Infinity Capital LLC v. Francis David Corp.

CourtCourt of Appeals for the Sixth Circuit
DecidedApril 14, 2021
Docket19-4004
StatusUnpublished

This text of Infinity Capital LLC v. Francis David Corp. (Infinity Capital LLC v. Francis David Corp.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Infinity Capital LLC v. Francis David Corp., (6th Cir. 2021).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 21a0190n.06

No. 19-4004

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

FILED Apr 14, 2021 INFINITY CAPITAL LLC; JOHN PAUL ) DEBORAH S. HUNT, Clerk GOLINO, ) ) Plaintiffs-Appellees, ) ON APPEAL FROM THE UNITED ) STATES DISTRICT COURT FOR v. ) THE NORTHERN DISTRICT OF ) OHIO FRANCIS DAVID CORPORATION, dba ) Electronic Merchant Systems, ) ) Defendant-Appellant. )

BEFORE: BATCHELDER, STRANCH, and MURPHY, Circuit Judges.

MURPHY, Circuit Judge. Contracts in many industries regularly grant a stream of income

to a party but make clear that the party will forfeit this income if it starts competing with the other

side. Courts have generally enforced these forfeiture clauses because they do not absolutely bar

competition and instead give the party a choice: compete (and forgo the benefits) or refrain (and

accept the benefits). See Carl Ralston Ins. Agency, Inc. v. Nationwide Mut. Ins. Co., 2007 WL

397313, at *2–3 (Ohio Ct. App. Feb. 7, 2007); Schlumberger Tech. Corp. v. Blaker, 859 F.2d 512,

516 (7th Cir. 1988). We must decide whether this case’s forfeiture clause fits the same mold.

Entities in the credit-card industry known as “independent sales organizations” recruit

retail merchants to accept credit cards. These organizations receive a portion of the fee charged

merchants for each credit-card swipe. They often use independent “agents” to sign up merchants No. 19-4004, Infinity Cap., et al. v. Francis David Corp.

and split the merchant’s fee with these agents. The part of the fee that an agent receives is known

as the agent’s “residual” income because the agent typically continues to receive this income even

after it leaves the organization. Here, Electronic Merchant Services (EMS), an independent sales

organization, signed a contract with an agent, Choice Merchant Services, to recruit merchants.

EMS later concluded that Choice had recruited merchants for Choice’s own services in violation

of a noncompete provision. A separate clause in the contract stated that Choice would forfeit its

residual income if it violated this noncompete provision, so EMS stopped paying the income. The

district court held that this forfeiture clause was an unenforceable penalty under Ohio contract law.

Given how EMS has treated the forfeiture clause in this case, we agree that Ohio courts

would not enforce it. Unlike the forfeiture clauses that courts have upheld, see Carl Ralston, 2007

WL 397313, at *3, EMS did not read the contract as offering Choice the option to either solicit

merchants (and forfeit its residual income) or avoid that competition (and receive the income).

Rather, it sued Choice for breaching the noncompete provision and collected damages for that

breach. EMS thus treated the noncompete provision as an absolute ban on competition and the

forfeiture clause as another remedy for breach. Because EMS has treated the clause as a remedy,

the clause triggers Ohio’s distinction between unenforceable penalties and enforceable liquidated

damages. And Ohio courts would view the clause as a penalty. Nevertheless, the district court

erred when it calculated Choice’s damages from its lost residual income. We thus affirm the

district court’s decision on the parties’ liabilities but reverse its damages award to Choice.

I

A

A typical electronic financial transaction involves many actors, not just the consumer that

buys a product, the merchant that sells it, and the credit-card company that facilitates the deal. The

2 No. 19-4004, Infinity Cap., et al. v. Francis David Corp.

transaction often involves an “issuing” bank (which provides a line of credit and a credit card to

the consumer) and an “acquiring” bank (which signs up the merchant to accept the card and ensures

that the merchant gets paid). See United States v. Visa U.S.A., Inc., 344 F.3d 229, 235 (2d Cir.

