Global Payments, Inc. v. Incomm Financial Services, Inc

843 S.E.2d 821, 308 Ga. 842
CourtSupreme Court of Georgia
DecidedJune 1, 2020
DocketS19G1000
StatusPublished
Cited by8 cases

This text of 843 S.E.2d 821 (Global Payments, Inc. v. Incomm Financial Services, Inc) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Global Payments, Inc. v. Incomm Financial Services, Inc, 843 S.E.2d 821, 308 Ga. 842 (Ga. 2020).

Opinion

308 Ga. 842 FINAL COPY

S19G1000. GLOBAL PAYMENTS, INC. v. INCOMM FINANCIAL SERVICES, INC.

ELLINGTON, Justice.

In InComm Financial Svcs. v. Global Payments, 349 Ga. App.

363, 365 (1) (825 SE2d 839) (2019), the Court of Appeals reversed

the trial court’s order dismissing InComm’s negligent

misrepresentation claim against Global based on Global’s having

transmitted to InComm allegedly false information generated by a

third party. We granted Global’s petition for a writ of certiorari to

consider that holding. Because the allegations of the complaint show

that Global merely transmitted data concerning debit and credit

card transactions without representing that the transactions were

legitimate, the Court of Appeals erred, and we reverse.

We begin with the well-settled standard that

[a] motion to dismiss for failure to state a claim upon which relief may be granted should not be sustained unless (1) the allegations of the complaint disclose with certainty that the claimant would not be entitled to relief under any state of provable facts asserted in support thereof; and (2) the movant establishes that the claimant could not possibly introduce evidence within the framework of the complaint sufficient to warrant a grant of the relief sought. If, within the framework of the complaint, evidence may be introduced which will sustain a grant of the relief sought by the claimant, the complaint is sufficient and a motion to dismiss should be denied. In deciding a motion to dismiss, all pleadings are to be construed most favorably to the party who filed them, and all doubts regarding such pleadings must be resolved in the filing party’s favor.

(Citations omitted.) Anderson v. Flake, 267 Ga. 498, 501 (2) (480

SE2d 10) (1997). “On appeal, a trial court’s ruling on a motion to

dismiss for failure to state a claim for which relief may be granted

is reviewed de novo.” Northway v. Allen, 291 Ga. 227, 229 (728 SE2d

624) (2012). So viewed, InComm’s complaint shows the following.

InComm issues pre-paid debit and credit cards under the

“Vanilla VISA” brand to cardholders who use the cards to buy goods

and services. Global is a financial data payment processor. Global

provides its clients, primarily merchants, with payment technology

hardware and software that allows them to accept card payments

and to communicate electronically with card networks and card issuers. For example, when a Vanilla VISA cardholder makes a

purchase from a merchant who is a client of Global, Global transmits

the payment data it receives from the merchant to the VISA

network, and the VISA network relays the data to the card issuer,

InComm. In this case, thieves purchased Vanilla VISA pre-paid

debit and credit cards and used them to buy goods and services.

Then, using certain merchants that were not the merchants who

originally sold the goods and services, the thieves initiated

counterfeit electronic “reversal transactions” — basically requests

for refunds on behalf of the cardholders. Upon receiving the reversal

transaction data from the merchants, Global relayed the data to the

VISA network. The VISA network then submitted the reversal

transaction data to InComm. InComm received the data, posted the

reversal transactions to the cardholder accounts, and then issued

credits to the merchants who, in turn, passed the credits on to the

thieves holding the Vanilla VISA cards. The thieves then converted

those credits (in excess of $1.5 million made over 3,600 transactions)

to their use. InComm does not allege that Global participated in creating

the counterfeit reversal transactions. InComm alleged in its

complaint that thieves used merchants to create the counterfeit

reversal transactions at issue. Specifically, InComm alleged that “all

of the Reversal Transactions were initiated through the accounts of

the Reversal Merchants and electronically transmitted to [Global].”

Although Global had no role in creating the counterfeit transactions,

InComm nevertheless asserted that Global is liable for the losses

InComm suffered as a consequence of those transactions because

Global negligently supplied to the VISA network the data created by

the reversal merchants. In support of its claim, InComm asserted

that Global, as a payment processor, “had a duty to exercise

reasonable care in supplying the VISA Network and its participants

with the transactions initiated by the Reversal Merchants.”

InComm alleged that Global

knew or should have known that the Reversal Transactions were invalid because: (a) the Originating Merchants (who debited the Vanilla VISA cards) were different from the Reversal Merchants; (b) the preauthorization keys transmitted by the Reversal Merchants in the Reversal Transactions did not match any prior preauthorization key sent by the same Reversal Merchant; and (c) the preauthorization keys of the Reversal Transactions did not match any preauthorization keys in any Originating Transaction processed by [Global].

Citing this Court’s decision in Robert & Co. Assoc. v. Rhodes-Haverty

Partnership, 250 Ga. 680 (300 SE2d 503) (1983), InComm alleged

that Global owes it a common-law duty of ordinary care and is liable

to it under a negligent misrepresentation tort theory of liability for

supplying it with “bogus data.” InComm has not alleged, however,

that Global transmitted data that had been altered intentionally or

negligently by Global or that otherwise failed to accurately reflect

the counterfeit transactions.

“In [Robert,] this Court first recognized a claim for negligent

misrepresentation and adopted the liability standard set forth in

section 552 of the Restatement (Second) of Torts.” BDO Seidman,

LLP v. Mindis Acquisition Corp., 276 Ga. 311, 311 (1) (578 SE2d

400) (2003).1 Under the standard adopted in Robert,

1 Although this Court has looked to § 552 of the Restatement (Second) of one who supplied information during the course of his business, profession, employment, or in any transaction in which he has a pecuniary interest has a duty of reasonable care and competence to parties who rely upon the information in circumstances in which the maker was manifestly aware of the use to which the information was to be put and intended that it be so used. This liability is limited to a foreseeable person or limited class of persons for whom the information was intended, either directly or indirectly.

(Citation, punctuation and emphasis omitted.) Badische Corp. v.

Caylor, 257 Ga. 131, 132-133 (356 SE2d 198) (1987). Liability for a

negligent representation attaches when a defendant makes a false

representation upon which the plaintiff relies. See, e.g., Robert, 250

Ga. at 681-682 (“If it can be shown that the representation was made

for the purpose of inducing third parties to rely and act upon the

reliance, then liability to the third party [for negligent

misrepresentation] can attach.”); Ali v. Fleet Finance, 232 Ga. App.

13, 14 (500 SE2d 914) (1998) (“[B]ecause [the defendant] did not

Torts for guidance in defining the tort of negligent misrepresentation under Georgia law, § 552 is not a statute or other authority binding on Georgia’s courts, and the Restatement should be considered as a whole for what it is — a learned treatise. InComm’s efforts to have us parse § 552 and, in particular, to read it in isolation from the comments and illustrations that accompany it, are misplaced.

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