Banc of Am. Merch. Servs., LLC v. Arby's Rest. Grp., Inc.

2021 NCBC 42
CourtNorth Carolina Business Court
DecidedJune 30, 2021
Docket20-CVS-426
StatusPublished

This text of 2021 NCBC 42 (Banc of Am. Merch. Servs., LLC v. Arby's Rest. Grp., Inc.) is published on Counsel Stack Legal Research, covering North Carolina Business Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Banc of Am. Merch. Servs., LLC v. Arby's Rest. Grp., Inc., 2021 NCBC 42 (N.C. Super. Ct. 2021).

Opinion

Banc of Am. Merch. Servs., LLC v. Arby’s Rest. Grp., Inc., 2021 NCBC 42.

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION MECKLENBURG COUNTY 20 CVS 426

BANC OF AMERICA MERCHANT SERVICES, LLC,

Plaintiff and Counterclaim Defendant,

v. ORDER AND OPINION ARBY’S RESTAURANT GROUP, ON THIRD-PARTY DEFENDANTS INC., VISA, INC.’S AND MASTERCARD INTERNATIONAL INC.’S Defendant, Counterclaim MOTIONS TO DISMISS Plaintiff, and Third-Party Plaintiff,

v.

VISA, INC.; and MASTERCARD INTERNATIONAL INC.,

Third-Party Defendants.

1. This case arises out of an indemnification dispute between Banc of America

Merchant Services, LLC (“BAMS”) and Arby’s Restaurant Group, Inc. After a data

security incident at Arby’s restaurants across the country, Visa, Inc. and Mastercard

International Inc. assessed roughly $20 million in fees on Bank of America, N.A.

(“BANA”), the bank that sponsored Arby’s as a participating merchant in Visa’s and

Mastercard’s payment card networks. BAMS, as BANA’s assignee, sought

reimbursement from Arby’s for those assessments, but Arby’s refused. So BAMS filed

this suit against Arby’s.

2. Arby’s denies any responsibility for the incident and any duty to indemnify

BAMS. It also contends that Visa and Mastercard should not have imposed the assessments in the first place. It has brought third-party claims against Visa and

Mastercard, seeking to challenge the assessments as BANA’s equitable subrogee.

3. Visa and Mastercard have moved to dismiss the third-party complaints

against them for lack of personal jurisdiction, improper venue, and failure to state a

claim. (ECF Nos. 67, 71.) For the following reasons, the Court concludes that it lacks

personal jurisdiction over Visa and Mastercard, dismisses the third-party complaints

on that basis, and denies all other requested relief as moot.

McGuireWoods LLP, by Jodie Herrmann Lawson, and Covington & Burling LLP, by Alexander A. Berengaut, for Plaintiff/Counterclaim Defendant Banc of America Merchant Services, LLC.

Smith, Anderson, Blount, Dorsett, Mitchell & Jernigan, L.L.P., by Christopher G. Smith, and Orrick, Herrington & Sutcliffe LLP, by Seth Harrington and Douglas H. Meal, for Defendant/Counterclaim Plaintiff/Third-Party Plaintiff Arby’s Restaurant Group, Inc.

Bradley Arant Boult Cummings LLP, by C. Bailey King, Jr. and Bridget V. Warren, and O’Melveny & Myers LLP, by Randall W. Edwards, Megan Havstad, and Eric Ormsby, for Third-Party Defendant Visa Inc.

Cozen O’Connor, by Tracy L. Eggleston, and Golenbock Eiseman Assor Bell & Peskoe LLP, by Martin S. Hyman and Matthew C. Daly, for Third- Party Defendant Mastercard International, Inc. 1

Conrad, Judge.

I. DISCUSSION

4. When a defendant moves to dismiss for lack of personal jurisdiction, the

plaintiff must establish, by a preponderance of the evidence, a prima facie case that

jurisdiction exists. See Bauer v. Douglas Aquatics, Inc., 207 N.C. App. 65, 68 (2010).

1 After these motions were filed, the Court granted Ms. Warren, Ms. Lawson, and Ms. Havstad leave to withdraw as counsel. (ECF Nos. 93, 131, 136.) Here, the parties rely on dueling affidavits, exhibits, and the allegations in the

third-party complaints. In such a case, “the trial judge must determine the weight

and sufficiency of the evidence presented in the affidavits much as a juror.” Capitala

Grp., LLC v. Columbus Advisory Grp. LTD, 2018 NCBC LEXIS 183, at *3 (N.C.

