Golubiewski v. Activehours, Inc.

CourtDistrict Court, M.D. Pennsylvania
DecidedAugust 28, 2025
Docket3:22-cv-02078
StatusUnknown

This text of Golubiewski v. Activehours, Inc. (Golubiewski v. Activehours, Inc.) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Golubiewski v. Activehours, Inc., (M.D. Pa. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA DAN GOLUBIEWSKT et al., Plaintiffs, CIVIL ACTION NO. 3:22-CV-02078 . (MEHALCHICK, J.) ACTIVEHOURS, INC., et al., Defendants. MEMORANDUM Plaintiffs Dan Golubiewski and Steven Checchia (collectively, “Plaintiffs”) individually and on behalf of a putative class, initiated this action against Defendant Activehours, Inc. d/b/a/ EarnIn (“EarnIn”) by filing a complaint asserting violations of the Unfair Trade Practices and Consumer Protection Law (“UTPCPL”), the Loan Interest and Protection Law (“LIPL”), the Consumer Discount Company Act (“CDCA”), and the Truth-in-Lending Act (“TILA”). (Doc. 1; Doc. 18). Plaintiffs filed the operative second amended complaint on October 7, 2024. (Doc. 48). Presently before the Court is EarnIn’s motion to dismiss Plaintiffs’ second amended complaint. (Doc. 49). For the foregoing reasons, EarnIn’s motion to dismiss is DENIED. (Doc. 49). I. BACKGROUND AND PROCEDURAL HISTORY The following background is taken from the second amended complaint. (Doc. 48). EarnIn is an app that enables users to get cash advances of up to $100 per use from their own paychecks. (Doc. 48, ff 3, 19-20). “The advertised and intended purpose of EarnIn’s cash advance product is to provide an instant source of money directly from a cell phone, that consumers can use to pay time-sensitive obligations or cover surprise expenses.” (Doc. 48, §] 21). EarnIn is not a bank and is not a licensed lender under any Pennsylvania statute. (Doc. 48, 4 17). However:

To ensure it gets paid, EarnIn requires its users to: (i) have an employer that pays them regularly; (ii) link the bank account to which paychecks are deposited to EarnIn’s app; and (iii) authorize EarnIn to automatically debit linked accounts on payday in an amount that is equal to the advance a user receives and the tips and fees a user agrees to repay.

(Doc. 48, ¶ 42).

On the EarnIn app, users can either receive a “standard” or “expedited” advance. (Doc. 18, ¶ 32). The standard advance appears in the user’s bank account within a few days, while the expedited advance arrives within minutes. (Doc. 18, ¶ 33). To obtain an “expedited advance,” users must pay a “lightning speed fee,” which ranges from $1.99 to $3.99. (Doc. 18, ¶ 34). Before users can obtain a standard or an expedited advance, EarnIn also requests payment of a “tip.” (Doc. 48, ¶¶ 29-33). In collecting these tips, EarnIn uses “deceptive tactic[s]” to fool users into thinking the tip is mandatory. (Doc. 48, ¶¶ 29-33). For example, none of the default options include not paying a tip, and if a consumer does not wish to pay a tip, the consumer must proactively change the default amount to $0.00. (Doc. 48, ¶¶ 35-37). Then “[w]hen a consumer changes the default tip to $0, they are taken back to the original tip screen, and are asked to confirm that they wish to forgo paying a tip and forgo helping to ‘support EarnIn.’” (Doc. 48, ¶ 37). These tips and are a major source of revenue for EarnIn. (Doc. 48, ¶ 31). Furthermore, “[t]he average fees and tips that EarnIn collects on its advances yield an APR-equivalent of 284%.” (Doc. 48, ¶ 39). These charges are not disclosed per the requirements of the relevant lending statutes. (Doc. 48, ¶¶ 77-79). Plaintiffs’ second amended complaint contains two counts; one for violation of 41 P.S. § 502, Pennsylvania’s Usury Statutes and the other for violation of 15 U.S.C. §§ 1601, et seq., the Truth-In-Lending Act. (Doc. 48, at 19-22). On October 21, 2024, EarnIn filed a motion to dismiss the second amended complaint and a brief in support its motion. (Doc. 49; Doc. 50). On November 4, 2024, EarnIn filed a brief in opposition to the motion. (Doc. 53). On November 18, 2024, EarnIn filed a reply brief.' (Doc. 54). Accordingly, the motion to dismiss is ripe and ready for disposition. Il. MOTION TO DISMIss STANDARD Rule 12(b)(6) of the Federal Rules of Civil Procedure authorizes a defendant to move to dismiss for “failure to state a claim upon which relief can be granted.” Fed. R. Civ. P. 12(b)(6). To assess the sufficiency of a complaint on a Rule 12(b)(6) motion, a court must first take note of the elements a plaintiff must plead to state a claim, then identify mere conclusions that are not entitled to the assumption of truth, and finally determine whether the complaint’s factual allegations, taken as true, could plausibly satisfy the elements of the legal claim. Burtch v. Milberg Factors, Inc., 662 F.3d 212, 221 (3d Cir. 2011). In deciding a Rule 12(b)(6) motion, the court may consider the facts alleged on the face of the complaint, as well as “documents incorporated into the complaint by reference, and matters of which a court may take judicial notice.” Tellabs, Inc. v. Makor Issues & Rights, Ltd., 551 U.S. 308, 322 (2007). After recognizing the required elements that make up the legal claim, a court should “begin by identifying pleadings that, because they are no more than conclusions, are not entitled to the assumption of truth.” Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). The plaintiff must provide some factual ground for relief, which “requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007). “[T]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Jgbal, 556 U.S. at 678. Thus, courts “need not credit a complaint’s ‘bald assertions’ or ‘legal conclusions’. . . ” Morse v.

"On May 1, 2025 and August 11, 2025, EarnIn also filed notices of supplemental authority. (Doc. 55; Doc. 56).

Lower Merion Sch. Dist., 132 F.3d 902, 906 (3d Cir. 1997) (quoting In re Burlington Coat Factory Sec. Litig., 114 F.3d 1410, 1429-30 (3d Cir. 1997)). Nor need a court assume that a plaintiff can prove facts that the plaintiff has not alleged. Associated Gen. Contractors of Cal. v. Cal. State Council of Carpenters, 459 U.S. 519, 526 (1983). A court must then determine whether the well-pleaded factual allegations give rise to a plausible claim for relief. “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Palakovic v. Wetzel, 854 F.3d 209, 219-20 (3d Cir. 2017) (quoting Iqbal, 556 U.S. at 678) (internal quotation marks omitted); see also Sheridan v. NGK Metals Corp., 609 F.3d 239, 262 n.27 (3d Cir. 2010). The court must accept as true all allegations in the complaint, and any reasonable inferences that can be drawn therefrom are to be construed in the light most favorable to the plaintiff. Jordan v. Fox, Rothschild, O'Brien & Frankel, 20 F.3d 1250, 1261 (3d Cir. 1994).

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Bluebook (online)
Golubiewski v. Activehours, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/golubiewski-v-activehours-inc-pamd-2025.