Brown v. Quantcast Corp.

CourtDistrict Court, N.D. California
DecidedDecember 11, 2019
Docket3:19-cv-05773
StatusUnknown

This text of Brown v. Quantcast Corp. (Brown v. Quantcast Corp.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brown v. Quantcast Corp., (N.D. Cal. 2019).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 TAG BROWN, Case No. 19-cv-05773-EMC

8 Plaintiff, ORDER GRANTING DEFENDANT’S 9 v. MOTION TO COMPEL ARBITRATION; AND STAYING CASE 10 QUANTCAST CORP., Docket No. 22 11 Defendant.

12 13 14 Plaintiff Tag Brown has filed a putative class and collective action against Defendant 15 Quantcast Corp., his former employer. According to Mr. Brown, “Quantcast is a website analytics 16 company.” Compl. ¶ 14. He worked for Quantcast as a sales representative for which he was paid 17 a salary plus commissions. He was deemed exempt from overtime pay. See Compl. ¶ 26. Mr. 18 Brown has brought suit because he maintains that Quantcast misclassified him and others similarly 19 situated as exempt from overtime. Mr. Brown has asserted a claim for failure to pay overtime 20 under the federal Fair Labor Standards Act (“FLSA”) as well as a claim for violation of California 21 Business & Professions Code § 17200.1 Since Mr. Tag has filed suit, five other former employees 22 of Quantcast have opted into the FLSA collective action – namely: 23 • Jalen Ransome, see Docket No. 6; 24 • Tyler Berg, see Docket No. 19; 25 • Sam Awrabi, see Docket No. 20; 26

27 1 The § 17200 claim is predicated on a violation of the FLSA as well as certain provisions in the 1 • Andrea Primer, see Docket No. 20; and 2 • Pierce McManus. See Docket No. 21. 3 Quantcast now moves to compel arbitration with respect to Mr. Brown and each of the five 4 other former employees. 5 I. FACTUAL & PROCEDURAL BACKGROUND 6 Quantcast argues that arbitration must be compelled because each individual has an offer- 7 of-employment letter that contains an arbitration provision. According to Quantcast, some of the 8 individuals are also subject to arbitration based on provisions in their sales commission plans and 9 severance agreements. For purposes of the pending motion, the Court need only consider the offer 10 letters. There are two different offer letters that cover the six individuals. The parties have 11 referred to them as the first and second offer letters, respectively, and the Court shall do the same. 12 Mr. Brown and Mr. Berg received the first offer letter. See Schwartz Decl., Exs. A, E. Ms. 13 Primer, Mr. Ransome, Mr. Awrabi, and Mr. McManus received the second offer letter. See 14 Schwartz Decl., Exs. H, J, K, M. 15 II. DISCUSSION 16 A. Legal Standard 17 Quantcast asserts, and Plaintiffs do not dispute, that the Federal Arbitration Act (“FAA”) 18 governs the instant case. The FAA provides in relevant part that

19 [a] written provision in any maritime transaction or a contract evidencing a transaction involving commerce to settle by arbitration 20 a controversy thereafter arising out of such contract or transaction, or the refusal to perform the whole or any part thereof, or an 21 agreement in writing to submit to arbitration an existing controversy arising out of such a contract, transaction, or refusal, shall be valid, 22 irrevocable, and enforceable, save upon such grounds as exist at law or in equity for the revocation of any contract. 23 24 9 U.S.C. § 2. 25 Grounds that exist to support the revocation of an arbitration agreement include no contract 26 formation and contract invalidity, see generally Eiess v. USAA Fed. Sav. Bank, No. 19-cv-00108- 27 EMC, 2019 U.S. Dist. LEXIS 144026 (N.D. Cal. Aug. 23, 2019) (discussing both contract 1 arbitration or . . . derive their meaning from the fact that an agreement to arbitrate is at issue.” 2 Sakkab v. Luxottica Retail N. Am., Inc., 803 F.3d 425, 432 (9th Cir. 2015) (internal quotation 3 marks omitted). A party may also argue that an arbitration clause in a concededly binding contract 4 does not “‘appl[y] to a given controversy.’” Id. 5 B. First Offer Letter (Mr. Brown and Mr. Berg) 6 Both Mr. Brown and Mr. Berg received the first offer letter which contained the following 7 arbitration provision:

8 To ensure rapid and economical resolution of any disputes which may arise under this letter agreement, you agree that any and all 9 disputes or controversies, whether of law or fact of any nature whatsoever (including, but not limited to, all state and federal 10 statutory and discrimination claims, with the sole exception of those disputes which may arise from your confidentiality agreement) 11 arising from or regarding the interpretation, performance, enforcement or breach of this letter agreement shall be resolved by 12 final and binding arbitration under the Judicial Arbitration and Mediation Services Comprehensive Arbitration Rules and 13 Procedures. 14 Schwartz Decl., Exs. A, E. 15 Mr. Brown and Mr. Berg challenge the first offer letter on three grounds: (1) the arbitration 16 provision does not cover the claims at issue; (2) there was no “meeting of the minds” regarding 17 arbitration; and (3) the arbitration provision is unconscionable and severance cannot save it. 18 1. Scope of the Arbitration Provision 19 Mr. Brown and Mr. Berg argue first that the arbitration provision does not apply to their 20 claims because their claims do not arise under the employment agreement but rather are based on 21 statutes. See Elijahjuan v. Superior Court, 210 Cal. App. 4th 15, 20-21 (2012) (noting that a 22 Ninth Circuit case, Narayan v. EGL, Inc., 616 F.3d 895 (9th Cir. 2010), “explains the distinction 23 between rights arising under a contract and those arising under a Labor Code statute”; “[a]lthough 24 Narayan involved a choice of law provision, its reasoning is applicable here”). The problem with 25 this argument is that it reads out critical language in the arbitration provision. The provision does 26 not state that it covers claims arising from or regarding the employment agreement; rather, the 27 provision states that it covers claims arising from or regarding (inter alia) performance of the 1 performance of the employment agreement which classifies and treats Mr. Brown and Mr. Berg as 2 exempt from overtime pay. 3 2. Meeting of the Minds 4 Mr. Brown and Mr. Berg argue that, even if their claims fall within the scope of the 5 arbitration provision, the arbitration provision is not enforceable because there was no “meeting of 6 the minds” with respect to the provision. This is essentially a contract formation issue. They 7 contend that, at the time they signed the first offer letter, they also signed a sales commission plan, 8 which also contains an arbitration provision. The arbitration provision in the sales commission 9 plan states as follows:

10 Quantcast and Seller agree to submit to mandatory binding arbitration any and all claims arising out of or related to Seller’s 11 commission under this plan. Seller may bring an administrative claim before any government agency where, as a matter of law, the 12 parties may not restrict Seller’s ability to file such claims. However, to the fullest extended permitted under applicable law (including but 13 not limited to the federal Arbitration Act), Seller agrees that arbitration shall be the exclusive remedy for his or her individual 14 claims that are the subject of such administrative complaints. The arbitration shall be conducted in San Francisco, CA, before a single 15 neutral arbitration from the American Arbitration Association (“AAA”) and be governed by the AAA Rules and Procedures. 16 17 Schwartz Decl., Exs. A, E (Sales Commission Plan ¶ 14) (emphasis added). 18 Mr. Brown and Mr.

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Brown v. Quantcast Corp., Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-quantcast-corp-cand-2019.