Kang v. PayPal Holdings, Inc

CourtDistrict Court, N.D. California
DecidedAugust 8, 2022
Docket3:21-cv-06468
StatusUnknown

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

Bluebook
Kang v. PayPal Holdings, Inc, (N.D. Cal. 2022).

Opinion

1 2 3 4 5 IN THE UNITED STATES DISTRICT COURT 6 FOR THE NORTHERN DISTRICT OF CALIFORNIA 7 8 HUEI-TING KANG, et al., Case No. 21-cv-06468-CRB

9 Plaintiffs,

ORDER GRANTING MOTION TO 10 v. DISMISS

11 PAYPAL HOLDINGS, INC, et al., 12 Defendants.

13 Plaintiffs Huei-Ting Kang and Arthur Flores are suing PayPal Holdings, Inc. and 14 four officers and employees (collectively, PayPal) for securities fraud under §§ 10(b) and 15 20(a) of the Securities Exchange Act of 1934 and SEC Rule 10b-5. Seeking to represent a 16 class of purchasers of PayPal common stock between April 27, 2016 and July 28, 2021 17 (the “Class Period”), Plaintiffs allege that PayPal made false or misleading statements 18 pertaining to (1) its compliance with regulatory obligations as to its PayPal Credit product; 19 (2) its compliance with regulations on debit card interchange fees; and (3) its response to 20 letters about conduct by PayPal Credit merchants. PayPal moves to dismiss for failure to 21 state a claim. The Court GRANTS the motion with leave to amend. 22 I. BACKGROUND 23 A. Parties 24 Plaintiffs Kang and Flores allege that they purchased PayPal common stock at 25 artificially inflated prices during the Class Period and suffered damage. Am. Compl. ¶ 27; 26 Declarations (dkts. 17-5, 21-3). 27 Defendant PayPal is a Delaware financial technology (“fintech”) corporation based 1 Am. Compl. (dkt. 49) ¶¶ 2, 28, 34. 2 Plaintiffs also bring their claims against four individual defendants. Daniel 3 Schulman was PayPal’s President, CEO and a member of the Company’s Board of 4 Directors. Id. ¶ 29. John Rainey cycled through the following three offices at PayPal: 5 Senior Vice President, Chief Financial Officer; Executive Vice President, Chief Financial 6 Officer; and Chief Financial Officer and Executive Vice President, Global Customer 7 Operations. Id. ¶ 30. Doug Bland was initially Vice President and General Manager of 8 PayPal Credit, Business Financing Solutions and later Senior Vice President and General 9 Manager of Global Credit. Id. ¶ 31. Joseph Gallo served in senior communications roles 10 at PayPal before becoming Director of Communications. Id. ¶ 32. 11 B. Alleged Wrongdoing 12 Most of Plaintiffs’ allegations concern misrepresentations about two underlying 13 issues: (1) PayPal’s compliance with regulatory obligations as to PayPal Credit; and (2) 14 PayPal’s compliance with Regulation II, which caps debit card interchange fees. Am. 15 Compl. ¶ 35. The Court first summarizes the allegations of underlying noncompliance 16 before describing the statements. 17 1. PayPal Credit 18 PayPal Credit is a revolving credit line issued by Synchrony Bank that allows 19 customers to pay for purchases with their PayPal Credit account on merchant websites. Id. 20 ¶¶ 3, 35. One of PayPal Credit’s promotional finance offerings is a “deferred interest” 21 arrangement on purchases of $99 or more, where no interest is charged if the balance is 22 paid within six months of the purchase date, but interest is charged from the date of 23 purchase if the customer does not pay the balance in full within six months. Id. ¶ 35. 24 Plaintiffs allege that, with respect to its merchants’ statements regarding PayPal Credit, 25 PayPal violated its legal duties stemming from a CFPB Consent Order. 26 a. The Consent Order 27 On May 19, 2015, the Consumer Finance Protection Bureau (CFPB) filed a 1 customers about deferred interest, enrolled customers in PayPal Credit without their 2 consent, engaged in illegal billing practices, and mishandled customer disputes for a litany 3 of violations of the Consumer Financial Protection Act (CFPA). Id. ¶ 38; see RJN Ex 9 4 (dkt. 71-9); CFPB v. PayPal, Inc. and Bill Me Later, Inc., No. 1:15-cv-01426 (D. Md. May 5 19, 2015), ECF No. 1. The Consent Order (“Order”) was entered in the following day. 6 See RJN Ex 10 (dkt. 71-10). It forbade PayPal from enrolling customers in PayPal Credit 7 without affirmative consent after a clear and prominent disclosure. RJN Ex 10 ¶ 17. It 8 also enjoined PayPal from misrepresenting the terms and conditions of any promotion and 9 required them to ensure that consumers receive the benefit of promotions exactly as 10 advertised. See Am. Compl. ¶¶ 7, 11, 70. Specifically, the Order provided:

