Comerica Bank v. Global Payments Direct, Inc.

CourtCourt of Chancery of Delaware
DecidedJuly 21, 2014
DocketCA 9707-CB
StatusPublished

This text of Comerica Bank v. Global Payments Direct, Inc. (Comerica Bank v. Global Payments Direct, Inc.) is published on Counsel Stack Legal Research, covering Court of Chancery of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Comerica Bank v. Global Payments Direct, Inc., (Del. Ct. App. 2014).

Opinion

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

COMERICA BANK, a Texas Banking ) Association, ) ) Plaintiff, ) ) v. ) C.A. No. 9707-CB ) GLOBAL PAYMENTS DIRECT, INC., a ) New York Corporation, ) ) Defendant, ) ) and ) ) GLOBAL PAYMENTS COMERICA ) ALLIANCE, L.L.C., a Delaware Limited ) Liability Company, ) ) Nominal Defendant. )

MEMORANDUM OPINION

Date Submitted: July 18, 2014 Date Decided: July 21, 2014

Daniel A. Dreisbach, Thomas A. Uebler and Sarah A. Clark of Richards, Layton & Finger, P.A., Wilmington, DE; Howard J. Roin and Laura R. Hammargren of Mayer Brown LLP, Chicago, Illinois, Attorneys for Plaintiff.

Peter B. Ladig, Meghan A. Adams and Kyle E. Gay of Morris James LLP, Wilmington, DE; John P. Brumbaugh and Claire Carothers Oates of King & Spalding LLP, Atlanta, GA, Attorneys for Defendant.

BOUCHARD, C. I. INTRODUCTION

This action involves a business divorce. In 1996, predecessors of plaintiff

Comerica Bank (“Comerica”) and defendant Global Payment Direct, Inc. (“Global” or

“Global Direct”) established a Delaware limited liability company called Global

Payments Comerica Alliance, L.L.C. (“Alliance”) to process credit and debit card

transactions in a joint venture. Comerica, a financial institution and a member of the

Visa and MasterCard associations, agreed to refer merchants to Alliance exclusively.

Global, a payment processor, was to be the exclusive processor for Alliance. These

arrangements are reflected in a series of agreements the parties entered simultaneously

when the joint venture began.

In October 2013, Comerica elected not to renew the parties’ Service Agreement,

which thus expired on January 31, 2014. On May 14, 2014, Comerica exercised its right

to dissolve Alliance. Now, the parties are embroiled in a series of disputes as they work

through the wind up of Alliance and Comerica seeks to transition its share of the

merchant portfolio to a new payment processor. Global asserts that Comerica remains

bound by certain exclusivity obligations during the transition period. Comerica seeks

declaratory relief that, among other things, it is no longer bound by these obligations. It

also seeks the appointment of a liquidating trustee. An expedited trial on these issues was

held on July 14-15, 2014.

In this opinion, I conclude that the exclusivity and non-competition obligations in

the parties’ agreements, discussed in detail below, ended when the Service Agreement

1 terminated on January 31, 2014. Comerica’s request for a liquidating trustee will be

addressed separately at a later date.

II. BACKGROUND1

A. The Parties

Plaintiff Comerica Bank is a Texas Banking Association with its principal place of

business in Dallas, Texas. It is a member of the Visa and MasterCard associations.

Defendant Global Payments Direct, Inc. is a New York corporation with its

principal place of business in Atlanta, Georgia. It is a provider of payment processing

services.

Electronic payment processing involves a consumer acquiring goods or services

from a merchant using an electronic method such as a credit card as the form of payment.

A payment processor is the intermediary between the merchant, the credit card networks,

and the banks that issue credit cards. Visa and MasterCard, which are the largest card

associations, require that a payment processor be sponsored by a member financial

institution. In this arrangement, a payment processor will route and clear transactions

under the member bank’s control through the Visa and MasterCard networks.

1 The Pre-trial Stipulation and Order is cited as “PTO.” Joint trial exhibits are cited as “JX.” The trial transcript is cited as “Trial Tr.”

2 B. The Formation of Alliance and the Governing Agreements

On March 31, 1996, Comerica2 and Global entered into a Limited Liability

Company Agreement (“LLC Agreement”) establishing Alliance as a joint venture to

process credit and debit card transactions and provide related services.3 Alliance

provides these services to merchants in its merchant portfolio with whom it has made

agreements.4 Alliance’s merchant customers are collectively referred to as the “Merchant

Portfolio.”

Alliance is a Delaware limited liability company. Comerica and Global have been

its only two members during the time period relevant to this action, with Global holding a

51% membership interest and Comerica holding a 49% membership interest.5 Alliance is

managed by its two members, who act through designated Representatives. Global has

three Representatives and Comerica has two Representatives.6

As part of their joint venture, Comerica and Global entered into additional

agreements on and after March 31, 1996, including (1) Asset Purchase and Contribution

2 The named parties to the LLC Agreement were Comerica Bank-Texas and Comerica Merchant Services, Inc., which are predecessors of Comerica, and National Data Payments Systems, Inc., which is now known as Global. PTO § II, ¶ 6. I refer to them as Comerica and Global, respectively, for simplicity. 3 Id. 4 JX 5 § 4.1. 5 PTO § II, ¶ 4. 6 Id. § II, ¶ 5.

3 Agreements dated March 31, 1996, December 31, 1996, and May 31, 2001

(“Contribution Agreements”) and (2) Merchant Alliance and Service Agreements dated

March 31, 1996 and May 31, 2001 (“Service Agreement”).7 In general terms, the

Contribution Agreements set forth the terms by which Comerica contributed its merchant

accounts to Alliance, and the Service Agreement sets forth specific services that

Comerica and Global each would provide to each other and Alliance in connection with

the joint venture. The Contribution Agreements and the Service Agreement are governed

by Delaware law.8

C. Key Provisions of the Service Agreement

Section 2 of the Service Agreement sets forth the services that Global and

Comerica were obligated to provide to Alliance and each other.9 Under that section,

Global was obligated to furnish certain services listed in Exhibit A (“Global Direct

Services”), which generally consist of payment processing services, and Comerica was

obligated to furnish certain services listed in Exhibit C (“Comerica Services”), which

7 The most recent comprehensive update of the Service Agreement is the Second Amended and Restated Merchant Alliance and Service Agreement dated May 31, 2001. JX 10. The parties agree that the language in Sections 15(a) and 15(d) of the Service Agreement, which are at the heart of the present dispute, was the same in the original March 31, 1996 version. PTO § II, ¶ 10. 8 JX 11 § 13.9 (May 31, 2001 Contribution Agreement); JX 10 § 24(a) (May 31, 2001 Service Agreement). 9 JX 10 § 2.

4 generally consist of bank sponsorship and transaction clearing services.10 The Global

Direct Services and the Comerica Services, collectively, are defined in the Service

Agreement as the “Services.”11

The Service Agreement contains certain exclusivity obligations. Section 2

provides, in relevant part, that “[d]uring the term of this Agreement, Alliance [and

Comerica] shall purchase all merchant processing services, including but not limited to

the Global Direct Services, exclusively from Global Direct.”12 Section 6(a) provides, in

relevant part, that “[d]uring the term of this Agreement, [Comerica] agrees[s] to refer to

Alliance, exclusively, potential merchants for Credit Card processing services.”13

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