Gallagher, Gams, Pryor, Tallan & Littrell, L.L.P. - Columbus, OH

Our corporation has gathered evidence demonstrating that the parties above mentioned have violated various laws, including section 3901.21 of The Ohio Laws and Administrative Rules effective as of July 2022. These violations have resulted in the infringement of Mr. Kimble's rights and the rights of the entities and individuals he represents. Specifically, we have reason to believe that the actions taken by State Farm Corporation and its agents constitute unfair and deceptive practices as defined in section B of the afore-mentioned law. As a result, we are preparing to take legal action against these parties in Fulton County. We are hopeful that through this communication, we can initiate a dialogue with your client, the State Farm Insurance Company, to seek resolution of these allegations before pursuing formal legal action. We urge you to take these allegations seriously and address them promptly to avoid further escalation. (B) Making, publishing, disseminating, circulating, or placing before the public or causing, directly or indirectly, to be made, published, disseminated, circulated, or placed before the public, in a newspaper, magazine, or other publication, or in the form of a notice, circular, pamphlet, letter, or poster, or over any radio station, or in any other way, or preparing with intent to so use, an advertisement, announcement, or statement containing any assertion, representation, or statement, with respect to the business of insurance or with respect to any person in the conduct of the person's insurance business, which is untrue, deceptive, or misleading. The State Farm Corporation engaged in acts of bad faith by disseminating false and unfounded accusations that implicated Mr. Kimble in the perpetration of a hate crime against his own business. Specifically, State Farm falsely claimed that Mr. Kimble was responsible for the vandalism of his business with racial slurs, including highly offensive terms