DesignTechnica Corporation v. Swigart Law Group

CourtDistrict Court, S.D. California
DecidedDecember 9, 2024
Docket3:24-cv-01054
StatusUnknown

This text of DesignTechnica Corporation v. Swigart Law Group (DesignTechnica Corporation v. Swigart Law Group) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
DesignTechnica Corporation v. Swigart Law Group, (S.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 DESIGNTECHNICA CORPORATION, Case No.: 24-CV-1054 W (AHG)

12 Plaintiff, ORDER GRANTING DEFENDANT’S 13 v. MOTION TO DISMISS [DOC. 4] 14 SWIGART LAW GROUP, APC and Thirty-Six (36) Of Its Putative Clients, 15 Defendants. 16 17 18 19 Pending before the Court is Swigart Law Group’s (“SLG”) motion to dismiss 20 DesignTechnica Corporation’s (“DTC”) Complaint under Federal Rule of Civil Procedure 21 12(b)(1) and (b)(6). (Mtn. [Doc. 4].) The Court decides the matter on the papers submitted 22 and without oral argument. See CivLR 7.1(d)(1). For the reasons provided below, the 23 Court GRANTS the motion to dismiss based on lack of subject matter jurisdiction. 24 25 I. BACKGROUND 26 DesignTechnica (“DTC”) is a multimedia company incorporated in Delaware with 27 its principle place of business in Portland, Oregon. (Complaint [Doc. 1] 2, ¶ 2.) DTC 28 manages two websites pertinent to this lawsuit: www.themanual.com (“the Manual”) and 1 www.digitaltrends.com (“Digital Trends”) (collectively “the Websites”). (Id. at ¶ 8.) The 2 Manual is described as “the essential guide for men . . . offering a suite of expert guides on 3 a wide range of topics, including fashion, food, drink, travel, and grooming[.]” (Id.) 4 Digital Trends is described as a website “that guides consumers to the best products and 5 services available . . . .” (Id.) 6 Upon visiting the Websites, visitors are required to either agree to all the Terms of 7 Use or cease use of the services. (Id. at ¶ 9.) Under the Terms of Use, visitors agree that 8 any dispute “will be governed by and construed and enforced in accordance with the laws 9 of Oregon, except to the extent preempted by U.S. federal law . . . .” (Id. at ¶ 10.) Further, 10 “[a]ny dispute between the parties that is not subject to arbitration or cannot be heard in 11 small claims court will be resolved in the state or federal courts of Oregon and the United 12 States, respectively, sitting in Multnomah County, Oregon.” (Id.) The Terms of Use also 13 contain a binding mandatory arbitration provision requiring aggrieved parties to submit to 14 arbitration administered by JAMS. (Id. at ¶ 11.) 15 The present suit arises out of thirty-six separate claims brought on behalf of various 16 claimants (collectively “Claimants”) against DTC with JAMS. (Id. at ¶¶ 13–14.) DTC 17 alleges that Swigart Law Group has filed various “cookie-cutter allegations of . . . the 18 California Invasion of Privacy Act (CIPA)” in violation of the choice of law provision 19 requiring all disputes to be governed by Oregon substantive law. (Id. at ¶¶ 15–17.) DTC 20 argues that Claimants “have suffered no actual damages,” are “rely[ing] solely on CIPA’s 21 $5,000 . . . statutory penalty for any recovery,” and that “SLG is . . . filing large numbers 22 of baseless claims in contravention of the Terms’ choice of law provision in an effort to 23 compel DTC . . . to pay to settle claims rather than incur significant arbitration fees.” (Id. 24 at ¶¶ 18–19.) 25 In response to the arbitration claims brought with JAMS, DTC has filed the present 26 suit in federal court. Among other things, DTC prays for a declaratory judgment that the 27 Terms of Use and Choice of Law provision are enforceable against SLG and Claimants 28 (collectively “Defendants”), as well as an injunction enjoining present and potential future 1 CIPA claims arising out of the same facts and circumstances. (Id. at 7.) Defendants have 2 filed a motion to dismiss under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). 3 (Mtn. [Doc. 4].) DTC opposes. (Opp’n [Doc. 5].) 