Pereda

FACTS AND PROCEDURAL BACKGROUND

I. Facts

A. Plaintiff In 2017, Ramon Pereda (plaintiff) was 49 years old. He was a former competitive bodybuilder who was familiar with sports that involved grappling: He was a wrestling celebrity at his high school; he kickboxed; he knew judo; and he had nearly achieved a brown belt in Taekwondo.

2 B. Plaintiff joins a local jiu-jitsu studio In the summer of 2017, plaintiff decided he wanted to learn Brazilian jiu-jitsu. A subset of jiu-jitsu generally, Brazilian jiu- jitsu is a sport in which competitors spar with one another on a mat and, through various grappling-type maneuvers, attempt to get one another into a chokehold; the match ends when the competitor who ends up in a chokehold submits, typically by “tapping out.” As this description implies, “choking” is a “major” and “integral” part of Brazilian jiu-jitsu. Plaintiff’s neighbor told him about The Jiu Jitsu League (the League), which is a Brazilian jiu-jitsu studio where the neighbor was a part-time instructor. Plaintiff also visited a website for Atos Jiu Jitsu, LLC, which does business as Atos Jiu- Jitsu Association (Atos). Atos’s website listed its various “affiliates,” of…