Super. Ct. Dec. 3, 2018) (citation and quotation marks omitted). The Court must

make findings of fact “adequate to resolve its inquiry,” and must “resolv[e] contested

facts as necessary.” Diamond Candles, LLC v. Winter, 2020 NCBC LEXIS 28, at *12

(N.C. Super. Ct. Mar. 12, 2020) (citation omitted), aff’d per curiam, 2021-NCSC-59.

Once a defendant offers evidence to support its challenge to jurisdiction, “the

allegations of an unverified complaint can no longer be taken as true or controlling,”

although the Court will “construe uncontroverted allegations in the complaint in

plaintiff’s favor.” Id. at *12–13 (citations omitted).

5. The motions have been fully briefed, and the Court held a hearing in August

2020. Having considered all relevant matters, the Court finds the following facts by

a preponderance of the evidence and makes the following conclusions of law.

A. Findings of Fact

6. This case involves the relationship between the various players involved in

credit and debit card transactions. The relevant facts are more or less undisputed.

7. Visa and Mastercard operate the payment card networks that facilitate

transactions between merchants and consumers. (See Aff. of Chad Stout ¶ 2, ECF

No. 73 [“Stout Aff.”]; Aff. of Marie Russo ¶ 8, ECF No. 69 [“Russo Aff.”].) Both card

organizations are incorporated in Delaware, with Visa headquartered in California and Mastercard headquartered in New York. (See Visa Compl. ¶ 10, ECF No. 42;

Stout Aff. ¶ 2; Mastercard Compl. ¶ 10, ECF No. 43; Russo Aff. ¶ 3.)

8. Visa and Mastercard do not issue the credit and debit cards that bear their

logos, and they do not have a direct relationship with the consumers who use the

cards or with the merchants that accept them. (See Stout Aff. ¶¶ 2, 4; Russo Aff.

¶¶ 10, 12, 23, 24.) Instead, issuing banks (“issuers”) and acquiring banks

(“acquirers”) contract with the card organizations to use their trademarks and

participate in their networks. Issuers provide cards to consumers, and acquirers

provide merchants with access to the payment networks. (See, e.g., Stout Aff. ¶¶ 2,

4; Russo Aff. ¶¶ 8–10, 12, 23, 24.)

9. BANA is an issuer and an acquirer for Visa and Mastercard. (See Visa

Compl. ¶ 33; Stout Aff. ¶ 3; Mastercard Compl. ¶ 32; Russo Aff. ¶¶ 9, 13.) It was

headquartered in California until 1999 when it moved to North Carolina. (See Russo

Aff. ¶ 14.)2 BAMS is an affiliate of BANA. It is a Delaware company that, at all times

relevant, was headquartered in Georgia. 3

2 See Bank of America, National Association, FDIC, https://banks.data.fdic.gov/bankfind- suite/bankfind/details/3510 (last updated June 25, 2021) (navigate to “History” tab). The Court may take judicial notice of information on the FDIC’s official website about FDIC- regulated banks. See N.C. R. Evid. 201(b), (c); e.g., Tehranchi v. Plan River Inv., LLC, 2012 U.S. Dist. LEXIS 200080, at *7 (C.D. Cal. May 2, 2012). 3 BAMS moved to North Carolina in 2020. See Application for Certificate of Authority for Limited Liability Company for Banc of America Merchant Services, LLC (SOSID: 1119625) (filed Oct. 14, 2009), available at https://www.sosnc.gov/; Limited Liability Company Annual Report for Banc of America Merchant Services, LLC (SOSID: 1119625) (filed Apr. 3, 2020), available at https://www.sosnc.gov/. The Court may take judicial notice of public filings available on the North Carolina Secretary of State’s official website. See N.C. R. Evid. 201(b), (c); e.g., Willard v. Barger, 2020 NCBC LEXIS 117, at *25 (N.C. Super. Ct. Oct. 9, 2020). 10. BANA’s agreement with Mastercard dates back to October 1976. It was

formed between Mastercard’s predecessor (Interbank Card Association) and BANA’s

predecessor (Bank of America NT&SA), which was headquartered in California at

the time. (See Russo Aff. ¶¶ 13, 14; Russo Aff. Ex. 3, ECF No. 69.4 [“Mastercard

Agrmt.”].) The agreement contains a New York choice-of-law clause. (See Mastercard

Agrmt. § 19; Russo Aff. ¶ 19.) And Mastercard’s “Rules,” which are incorporated by

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