4 5 II. LEGAL STANDARD 6 Federal courts are courts of limited jurisdiction. Exxon Mobil Corp. v. Allapattah 7 Servs., Inc., 545 U.S. 546, 552 (2005). Limited jurisdiction means that federal courts can 8 only adjudicate cases that both the Constitution and Congress authorize them to adjudicate, 9 such as those involving diversity of citizenship, a federal question, or where the United 10 States is a party. Id. See also Ex parte Bollman, 8 U.S. 75, 94 (1807) (“To enable the court 11 to decide on such question, the power to determine it must be given by written law.”). 12 Federal courts are presumptively without jurisdiction over civil actions, and the burden of 13 establishing the contrary rests upon the party asserting jurisdiction. Kokkonen v. Guardian 14 Life Ins. Co., 511 U.S. 375, 377 (1994). 15 Under Rule 12(b)(1) of the Federal Rules of Civil Procedure, a defendant may seek 16 to dismiss a complaint for lack of subject matter jurisdiction. Because subject matter 17 jurisdiction involves the authority of the court to decide the case, the court cannot reach 18 the merits of any dispute until it confirms its own subject matter jurisdiction. See Steel Co. 19 v. Citizens for a Better Environ., 523 U.S. 83, 95 (1998). Additionally, lack of subject 20 matter jurisdiction may be raised either by the parties or sua sponte by the court. See 21 Washam v. Rabine, No. 3:12CV2433-GPC-BLM, 2013 WL 1849233, at *1 (S.D. Cal. May 22 1, 2013). 23 When considering a Rule 12(b)(1) motion to dismiss, the district court is free to hear 24 evidence regarding jurisdiction and to rule on that issue prior to trial, resolving factual 25 disputes where necessary. Augustine v. United States, 704 F.2d 1074, 1077 (9th Cir. 1983). 26 In such circumstances, “[n]o presumptive truthfulness attaches to [a] plaintiff’s allegations, 27 and the existence of disputed facts will not preclude the trial court from evaluating for itself 28 1 the merits of jurisdictional claims.” Id. (quoting Thornhill Publishing Co. v. General 2 Telephone & Electronic Corp., 594 F.2d 730, 733 (9th Cir. 1979). 3 DTC does not dispute SLG’s assertion that the lawsuit does not invoke federal 4 question jurisdiction. See (Opp’n at 5–6) (discussing only diversity jurisdiction). 5 Therefore, the only plausible jurisdictional hook is diversity jurisdiction. 28 U.S.C. § 1332. 6 Diversity jurisdiction requires complete diversity of citizenship between both parties and 7 an amount-in-controversy exceeding $75,000. See Agha v. U.S. Small Bus. Admin., No. 8 13-CV-1943-MMA (JMA), 2014 WL 12539701, at *1 (S.D. Cal. Apr. 17, 2014). 9 The parties also do not dispute that there is complete diversity of citizenship present 10 on both sides of the suit. (Reply at 1: 20); (Opp’n at 5: 6–12) (“[T]he parties are citizens 11 of different states as Plaintiff is a citizen of Oregon and Defendants are all citizens of 12 California . . . .”). Therefore, the only issue is whether the amount-in-controversy element 13 has been satisfied. 14 15 III. DISCUSSION 16 A court should not dismiss an action for failure to satisfy the amount-in-controversy 17 requirement unless it appears to a “legal certainty” that a plaintiff’s claim is for less than 18 the jurisdictional amount. See Abrego Abrego v. Dow Chemical Co., 443 F.3d 676, 683 19 n. 8 (9th Cir. 2006).

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Related

Ex Parte Bollman and Swartwout
8 U.S. 75 (Supreme Court, 1807)
Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Richard Augustine v. United States
704 F.2d 1074 (Ninth Circuit, 1983)
Exxon Mobil Corp. v. Allapattah Services, Inc.
545 U.S. 546 (Supreme Court, 2005)
Mendez-Castro v. Mukasey
552 F.3d 975 (Ninth Circuit, 2009)
Steel Co. v. Citizens for a Better Environment
523 U.S. 83 (Supreme Court, 1998)
De La Rosa v. Reliable, Inc.
113 F. Supp. 3d 1135 (D. New Mexico, 2015)

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DesignTechnica Corporation v. Swigart Law Group, Counsel Stack Legal Research, https://law.counselstack.com/opinion/designtechnica-corporation-v-swigart-law-group-casd-2024.