Checkers (or Is It Draughts?) Infighting Leads to Court

Some excerpts from the long opinion yesterday by Judge Beth Bloom (S.D. Fla.) in Rudnitsky v. Int’l Checkers Ass’n of N. Am. Inc.:

Between 2002 and 2024, [Alexander] Rudnitsky became United States National Champion five times and World Veterans Champion twice in the game of checkers. During that time, Rudnitsky was one of the most active members of [defendant] ICAONA. Indeed, between 2022 and 2025, Rudnitsky served as Vice President of ICAONA. Between 2002 and 2024, ICAONA functioned de facto as the sole organization of its type in the United States.

In 2005, ICAONA became a member of the World Draughts Federation (“FMJD”) and obtained the right to conduct U.S. qualifying championships for FMJD international tournaments. As a result, all players from the United States had to go through ICAONA to access FMJD national and international competitions. That also meant that ICAONA established conditions for admission to competitions and rules governing participant conduct, including mandatory membership and financial contribution requirements. One such rule prohibited any mention or promotion of alternative organizations during tournaments.

In 2024, Rudnitsky and his colleagues created an alternative nonprofit organization—the National Draughts Federation of the USA (“NDF”). The primary goal of NDF was to develop international draughts in Florida and the United States through (1) creating and developing an annual international tournament, the MIAMI OPEN, (2) the creation of new social projects in draughts, (3) the development of youth and junior programs, and (4) the popularization of the game at the local community level in Florida. After its creation, NDF announced and began preparing for the 2025 MIAMI OPEN, which was to be held in Florida. The tournament was included in the FMJD calendar.

On November 13, 2024, Lyublyana Turiy (“Turiy”), ICAONA’s Executive Director, sent a letter to FMJD demanding that the MIAMI OPEN be removed from the FMJD 2025 calendar. In that letter—which was public—Turiy stated the that the signature of ICAONA President R. Azimullah was “likely forged,” the event was falsified, and they likely lied about player accommodation and the availability of prize funds. The 2025 MIAMI OPEN was thereafter excluded from the FMJD calendar for over a month. ICAONA understood that by addressing the highest level of the FMJD with the public letter, it was causing serious damage to the reputations of NDF and Rudnitsky.

In January 2025, the 2025 MIAMI OPEN was re-included in the FMJD 2025 calendar. Also in January 2025, Rudnitsky became aware of communications between Turiy and other individuals, in which the possibility of his disqualification was directly discussed—the goal was to prevent his participation in the 2025 World Championship, stop the development of the “illegitimate” NDF, and organize individuals to disseminate information discrediting NDF. The communications referred to Rudnitsky as corrupt. Around that time, ICAONA discussed possible measures of influence and sanctions against players and ICAONA members for recognizing, supporting, or participating in NDF tournaments. Turiy and others contacted players from the United States and other countries, proposing that they not attend the 2025 MIAMI OPEN tournament and that they continue supporting ICAONA against NDF….

There is more, oh so much more, but the short version is that the court allowed plaintiff’s defamation and interference with business relations claims to go forward based on the “statements accusing Plaintiff of fraud, forgery of signatures, and submission of false information.” And the court also allowed plaintiff’s claim under Florida Deceptive and Unfair Trade Practices Act (FDUTPA), a statute that forbids “[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] non-profit’s activities fall squarely within FDUTPA’s scope. Moreover, the undisputed facts, drawn from the admitted items in the Request for Admissions, show unfair trade practices. For instance, ICAONA imposed upon Rudnitsky—as a precondition to his participation in competitions—the requirement that he abandon his lawsuit and withdraw all complaints to the FMJD Executive Committee and FMJD Ethics Committee. That plainly falls within FDUTPA’s prohibition on unfair methods of competition, unconscionable acts, and on acts that offend “established public policy” and are “immoral, unethical, oppressive, unscrupulous or substantially injurious to consumers.”

Furthermore, as established above, ICAONA disseminated false accusations to third parties in an effort to exclude Plaintiff and preclude the development of his new organization. “Intentionally making false statements to a competitor’s customers”—in this case, to the FMJD—”is clearly barred by the FDUTPA because it is an unethical practice that offends public policy.”

Finally, the facts demonstrate that ICAONA effectively forced U.S. players to join ICAONA as the only way to participate in the U.S. National Championship and obtain international qualification, which directly contravenes the FMJD’s statement that “every player registered in the FMJD database must have the opportunity to participate in the U.S. National Championship.” That constitutes a plainly unfair method of restricting competition from alternative organizations….

And the court allowed a federal antitrust claim to go forward as well:

Here, Rudnitsky has shown a violation of the Sherman Act, vindicated by way of the Clayton Act. As an initial matter, Rudnitsky has shown an antitrust injury—specifically, a conspiracy to restrict national and international competition in sports 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 of the Sherman Act. For instance, in the regulations for the 2025 U.S. OPEN, ICAONA stated that a U.S. citizen or lawful resident who otherwise meets appropriate sporting criteria but is not a member of ICAONA would not be admitted to the U.S. National Championship. That means that independent players, players of other legally existing organizations, and players 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.”

Put simply, ICAONA excluded non-members from the U.S. National Championship and from obtaining international qualification. Furthermore, ICAONA admitted 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.”

Moreover, ICAONA admitted that its proposal to disqualify Rudnitsky and its decision to bar Rudnitsky from the 2025 World Championship were rooted in a “desire for Rudnitsky to stop developing his ‘illegitimate’ organization.” Those actions—forced membership, suppression of alternative organizations, and limitation of independent tournaments—violate Section 1 and Section 2 of the Sherman Act and constitute an antitrust injury.

George Lambert represents plaintiff.