Alt Platform Inc v. Beckett Collectibles LLC

CourtDistrict Court, N.D. Texas
DecidedOctober 1, 2024
Docket3:22-cv-02867
StatusUnknown

This text of Alt Platform Inc v. Beckett Collectibles LLC (Alt Platform Inc v. Beckett Collectibles LLC) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alt Platform Inc v. Beckett Collectibles LLC, (N.D. Tex. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

ALT PLATFORM, INC., et al., § § Plaintiffs, § § v. § Civil Action No. 3:22-CV-02867-N § BECKETT COLLECTIBLES, LLC, § § Defendant. §

MEMORANDUM OPINION AND ORDER

This Order addresses Defendant Beckett Collectibles, LLC’s (“Beckett”) motion for summary judgment [54]. For the reasons below, the Court denies the motion. I. ORIGINS OF THE DISPUTE This case arises out of an alleged misrepresentation about whether a 2009 Stephen Curry trading card (“Curry Card”) was physically altered at the time Beckett assigned it a grade of “9.5 Gem Mint.” Def.’s Br. 1 [55]. Beckett is in the business of grading and authenticating sports memorabilia. Id. In 2016, Beckett examined the Curry Card at the request of a third-party customer, assigned it a grade of 9.5 Gem Mint, and encapsulated the card in a tamper-proof “slab.” Id. at 2. Plaintiffs Alt Sports Card Fund GP, LLC and Alt Platform, Inc. (collectively, “Alt”) are involved in the business of buying and selling sports trading cards. Id. In 2020, a predecessor Alt entity, Alt Fund I, LP, purchased the Curry Card from a different third party for $168,000. Id.; Pls.’ Resp. 8 [63]1. In doing so, Alt was aware that the card had previously been graded at a 9.5 Gem Mint by Beckett. Pls.’ Resp. 8. Alt then decided to remove the Curry Card from its slab, hoping that it could submit

the card to PSA, another grading company, and receive a higher grade. Id. at 9. Alt submitted the card to PSA, but PSA returned the card to Alt and stated that the card appeared to be “trimmed.” Id. at 9–10. “Trimming” involves cutting the edge of a trading card to make it appear to be in better condition than it is. Id. at 1. Alt claims that the card was trimmed before Beckett assigned it a 9.5 Gem Mint grade, and that Beckett negligently

misrepresented the status of the card by assigning it such a grade. Am. Compl. ¶¶ 68–76 [14]. Beckett now moves for summary judgment on Alt’s sole claim of negligent misrepresentation. Beckett argues that the statute of limitations has passed, the discovery rule does not apply, Alt does not have standing, and that a sports card grade is an opinion and therefore not actionable as negligent misrepresentation.

II. LEGAL STANDARD FOR SUMMARY JUDGMENT Courts “shall grant summary judgment if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” FED. R. CIV. P. 56(a); Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247 (1986). In making this determination, courts must view all evidence and draw all reasonable

1 Beckett argues in its reply that the Court should only consider the first 25 pages of Alt’s response, asserting that Alt violated Local Rule 7.2(c) by submitting a brief over 25 pages long without seeking leave to do so. Def.’s Reply 1 n.2 [77]. However, Beckett fails to note that Local Rule 56.5(b) increases the page limit to 50 pages for summary judgment briefs. inferences in the light most favorable to the party opposing the motion. United States v. Diebold, Inc., 369 U.S. 654, 655 (1962). The moving party bears the initial burden of informing the court of the basis for its belief that there is no genuine issue for trial. Celotex

Corp. v. Catrett, 477 U.S. 317, 323 (1986). When a party bears the burden of proof on an issue, “he must establish beyond peradventure all of the essential elements of the claim or defense to warrant judgment in his favor.” Fontenot v. Upjohn Co., 780 F.2d 1190, 1194 (5th Cir. 1986). When the nonmovant bears the burden of proof, the movant may demonstrate entitlement to summary

judgment either by (1) submitting evidence that negates the existence of an essential element of the nonmovant’s claim or affirmative defense, or (2) arguing that there is no evidence to support an essential element of the nonmovant’s claim or affirmative defense. Celotex, 477 U.S. at 322–25. Once the movant has made this showing, the burden shifts to the nonmovant to

establish that there is a genuine issue of material fact so that a reasonable jury might return a verdict in its favor. Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 586–87 (1986). Moreover, “[c]onclusory allegations, speculation, and unsubstantiated assertions” will not suffice to satisfy the nonmovant’s burden. Douglass v. United Servs. Auto. Ass’n, 79 F.3d 1415, 1429 (5th Cir. 1996) (en banc), superseded by statute on other

grounds, 28 U.S.C. § 636(b)(1). Factual controversies are resolved in favor of the nonmoving party “only when an actual controversy exists, that is, when both parties have submitted evidence of contradictory facts.” Olabisiomotosho v. City of Houston, 185 F.3d 521, 525 (5th Cir. 1999) (quoting McCallum Highlands, Ltd. v. Washington Capital Dus, Inc., 66 F.3d 89, 92 (5th Cir. 1995)). III. THE COURT DENIES SUMMARY JUDGMENT ON ALT’S NEGLIGENT MISREPRESENTATION CLAIM

To prevail on a motion for summary judgment, Beckett, as the movant, must show that no genuine issue of material fact exists, and that the undisputed facts entitle it to judgment as a matter of law. The Court finds that the discovery rule applies to toll the statute of limitations on Alt’s negligent misrepresentation claim. Additionally, the Court finds that both plaintiffs have standing to pursue their claim. Finally, the Court finds that Beckett’s grading of the card was an actionable statement of fact that the card was not altered. Accordingly, Beckett is not entitled to summary judgment on Alt’s negligent

misrepresentation claim. A. The Discovery Rule Applies to Toll the Statute of Limitations

Beckett argues that the statute of limitations has passed on Alt’s claim and that the discovery rule does not apply to toll the limitations period. Def.’s Br. 6–7. To prevail at summary judgment on this issue, Beckett bears the burden of conclusively negating the discovery rule. McGowan v. S. Methodist Univ., 2024 WL 455340, at *3 (N.D. Tex. 2024) (citing Draughon v. Johnson, 631 S.W.3d 81, 90 (Tex. 2021)). Because the Court finds that the discovery rule applies, the Court denies summary judgment on this issue. The limitations period for a negligent misrepresentation claim in Texas is two years. TEX. CIV. PRAC. & REM. CODE § 16.003(a); Tex. Am. Corp. v. Woodbridge Joint Venture,

809 S.W.2d 299, 302–03 (Tex. App. – Ft. Worth 1991, writ denied) (applying the two-year statute of limitations to a negligent misrepresentation claim because it sounded in negligence rather than fraud). However, when “the discovery rule applies, the statute of limitations does not begin to run ‘until the plaintiff knew or in the exercise of reasonable

diligence should have known of the wrongful act and resulting injury.’” Marcus & Millichap Real Est. Inv. Servs. of Nev., Inc.

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Bluebook (online)
Alt Platform Inc v. Beckett Collectibles LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alt-platform-inc-v-beckett-collectibles-llc-txnd-2024.