First-Citizens Bank and Trust Company v. HSBC Holdings plc

CourtDistrict Court, N.D. California
DecidedJanuary 10, 2024
Docket3:23-cv-02483
StatusUnknown

This text of First-Citizens Bank and Trust Company v. HSBC Holdings plc (First-Citizens Bank and Trust Company v. HSBC Holdings plc) 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
First-Citizens Bank and Trust Company v. HSBC Holdings plc, (N.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 San Francisco Division 11 FIRST-CITIZENS BANK & TRUST Case No. 23-cv-02483-LB COMPANY, a Delaware Corporation, 12 ORDER GRANTING MOTION TO Plaintiff, DISMISS IN PART AND 13 DENYING MOTION TO STAY v. DISCOVERY 14 HSBC HOLDINGS plc a/k/a THE HSBC Re: ECF Nos. 46, 48 15 GROUP a/k/a HONGKONG AND SHANGHAI BANKING CORPORATION, et al., 16 Defendants. 17 18 INTRODUCTION 19 Silicon Valley Bank (SVB) collapsed on Friday, March 10, 2023. Its depositors (concentrated in 20 the tech sector) had withdrawn substantial cash, resulting in the bank’s sale of investments on March 21 8 at a loss to cover the withdrawals and then, on March 9, a run on the bank’s deposits by other 22 depositors.1 The FDIC was appointed as the receiver and, on Monday, March 13, transferred the 23 assets (through a transfer agreement) into a bridge bank to protect depositors.2 On Monday, March 24 27, plaintiff First Citizens Bank acquired SVB’s deposits and loans through a purchase agreement 25 26 1 Compl. – ECF No. 1 at 3 (¶ 1), 16 (¶ 63), 17–18 (¶¶ 74). Citations refer to material in the Electronic Case File (ECF); pinpoint citations are to the ECF-generated page numbers at the top of documents 27 and page numbers at the bottom. 2 1 with the FDIC.3 SVB’s UK subsidiary SVB UK collapsed too: the Bank of England seized its assets 2 and by March 13 had sold SVB UK to defendant HSBC for £1 (approximately $1.21).4 3 Defendant David Sabow was a longtime senior executive at SVB until early 2023, when he 4 transferred to SVB UK to become CEO and head of Europe, the Middle East, and Africa (effective 5 April 1, 2023).5 He became an HSBC executive “within days of HSBC’s acquisition of SVB UK.”6 6 On April 9, 2023 (Easter Sunday), at 9:00 p.m., forty-two former SVB employees — including six 7 “core leaders” in the U.S. (individual defendants Sunita Patel, Melissa Stepanis, Peter Kidder, Kevin 8 Longo, Rebekah Hanlon, and Katherine Andersen) — resigned from First Citizens to work at 9 HSBC.7 Mr. Sabow allegedly targeted the employees (all senior bankers) because they could bring 10 other employees with them.8 First Citizens alleged that this poaching (dubbed “Project Colony” by 11 Mr. Sabow) included misappropriation of SVB’s “confidential, proprietary[,] and trade secret 12 information.”9 It asserts rights to SVB’s intellectual property through the transfer agreement.10 13 14 15 16 17 18 3 Compl. – ECF No. 1 at 2, 21 (¶ 91). 4 Id. at 3 (¶ 2), 21 (¶ 92). The plaintiff refers to the five entity defendants — HSBB Holdings a/k/a 19 Hongkong and Shanghai Banking Corporation, HSBC USA Inc., HSBC Bank USA, N.A., HSBC UK, and SVB UK Ltd. — collectively as HSBC. Id. at 2. 20 5 Id. at 3 (¶ 3), 36 (¶ 154). 21 6 Id. at 3 (¶ 3). 22 7 Id. at 2, 3–4 (¶ 3), 6 (¶ 13). 8 Id. at 2, 4 (¶¶ 4–5), 22 (¶ 97). 23 9 Id. at 3–4 (¶ 3) (bullet points of information, including SVB’s “win rate” and volumes against its core 24 competitors, data about SVB’s market share within U.S. segments and borrower types, data about market-share percentages for SVB’s Life Sciences & Technology based on market cap and total 25 amounts of deposits and investments (including the amount of future commitments, broken down by various factors), SVB’s practice overview notes about clients (including pace of adding clients, 26 numbers, ranking, valuations, and growth metrics), information about employees (capacity, head count, names, positions, and salaries), SVB’s ability to attract and meet needs of targeted customers 27 (possibly tied to the employee information), information about SVB’s loan portfolio (including implied revenue and growth), and an analysis of loans within SVB’s Accelerator & Growth Group). 