2003). It also involves “payment processors,” which make the physical “terminal” for card

swiping at brick-and-mortar stores or the digital “gateway” for purchases through online

merchants.

This case concerns the merchant side of credit-card transactions. To recruit merchants,

many banks rely on “independent sales organizations” (or “ISOs” in the industry’s language).

Independent sales organizations sign up merchants to accept electronic payments and offer

customer support to them. These organizations also monitor their merchants’ credit-card sales

because they bear the risk of loss for “chargebacks” in which a retail consumer refuses to pay for

a credit-card transaction (because of fraud, for example). Given the concerns with nonpayment,

independent sales organizations frequently do not permit merchants (especially riskier online

merchants) to process unlimited amounts of transactions with their services. They instead cap the

total monthly dollar volume that merchants may process. These volume caps require many

merchants to contract with additional independent sales organizations for “secondary” processing

depending on the amount of card-based business that the merchants anticipate.

Many independent sales organizations, in turn, delegate much of their work to independent

“agents” (in some respects analogous to insurance companies using independent agents to sign up

customers). Agents might have an “exclusive” contract to recruit for just one independent sales

organization or they might recruit for several different ones. These agents will, in the words of

one witness, “pound on the doors” of merchants and recruit them to use the independent sales

organization. They will also handle customer service for successfully recruited merchants, acting

3 No. 19-4004, Infinity Cap., et al. v. Francis David Corp.

as a go-between for the merchant and the organization. An agent might, for example, ask the

organization to increase a merchant’s monthly volume cap if the merchant makes such a request.

Merchants pay a fee for every retail transaction that uses an independent sales

organization’s payment processing. Independent sales organizations and their agents contract over

how to divvy up this fee. The portion of the fee that an agent receives is known as the agent’s

“residual” income because the contract often will allow an agent to receive the fee as long as the

merchant continues to use the independent sales organization. An agent’s total monthly residual

income for every merchant that the agent has recruited for an independent sales organization is

known as the agent’s “portfolio” with that organization. Agents can sell these portfolios based on

the revenue stream’s expected value.

B

EMS has been an independent sales organization for 30 years. It has over 19,000 merchant

customers (out of the millions of potential merchants). EMS uses its own sales force to recruit and

serve some merchants. To recruit many others, it relies on independent agents like the one

involved in this case: Infinity Capital. Owned by John Paul Golino, Infinity Capital does business

as Choice Merchant Services. Choice recruited merchants for EMS and was the customer-service

contact for the EMS merchants that it signed up.

In 2010, EMS entered into a contract with Choice. This agreement made Choice an

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Anderson v. City of Bessemer City
470 U.S. 564 (Supreme Court, 1985)
TMW Enterprises, Inc. v. Federal Insurance
619 F.3d 574 (Sixth Circuit, 2010)
Sanborn v. Parker
629 F.3d 554 (Sixth Circuit, 2010)
In Re: Graham Square, Inc.
126 F.3d 823 (Sixth Circuit, 1997)
Hance v. Norfolk Southern Railway Co.
571 F.3d 511 (Sixth Circuit, 2009)
Max Trucking, LLC v. Liberty Mutual Insurance Corp.
802 F.3d 793 (Sixth Circuit, 2015)
Boone Coleman Construction, Inc. v. Village of Piketon
2016 Ohio 628 (Ohio Supreme Court, 2016)
USS Great Lakes Fleet, Inc. v. Spitzer Great Lakes, Ltd.
621 N.E.2d 461 (Ohio Court of Appeals, 1993)

Cite This Page — Counsel Stack

Bluebook (online)
Infinity Capital LLC v. Francis David Corp., Counsel Stack Legal Research, https://law.counselstack.com/opinion/infinity-capital-llc-v-francis-david-corp-ca6-2021.