nfair methods of competition, unconscionable acts or practices, and unfair or deceptive acts or practices in the conduct of any trade or commerce.”
[A] nonprofit’s activities fall squarely within the reach of FDUTPA. Moreover, the undisputed facts drawn from the admitted items in the Requests for Admissions show unfair trade practices. For instance, ICAONA conditioned Rudnitsky’s eligibility to compete on his dropping of his lawsuit and withdrawal of all complaints to FMJD’s Executive Committee and FMJD’s Ethics Committee. This clearly falls within FDUTPA’s prohibition on unfair methods of competition, unconscionable acts, and acts that offend “established public policy” and are “immoral, unethical, oppressive, unscrupulous or substantially injurious to consumers.”
Additionally, as noted above, ICAONA circulated false accusations to third parties to exclude the plaintiff and hinder the development of his new organization. “Intentionally making false statements to a competitor’s customers”—here, to the FMJD—“is clearly barred by FDUTPA because it constitutes an unethical practice that offends public policy.”
Finally, the record shows that ICAONA effectively compelled U.S. players to join ICAONA as the only route to participate in the U.S. National Championship and to obtain international qualification, which directly contradicts FMJD’s statement that “every player registered in the FMJD database must have the opportunity to participate in the U.S. National Championship.” This represents a plainly unfair tactic that restricts competition from alternative organizations….
And the court also allowed a federal antitrust claim to proceed:
Here, Rudnitsky has demonstrated a Sherman Act violation, actionable through the Clayton Act. First, he has shown an antitrust injury—specifically, a conspiracy to constrain both national and international competition in the sport in violation of Section 1 of the Sherman Act, and an attempt to monopolize the market for official checkers competitions within the United States in violation of Section 2. For example, the 2025 U.S. OPEN regulations stated that a U.S. citizen or lawful resident who otherwise meets relevant sporting criteria but is not a member of ICAONA would be barred from the U.S. National Championship. This means that independent players, participants from other legally recognized organizations, and those who do not join ICAONA are “automatically deprived of national status and are not admitted to compete in the U.S. National Championship for the title of U.S. Champion or the right to represent the country internationally.”
In simple terms, ICAONA excluded non-members from the U.S. National Championship and from obtaining international qualification. Moreover, ICAONA conceded that those rules were “adopted for the purpose of establishing exclusive control over national ranking and qualification pathways for participation by U.S. citizens and lawful U.S. residents in international draughts competitions in the United States and abroad, and over the right to represent the United States internationally.”
Furthermore, ICAONA conceded that its plan to disqualify Rudnitsky and its decision to ban him from the 2025 World Championship were driven by a “desire for Rudnitsky to stop developing his ‘illegitimate’ organization.” Those actions—mandated membership, suppression of alternative organizations, and restriction of independent tournaments—violate Sections 1 and 2 of the Sherman Act and constitute an antitrust injury.
George Lambert represents the plaintiff.