1 The complaint has (1) claims against individual defendants for breach of their employment 2 contracts with SVB (claim one) and First Citizens (claim three), (2) claims against the individual 3 defendants (except for Mr. Sabow) for breach of their duty of loyalty and fiduciary duty to First 4 Citizens (claims four and five), (3) aiding and abetting these breaches (by Mr. Sabow and the 5 HSBC defendants) (claim six), (4) tortious interference with contract and prospective economic 6 advantage by all defendants (claims seven and eight), (5) misappropriation of trade secrets by all 7 defendants, in violation of the federal Defend Trade Secrets Act (DTSA) and state law (either 8 California’s Uniform Trade Secrets Act (CUTSA) or North Carolina Trade Secrets Protection Act) 9 (claims nine and ten), and (6) civil conspiracy by all defendants.11 10 The defendants moved to dismiss on the grounds that (1) First Citizens lacks standing to bring 11 claims one and five through ten and twelve because its purchase agreement with the FDIC precludes 12 claims based on conduct that predates the agreement’s execution on March 27, 2023, and, for claim 13 one, because it did not acquire a right to enforce confidentiality agreements, (2) it did not plausibly 14 plead claims, and (3) there is no personal jurisdiction over the five entity defendants and three out- 15 of-state individual defendants.12 16 First Citizens has standing: it rests its claims only on conduct that post-dates its purchase of the 17 SVB assets, and it acquired the right in its purchase agreement (and through the earlier transfer 18 agreement to the bridge bank) to enforce the confidentiality provisions. First Citizens plausibly 19 pleads viable theories supporting the contract and misappropriation claims against the HSBC 20 successor to SVB UK and Mr. Sabow. But it lumps the other defendants together, thus does not 21 give fair notice of the claims against them, and seemingly predicates claims on conduct that 22 predates the purchase agreement (even though it disavowed reliance on those acts in its opposition). 23 At minimum, the complaint is confusing and needs to be cleaned up. CUTSA preempts the state tort 24 claims (as alleged in this complaint). Finally, First Citizens said at the hearing that it would clean up 25 26 27 11 Compl. – ECF No. 1 at 36–66 (¶¶ 153–275). The plaintiff voluntarily dismissed claims two and eleven. Opp’n – ECF No. 60 at 12 n.3. 1 its jurisdictional allegations. First Citizens must address these deficiencies by filing an amended 2 complaint within twenty-eight days. 3 The court denies the motion to stay discovery because there is a viable case going forward. 4 5 STATEMENT 6 1. SVB’s Collapse and First Citizens’ Acquisition 7 SVB Financial Group was a bank holding company that provided banking services through its 8 “subsidiaries and divisions, such as” SVB in the U.S. and SVB UK in the United Kingdom.13 The 9 individual defendants are former employees of SVB or SVB UK.14 David Sabow started at SVB in 10 2012, became the head of Life Sciences and Technology Banking, and, in early 2023, became 11 CEO of SVB UK and head of Europe, the Middle East, and Africa (effective April 1, 2023, but 12 apparently necessitating a transfer of functions earlier).15 He allegedly had an executive function 13 at SVB until March 1, 2023, to award 2022 compensation awards.16 14 “Over a period of two days in March 2023, SVB went from solvent to broke.”17 On March 8, it 15 announced a $1.8 billion loss after it sold investments at a loss to cover withdrawals.18 The next 16 day, its stock “plummeted,” and VC firms “began pulling their money out of SVB.” By the end of 17 the day, depositors had withdrawn $42 billion.19 On March 10, 2023, California regulators closed 18 the bank and appointed the FDIC as receiver.20 On March 13, the Bank of England, which had 19 seized the assets of SVB’s UK affiliate, SVB UK, sold them to HSBC UK for £1.21 That day, the 20 FDIC transferred SVB’s deposits and entities — via a transfer agreement — to a new entity (the 21

22 13 Compl. – ECF No. 1 at 16 (¶ 60). 23 14 Id. at 3–4 (¶¶ 3–4). 15 Id. at 22 (¶ 94), 36 (¶ 154). 24 16 Id. at 22 (¶ 94). 25 17 Id. at 17 (¶ 71).

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Bluebook (online)
First-Citizens Bank and Trust Company v. HSBC Holdings plc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/first-citizens-bank-and-trust-company-v-hsbc-holdings-plc-cand-2024.