Greater Guide, Inc. d/b/a American Service Pets v. SAPS LLC et al.

CourtDistrict Court, E.D. Louisiana
DecidedOctober 31, 2025
Docket2:25-cv-00428
StatusUnknown

This text of Greater Guide, Inc. d/b/a American Service Pets v. SAPS LLC et al. (Greater Guide, Inc. d/b/a American Service Pets v. SAPS LLC et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Greater Guide, Inc. d/b/a American Service Pets v. SAPS LLC et al., (E.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA GREATER GUIDE, INC. D/B/A CIVIL ACTION AMERICAN SERVICE PETS

VERSUS NO. 25-428 SAPS LLC ET AL. SECTION: “J”(5)

ORDER AND REASONS Before the Court is a Motion to Dismiss First Amended Complaint for Damages and Injunctive Relief (Rec. Doc. 48) filed by Defendants SAPS LLC; Prevent ESA Fraud, Inc.; Prevent ESA Fraud (“PEF”); and Dominick Latino, III (hereinafter

collectively “Defendants”). Plaintiff Greater Guide Inc. d/b/a American Service Pets (“ASP”) filed an opposition (Rec. Doc. 64), to which Defendants replied (Rec. Doc. 74). Having considered the motions and legal memoranda, the record, and the applicable law, the Court finds that the motion should be GRANTED. FACTS AND PROCEDURAL BACKGROUND At its most basic level, this litigation arises out of business competition between Plaintiff and Defendants in the emotional support animal industry. More

specifically, Defendants mailed complaints to state regulatory agencies concerning independent mental health professionals who contracted with Plaintiff, and these complaints led the mental health professionals to terminate their contracts with Plaintiff. 1 Both Defendant SAPS and Plaintiff are companies that sell Emotional Support Animal (“ESA”) certification letters by connecting consumers to contracted mental health care providers through their websites, and both companies appear to have

nearly identical business models. Plaintiff operates a website, www.americanservicepets.com, through which individuals can apply for ESA certification. The individual fills out an online questionnaire, complete with a request for an evaluation from a contracted medical provider. Within this application, users must accept the terms and conditions of Plaintiff’s website, which include an agreement not to submit any false information.

Defendant Dominick Latino, III serves as president and owner of Prevent ESA Fraud, which holds itself out as a nonprofit organization that does what its name suggests. He also serves as counsel for SAPS LLC, which owns the US Service Animals website, a direct competitor of Plaintiff. According to a quote from Mr. Latino on the Prevent ESA Fraud website, the goal of Prevent ESA Fraud is, in part, “to stop invalid ESA letters from harming people and businesses.” The website also includes a quote from Matt Handal, who is listed as the founder of US Service Animals, which

is the website owned by Defendant SAPS. Plaintiff asserts that Defendants are connected entities, with Mr. Latino serving as legal counsel for SAPS and as president-owner of PEF. As a basis for its claims, Plaintiff alleges that Defendants conspired to harm Plaintiff’s business. Specifically, Plaintiff claims Defendants used an investigator to submit at least thirty-one fictional online applications on Plaintiff’s website which served as 2 Defendants’ basis for state regulatory complaints. These complaints led to various mental health care providers terminating their agreements with Plaintiff. Further, Plaintiff alleges that Defendants lodged these complaints with regulatory agencies in

retaliation after Defendants’ lawsuit in Louisiana state court was dismissed. Plaintiff insists that Defendants’ actions (1) amount to civil conspiracy and fraud, (2) violated its website’s terms and conditions, and (3) were designed to harm business competition. Plaintiff raises actions that include violations of the Sherman Antitrust Act, the Computer Fraud and Abuse Act, and civil Racketeer Influenced and Corrupt Organizations (“RICO”) Act, in addition to a number of state-law claims.

The Court has original jurisdiction over Plaintiff’s claims under the Computer Fraud and Abuse Act, the Sherman Act, and Plaintiff’s civil RICO claims pursuant to 28 U.S.C. § 1331, and supplemental jurisdiction under 28 U.S.C. § 1367 over the remaining state-law claims. Defendants now move to dismiss the Complaint under Federal Rule of Civil Procedure 12(b)(6), averring that the Noerr-Pennington doctrine bars Plaintiff’s claims generally and, in the alternative, contending that the individual claims lack merit. Plaintiff opposes.

LEGAL STANDARD To survive a Rule 12(b)(6) motion to dismiss, the plaintiff must plead sufficient facts to “state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). A claim is facially plausible when the plaintiff pleads facts that allow the court to “draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. The 3 factual allegations in the complaint “must be enough to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555. “[D]etailed factual allegations” are not required, but the pleading must present “more than an unadorned, the-

defendant-unlawfully-harmed-me accusation.” Iqbal, 556 U.S. at 678. The court must accept all well-pleaded facts as true and must draw all reasonable inferences in favor of the plaintiff. Lormand v. US Unwired, Inc., 565 F.3d 228, 232 (5th Cir. 2009). However, “conclusory allegations or legal conclusions masquerading as factual conclusions will not suffice to prevent a motion to dismiss.” Beavers v. Metro. Life Ins. Co., 566 F.3d 436, 439 (5th Cir. 2009) (citation omitted).

DISCUSSION Defendants assert that the Noerr-Pennington doctrine bars all of Plaintiff’s claims in the First Amended Complaint, and alternatively, that Plaintiff’s claims fail as a matter of law. Because the Court is not persuaded that Defendants’ affirmative defense bars all of Plaintiff’s federal claims, the Court will address each of these claims separately. In its opposition to Defendants’ Motion to Dismiss, Plaintiff correctly notes that

Defendants’ invocation of the Noerr-Pennington doctrine constitutes an affirmative defense; however, Plaintiff misstates the legal consequences of this fact. Plaintiff relies on the Fifth Circuit’s opinion in Bayou Fleet, Inc. v. Alexander, 234 F.3d 852 (5th Cir. 2000) to argue that Noerr-Pennington is “not a basis for dismissal at the pleading stage” (Rec. Doc. 64, at 5), but Bayou Fleet does not support this conclusion. A primary issue in Bayou Fleet was whether the defendants had waived their 4 right to assert immunity under the Noerr-Pennington doctrine because they had failed to raise the defense timely. Bayou Fleet, 234 F.3d at 860. The district court had erroneously held that the Noerr-Pennington doctrine was not an affirmative defense,

id., but even despite this error, the Fifth Circuit affirmed the district court’s decision to dismiss the plaintiff’s claims, holding that defendants’ conduct was immune under Noerr-Pennington, id. at 862–63. Moreover, the Fifth Circuit has consistently held that “when a successful affirmative defense appears on the face of the pleadings, dismissal under Rule 12(b)(6) may be appropriate.” Kansa Reins. Co. v. Cong. Mortg. Corp. of Tex., 20 F.3d

1362, 1366 (5th Cir. 1994) (citing Clark v. Amoco Prod. Co., 794 F.2d 967, 970 (5th Cir.

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Greater Guide, Inc. d/b/a American Service Pets v. SAPS LLC et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/greater-guide-inc-dba-american-service-pets-v-saps-llc-et-al-laed-2025.