DotC United, Inc. v. Google Asia Pacific Pte. Ltd.

District Court, N.D. California·Decided May 1, 2023·No. 3:22-cv-04990·Unknown

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 DOTC UNITED, INC., et al., Case No. 22-cv-04990-JSC

8 Plaintiffs, ORDER FOLLOWING APRIL 19, 2023 v. 9 HEARING

10 GOOGLE ASIA PACIFIC PTE. LTD., Re: Dkt. Nos. 6, 32 Defendant. 11

12 13 Petitioners, DotC United, Inc., and Avazu Inc., challenge an order from an international 14 arbitration panel finding it had jurisdiction over Petitioners, non-signatories to the underlying 15 arbitration agreement. Petitioners move under the Federal Arbitration Act (FAA) to vacate the 16 arbitration panel’s order finding jurisdiction and Respondent Google Asia cross-moves to confirm the 17 order. (Dkt. Nos. 6, 32.) At the initial hearing on the cross-petitions, the Court requested 18 supplemental briefing regarding the scope of the Court’s review in light of the absence of a delegation 19 clause and the Supreme Court’s directive that courts conduct “independent review” of the arbitrability 20 question, see First Options of Chicago, Inc. v. Kaplan, 514 U.S. 938 (1995). (Dkt. No. 55.) On April 21 19, 2023, the Court heard further argument regarding the cross-petitions and supplemental briefing. 22 Having considered the parties’ arguments and the legal authority, this Order confirms the matters 23 discussed at the hearing and the Court’s rulings on certain preliminary matters. 24 DISCUSSION 25 A. Standard of Review 26 The parties agree that the standard of review under First Options is “independent,” but 27 they disagree as to what that means. Google Asia contends it means clear error for facts and de 1 (Dkt. Nos. 60, 66, 70.) 2 Where, as here, “the parties did not agree to submit the arbitrability question itself to 3 arbitration, then the court should decide that question just as it would decide any other question that 4 the parties did not submit to arbitration, namely, independently.” First Options of Chicago, Inc. v. 5 Kaplan, 514 U.S. 938, 943 (1995) (emphasis in original). Independent review is just that— 6 independent and without deference to the arbitrators’ findings. See Kaplan v. First Options of 7 Chicago, Inc., 19 F.3d 1503, 1520 (3d Cir. 1994), aff'd, 514 U.S. 938 (1995) (“neither this Court nor 8 the district court is bound by the arbitrators’ determination that Mr. Kaplan was the alter ego of MKI. 9 He is entitled to an independent judicial determination of that issue.”). So, the arbitrators’ findings are 10 not reviewed for clear error. To so hold would violate the Supreme Court’s command that the trial 11 court decide arbitrability independently. Clear error is not independent review; instead, it is having “a 12 serious thumb on the scale for the [factfinder].” U.S. Bank Nat. Ass’n ex rel. CWCapital Asset Mgmt. 13 LLC v. Vill. at Lakeridge, LLC, 138 S. Ct. 960, 966 (2018); see also Fed. R. Civ. P. 52(a)(6) (defining 14 the “clearly erroneous” standard as giving “due regard to the trial court’s opportunity to judge the 15 witnesses’ credibility”). 16 B. Choice-of-Law 17 The law governing whether Petitioners are bound by the arbitration agreement is federal 18 substantive law. “In cases involving the New York Convention, in determining the arbitrability of 19 federal claims by or against non-signatories to an arbitration agreement, [courts] apply federal 20 substantive law, for which we look to ordinary contract and agency principles.” Setty v. Shrinivas 21 Sugandhalaya LLP, 3 F.4th 1166, 1168 (9th Cir. 2021) (cleaned up). This is because “[t]he New York 22 Convention and its implementing legislation emphasize the need for uniformity in the application of 23 international arbitration agreements.” Id. at 1168. 24 Petitioners’ insistence Setty is distinguishable because the underlying claims involved federal 25 trademark claims whereas the underlying claims here are essentially state law breach of contract 26 claims is unpersuasive. First, the Ninth Circuit’s determination that federal substantive law applied in 27 Setty was not based on the federal nature of the underlying claims, but on the “need for uniformity in 1 Seventh Circuit Court of Appeal’s statement in Certain Underwriters at Lloyd’s v. Argonaut Ins. Co., 2 that “‘[t]he Supreme Court has recognized that in the context of the New York Convention, uniformity 3 of the law is of paramount importance’ and concluding application of state-specific law would 4 undermine this purpose.” Setty, 3 F.4th at 1168 (quoting Certain Underwriters at Lloyd’s v. Argonaut 5 Ins. Co., 500 F.3d 571, 580–81 (7th Cir. 2007) (emphasis in original”). Setty likewise noted that its 6 conclusion was consistent with decisions from the First, Second, and Fourth Circuits. Setty, 3 F.4th at 7 1168, n.1 (citing Smith/Enron Cogeneration Ltd. P’ship, Inc. v. Smith Cogeneration Int’l, Inc., 198 8 F.3d 88, 97 (2d Cir. 1999) (explaining that when the court exercises jurisdiction under Chapter Two of 9 the FAA, it has “compelling reasons to apply federal law, which is already well developed, to the 10 question of whether an agreement to arbitrate is enforceable” and that to conclude otherwise would 11 “introduce a degree of parochialism and uncertainty into international arbitration” and undermine the 12 FAA’s goal of simplicity and uniformity.); Int’l Paper Co. v. Schwabedissen Maschinen & Anlagen 13 GMBH, 206 F.3d 411, 413–14 (4th Cir. 2000) (recognizing the FAA and the New York Convention 14 “create a body of federal substantive law of arbitrability, applicable to any arbitration agreement 15 within the coverage of the Act” and looking to the “federal substantive law of arbitrability” to 16 determine whether a non-signatory was bound by the contract)). Further, none of the cases upon 17 which Setty relied involved federal claims. See, e.g., Anlagen GMBH, 206 F.3d at 414 (state law 18 breach of contract claims); Argonaut Ins. Co., 500 F.3d at 572 (insurance coverage dispute); Grina, 19 344 F.3d at 140 (state law tort and misrepresentation claims); Smith/Enron Cogeneration, 198 F.3d at 20 91 (fraudulent inducement and tortious interference claims). 21 Equally telling, the cases Petitioners rely upon for the proposition that the Court should follow 22 the Restatement (Second) of Conflict of Laws did not involve the New York Convention. See e.g., 23 Schoenberg v. Exportadora de Sal, S.A. de C.V., 930 F.2d 777, 782 (9th Cir. 1991) (holding the 24 Restatement (Second) of Conflict of Laws applied when jurisdiction based on Foreign Sovereign 25 Immunities Act (FSIA)); Bassidji v. Goe, 413 F.3d 928, 933 (9th Cir. 2005) (holding that because 26 “federal subject-matter jurisdiction in this case is based on the parties’ diversity of citizenship” “the 27 choice-of-law principles of the forum state” apply); Chuidian v. Philippine Nat. Bank, 976 F.2d 561, 1 based on FSIA); Huynh v.

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DotC United, Inc. v. Google Asia Pacific Pte. Ltd., (N.D. Cal. 2023).

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