CHECCHIA v. SOLO FUNDS, INC.

CourtDistrict Court, E.D. Pennsylvania
DecidedMarch 21, 2025
Docket2:23-cv-00444
StatusUnknown

This text of CHECCHIA v. SOLO FUNDS, INC. (CHECCHIA v. SOLO FUNDS, INC.) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
CHECCHIA v. SOLO FUNDS, INC., (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

STEVEN CHECCHIA, CIVIL ACTION

Plaintiff, NO. 23-444-KSM v.

SOLO FUNDS, INC.,

Defendant.

MEMORANDUM MARSTON, J. March 21, 2025 Plaintiff Steven Checchia, individually and on behalf of a putative class, brings this action against Defendant SoLo Funds, Inc. (“SoLo”) for violations of Pennsylvania’s Unfair Trade Practices and Consumer Protection Law (“UTPCPL”), Loan Interest and Protection Law (“LIPL”), and Consumer Discount Company Act (“CDCA”). (Doc. No. 1-2.) SoLo has moved to compel Checchia to arbitrate his claims, arguing that when Checchia created his SoLo account, he agreed to SoLo’s terms and conditions, which contained an arbitration provision (Doc. No. 40). Checchia opposes the motion, arguing that SoLo has not shown there was a valid agreement to arbitrate. (Doc. No. 41.) For the reasons discussed below, the Court grants SoLo’s motion. I. BACKGROUND1 SoLo operates an online platform that “connects third-parties seeking to borrow money . . . with third-parties offering to lend money.” (Doc. No. 40-9 at 3.) This platform is

1 As discussed below, the Court considers SoLo’s motion under the standard applicable to motions for summary judgment. Accordingly, the facts in this section are taken from the evidentiary record and viewed in the light most favorable to Checchia as the nonmovant. accessible online at www.solofunds.com and via a mobile application. (Id. at 3.) To borrow money through the platform, a user must first create an account. (Id. at 4.) On February 26, 2022, Checchia created a SoLo account using version 2.52 of SoLo’s iPhone app. (Id. at 3.) At that time, it was not possible to sign up for an account through SoLo’s website, nor was it

possible to request a loan through the website. (Doc. No. 40-10 at 3–4.) It is necessary to describe that sign-up process in some detail.2 A. SoLo’s App After downloading the app, a user in February 2022, like Checchia, would have been prompted to sign up using a pre-existing Apple, Facebook, or Google account. (See id. at 12; Video at 00:04.) In small grey lettering underneath these options was the phrase “Terms & Conditions,” which served as a hyperlink to SoLo’s “Terms”3:

2 SoLo does not maintain videos reflecting each user’s movements through its app, so it has no record of Checchia’s specific interactions. (Doc. No. 40-9 at 4.) But SoLo is capable of reverting the app to a historic version, in this case, version 2.52, which would reflect the sign-up process for the average user who used that version of the app. (Id.) Here, SoLo has submitted a screen recording, which shows what the average user would have seen when using version 2.52 of the app on an iPhone in February 2022. (See Screen Recording of Sign-Up Process for Mobile Application Version 2.52 (SoLo) (on file with Chambers) (the “Video”).) Checchia does not argue that his interaction differed from the average experience as reflected in this recording. See Dhruva v. CuriosityStream, Inc., __ F.4th __, No. 24-1080, 2025 WL 748138, at *1 (4th Cir. Mar. 10, 2025) (considering evidence showing the “website’s three-part sign-up process” because the plaintiffs “offered no evidence challenging [the defendant’s] representations about how the sign-up pages looked during the relevant times”). Accordingly, the Court relies on the screen recording and uses screenshots from that recording when describing the sign up-process. 3 In the screen recording, the hyperlink takes the user to a page labeled “Terms of Service,” which says “Revised: December 23, 2024.” (Video at 00:09.) SoLo’s Director of Product Eduardo Munoz explained that this page reflects “the version of the Terms as they appeared at the URL at the time the” screen recording was created, and not the version of SoLo’s terms and conditions that was in effect in February 2022. (Doc. No. 40-9 at 4–5.) This disconnect occurs because “[r]everting the Mobile Application to the version seen by Checchia at the time he signed-up does not alter what is available through the URL.” (Id. at 5.) In other words, although the screen recording shows the version of the app used by Checchia, the hyperlinks still take the user to the current iteration of SoLo’s terms and conditions, not the iteration that would have been available to Checchia in February 2022. A copy of the historic terms and conditions, titled simply, “Terms,” is attached to Munoz’s declaration, and an image of the first page is included here. (Id. at 21–27 (“Last Updated: May 2020”).) 2 Terms ve THIS MOBILE APPLICATION IS POWERED BY SOLO FUNDS, INC. (“SoLo*). By welcome to Sto gangs mse pate (lam sash aac oe Conditions, the SoLo Privacy Policy, and the E-SIGN Disclosure (collectively, the ‘SoLo Funds is a mobile lending exchange that “Agreement’) between you, the user (“you” or “your*), and us. Baim PAIS SS NATE These Terms and Conditions govern use of the Services. Please note that your application for any loan through the Platform is subject to a separate agreement with the AGRECHENT BOC NOT COVER THe LOAN APPLIED FOR OR OBTAINED THROUGH THE PLATFORM, unless otherwise stated herein. Requested $100 COO OS Yo me ou ue ote Serr and ay neque ee Cranes Tole ham vet tine Agen you ge ne Seroeenobten ey aver vu tenet , , detaud SoL0 ors users n any way. please be avare that SoLo wil prosecute you 0 full extent one fa ee. reserve te vant oaty mes (but will not have an obligation) to oaeiet te You will be notified in the event that your consent to additional terms and conditions is eee tent 18 days necessary to participate in certain other services provided through the Platform. SoLo Zier ‘spad—_ tte may mdi is oeet fom ne a sur modieaon shale efecve when you use the Platform after any such modification is posted. It is therefore important that you review this Agreement regularly upon each use of the Services to ensure you are updated as to any changes. THIS AGREEMENT CONTAINS AN ARBITRATION PROVISION THAT AUTHORIZES CERTAIN DISPUTES WHERE PERMITTED BY LAWN, THE TERNS OF THE. ARBITRATION PROVISION ARE SET FORTH IN THE SECTION ENTITLED “RESOLUTION OF DISPUTES BY ARBITRATION.” PLEASE READ THIS ARBITRATION PROVISION CAREFULLY. Eaton span Capp a anya wie cena obtain a personal loan ("Lean"); and/or (2) as a “Lender,” evaluate Applications and made trou neat, bom poses maepace wr Bont an Lenders. 3 ve °

(Doc. No. 40-9 at 12, 21; Video at 00:04-00:09.) The user did not have to click on the hyperlink to move forward in the sign-up process. Once the user linked their Apple, Facebook, or Google account, they were taken to a new page, which prompted them to enter their phone number into a text entry box. (Video at 00:37.) In the top right corner of this page was the phrase “Get help” in dark teal lettering, which hyperlinked to a new page that said, “Need more help?” and allowed the user to see answers to frequently asked questions or to submit a “Ticket” for assistance. (/d. at 00:37—00:46.) Underneath “Get help” and the text entry box was a faded teal rectangle with the words “Send SMS Verification.” (/d. at 00:37.) Once the user entered their phone number into the text entry box, this rectangle turned the same dark teal as the “Get help” phrase, and the user was able to click on it:

17:34 GD Fe lj 17:34 GD = i Welcome to SoLo! Get help Welcome to Solo! Get help » Let's Set You Up! Let's Set You Up! Plecise provicle the phone number you use to send Please provide the phone number you use to send & receive SMS text messages. & receive SMS text messages. We will send you a one-time oasscode. We will send you a one-time passcode

——_——————>

(Id. at 00:37—-1:00; Doc. No. 49-1 at 14.) The next page was labeled “Keep An Eye Out.” (Video at 1:00.) The “Get help” hyperlink remained in the top right comer in dark teal.

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CHECCHIA v. SOLO FUNDS, INC., Counsel Stack Legal Research, https://law.counselstack.com/opinion/checchia-v-solo-funds-inc-paed-2025.