GWINNETT COUNTY v. NETFLIX, INC.

CourtCourt of Appeals of Georgia
DecidedMarch 8, 2023
DocketA22A1172
StatusPublished

This text of GWINNETT COUNTY v. NETFLIX, INC. (GWINNETT COUNTY v. NETFLIX, INC.) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
GWINNETT COUNTY v. NETFLIX, INC., (Ga. Ct. App. 2023).

Opinion

FIFTH DIVISION MCFADDEN, P. J., GOBEIL and LAND, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

March 8, 2023

In the Court of Appeals of Georgia A22A1172. GWINNETT COUNTY et al. v. NETFLIX, INC. et al.

GOBEIL, Judge.

Gwinnett County, City of Brookhaven, and the Unified Government of

Athens-Clarke County (collectively referred to as the “Appellants”) filed a putative

class action, seeking declaratory and other relief against several streaming service

providers: Netflix, Inc.; Hulu, LLC; Disney DTC, LLC; DIRECTV, LLC; DISH

Network Corp.; and DISH Network L.L.C. (collectively referred to as the

“Defendants”). In their petition, the Appellants alleged that the Defendants violated

Georgia’s Consumer Choice for Television Act (the “TV Act” or the “Act”), OCGA

36-76-1 et seq., by providing streaming video services to Georgia customers without

obtaining franchises and paying franchise fees to local governments as required by the Act. The trial court granted the Defendants’ motions to dismiss, and the

Appellants filed the instant appeal. For the reasons explained below, we affirm.

The TV Act

In 2007, the General Assembly passed the TV Act, which creates a framework

for cable operators and video service providers to obtain state franchises from the

Secretary of State or to negotiate directly with municipal or county franchising

authorities for service areas in which the providers deliver “cable service” or “video

service.” OCGA § 36-76-3 (a), (b). “Video service” is defined as “the provision of

video programming through wireline facilities located at least in part in the public

rights of way without regard to delivery technology, including Internet protocol

technology. . . .” OCGA § 36-76-2 (16).1 Excepted from this definition is “video

programming provided as part of and via a service that enables users to access

content, information, e-mail, or other services offered over the public Internet,”

(referred to in this opinion as “the public Internet exception”). Id.

For purposes of the TV Act:

1 In 2022, the General Assembly amended the definitions of “cable service” and “video service” contained in the TV Act. See Ga. L. 2022, p. 807 § 1A. For purposes of this opinion, all mentions of OCGA § 36-76-2 refer to the 2007 version of the statute, unless otherwise noted.

2 “Franchise” means an initial authorization or renewal of an authorization issued by a franchise authority, regardless of whether the authorization is designated as a franchise, permit, license, resolution, contract, ordinance, certificate, agreement, or otherwise, that authorizes the construction or operation of a cable service provider or video service provider’s network in the public rights of way.

OCGA § 36-76-2 (6). Once a franchise application is submitted to and approved by

the Secretary of State, an affected municipal or county governing authority must

permit a franchise holder the “authority to construct, maintain, and operate facilities

along, across, or on the public right of way in the delivery of cable or video

service[.]” OCGA § 36-76-4 (d) (2). In exchange, franchise holders must pay fees

directly to local governing authorities in the holder’s service area. OCGA § 36-76-6

(b). Such fees are calculated as a percentage of the franchise holder’s gross revenues

derived from its provision of cable or video services to subscribers located within the

relevant service area. OCGA § 36-76-6 (a) (1).

Under the TV Act, local governing authorities are permitted to conduct, no

more than once annually, audits of “the business records of the state franchise holder

to the extent necessary to ensure payment in accordance with this Code section.”

OCGA § 36-76-6 (c). If the audit reveals a discrepancy in the amount of franchise

3 fees owed, “an action may be brought in a court of competent jurisdiction by an

affected local governing authority seeking to recover an additional amount alleged

to be due[.]” Id.

Procedural Background

In November 2020, the Appellants filed a petition in the Superior Court of

Gwinnett County seeking class certification on behalf of themselves and other

similarly situated local governments, requesting declaratory and other relief against

the Defendants, and asserting that the Defendants are providing “video service”

without complying with the TV Act’s requirements. Specifically, the Appellants

alleged that the Defendants violated the TV Act by failing to seek franchise

authorization (OCGA § 36-76-3 (a) (1)), give notice of their intent to provide service

within the Appellants’ geographic boundaries (OCGA § 36-76-4 (c)), or pay franchise

fees as required under the Act (OCGA § 36-76-6). The Appellants also claimed the

Defendants’ failure to obtain franchises and pay associated fees violated various local

ordinances. As relevant here, the Appellants asked the trial court for (1) a declaration

that the Defendants provide “video service” within the meaning of the TV Act, they

have failed to comply with the Act, and they owe franchise fees dating back to July

1, 2007; (2) an accounting of all monies, including interest and penalties, the

4 Defendants owe the Appellants and all putative class members; and (3) an injunction

restraining the Defendants from engaging in business within the Appellants’ and class

members’ respective geographic boundaries and deriving gross revenues therefrom

without paying the required franchise fees. And finally, (4) the Appellants raised a

claim for unjust enrichment, alleging that the Defendants have

received the benefit of doing business in [the Appellants’] and other class members’ jurisdictions without complying with [their] statutory obligations, been aware that [they were] doing business without complying with [their] statutory obligations, and accepted and retained this benefit under circumstances that are inequitable or unjust, i.e., by depriving [the Appellants] and other class members of monies and other things due under the statutes, codes, and ordinances that [the] Defendants refuse to honor.

DIRECTV removed the case to federal court in January 2021, and, in August

2021, the federal court remanded the case to the trial court under the doctrine of

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GWINNETT COUNTY v. NETFLIX, INC., Counsel Stack Legal Research, https://law.counselstack.com/opinion/gwinnett-county-v-netflix-inc-gactapp-2023.