11 19. In connection with offering, marketing, or providing PayPal Credit, Defendants, their officers, agents, servants, 12 contractors, and employees, and all other persons in active concert or participation with them who have actual notice of 13 this Order, whether acting directly or indirectly, are enjoined and restrained from misrepresenting any material aspect of 14 PayPal Credit, including:

15 A. Any benefits that a consumer will receive from using PayPal Credit and 16 B. The terms and conditions of any promotional offer 17 associated with PayPal Credit, such as deferred interest or money-back offers. 18 20. With respect to merchants that make promotional offers to 19 consumers who use PayPal Credit, Defendants must ensure that consumers receive the benefit of the promotional offer by 20 honoring the offer made through the merchant or providing other appropriate remediation such that the consumer receives 21 at least the benefit of the promotional offer as represented by the merchant. 22 RJN Ex 10 ¶¶ 19-20; Am. Compl. ¶ 42. The Order also required PayPal and its Board of 23 Directors to institute a comprehensive plan to ensure compliance and to report to the CFPB 24 that such compliance had been achieved. Am. Compl. ¶ 40; RJN Ex. 10 ¶¶ 24-25. 25 b. Deceptive Marketing 26 Plaintiffs allege that PayPal was not complying with its legal obligations under the 27 Order because it “knowingly enabled for-profit and largely unaccredited institutions to 1 deceptively market PayPal Credit’s terms to students for educational programs.” Am. 2 Compl. ¶ 54. Plaintiffs’ allegations are based on the claims of several confidential 3 witnesses, a 2020 report and letter by a nonprofit organization, and the later announcement 4 of an investigation into PayPal Credit by the CFPB. See id. ¶¶ 55–61. 5 Citing confidential witnesses at PayPal, Plaintiffs allege the following facts relating 6 to its internal policies concerning PayPal Credit and its merchants. A Director in Product 7 Marketing and Management stated that it was a “mutual understanding” between both 8 PayPal and merchant that both “were responsible for adhering to the language in the 2015 9 Consent Order,” and that PayPal’s “internal policy required it to remove merchants that did 10 not comply.” Id. ¶ 56. A Regulatory Compliance Lead Tester at PayPal Credit stated that 11 all merchants “had to submit an application to the Company to be able to offer PayPal 12 Credit, meet PayPal Credit’s specific criteria[,] and that merchants [could not] randomly 13 publish links directing consumers to PayPal’s products without PayPal’s knowledge.” Id. 14 ¶ 55. According to a Senior Manager of Customer Experiences and Platform, PayPal 15 received merchant-specific data about when consumers used PayPal Credit to pay for 16 merchants’ services. Id. ¶ 59. A Mid-Market Account Manager explained that “merchants 17 who offered PayPal Credit were required to provide to the Company business licenses, 18 bank statements and listed and verified business addresses.” Id. ¶ 57. A leader of the 19 product marketing group focused on merchant business stated that a group of employees 20 from compliance and legal “conducted ‘Know Your Customer’ checks on individual 21 merchants.” Id. ¶ 58. Another employee explained that a PayPal administrative tool 22 provided detailed information about merchants, classifying them by size and category, and 23 including transactional data between merchants and their customers. Id. ¶ 60.

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Kang v. PayPal Holdings, Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kang-v-paypal-holdings-inc-cand-2022.