Legal Notice

Without Prejudice
November 18, 2019

NOTICE OF NON-COMPLIANCE BY NOVO HEALTHNET LIMITED

By Asset Purchase Agreement and License Agreement dated July 22, 2019, Action Plus Physiotherapy (“Action Plus”) sold its Rockland clinic (the “Clinic”) to Novo Healthnet Limited (“Novo”).

As a term of the License, Action Plus granted a license to Novo to use the name “Action Plus Physiotherapy” in association with the Clinic.

Unfortunately, Novo is in breach of the terms of the Asset Purchase Agreement and the License.

Accordingly, Action Plus has demanded and continues to demand that Novo comply fully with all terms of the Asset Purchase Agreement and reimburse Action Plus for the damages and expenses it has suffered as a result of Novo’s non-compliance.

Further, until Novo is in full compliance with the Asset Purchase Agreement, Action Plus has demanded that Novo cease all use of the name “Action Plus” in any manner, place or media.