Oto Analytics, LLC v. Benworth Capital Partners PR LLC

CourtDistrict Court, D. Puerto Rico
DecidedApril 2, 2025
Docket3:23-cv-01034
StatusUnknown

This text of Oto Analytics, LLC v. Benworth Capital Partners PR LLC (Oto Analytics, LLC v. Benworth Capital Partners PR LLC) is published on Counsel Stack Legal Research, covering District Court, D. Puerto Rico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Oto Analytics, LLC v. Benworth Capital Partners PR LLC, (prd 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

Oto Analytics, LLC

Plaintiff, Civil No. 23-01034(GMM)cons.

v. Civil No. 24-01313 (GMM)

Benworth Capital Partners PR, LLC; Benworth Capital Partners, LLC; Bernardo Navarro and Claudia Navarro,

Defendants.

Federal Reserve Bank of San Francisco,

Plaintiff-Intervenor,

v.

Oto Analytics, LLC; Benworth Capital Partners PR, LLC; Benworth Capital Partners, LLC; Bernardo Navarro and Claudia Navarro,

Defendants in Intervention.

Consolidated Plaintiff,

Benworth Capital Partners PR, LLC; Benworth Capital Partners, LLC; Bernardo Navarro and Claudia Navarro,

Consolidated Defendants. P age -2-

OPINION AND ORDER Before the Court is Defendant Benworth Capital Partners, LLC’s (“Benworth FL”) Defendant Benworth Capital Partners, LLC’s Motion to Dismiss the Federal Reserve’s Complaint and Complaint in Intervention (“Motion to Dismiss”) (Docket No. 169), joined by Defendants Benworth Capital Partners PR, LLC; Bernardo Navarro and Claudia Navarro at Docket No. 170. Therein, Benworth FL seeks to dismiss in its entirety Plaintiff Federal Reserve Bank of San Francisco’s (“Reserve Bank”) Complaint at Docket No. 1 in Civil No. 24-01313 pursuant to Fed. R. Civ. P. 12(b)(6). For the

following reasons the Court DENIES the Reserve Bank’s Motion to Dismiss. I. RELEVANT FACTUAL AND PROCEDURAL BACKGROUND This is a civil action against defendants Benworth Capital Partners PR LLC, a Puerto Rico limited liability company (“Benworth PR”), Benworth Capital Partners LLC, a Florida limited liability company (“Benworth FL” and, together with Benworth PR, “Benworth”), Bernardo Navarro (“Mr. Navarro”), and Claudia Navarro (“Ms. Navarro” and, together with Mr. Navarro, the “Navarros” and, collectively with Benworth, the “Defendants”) for, among other relief, damages for breach of contract, collection of money,

conversion, and rescission of fraudulent transfers of various P age -3- assets from Benworth FL to Benworth PR and the Navarros. Before the Court is Defendant Benworth Capital Partners, LLC’s Motion to Dismiss the Federal Reserve’s Complaint and Complaint in Intervention (“Motion to Dismiss”). (Docket No. 169). The following facts, drawn from the Complaint, are accepted as true for purposes of the Motion to Dismiss. The Reserve Bank of San Francisco (“Reserve Bank” or “Plaintiff”) is part of the U.S. central bank system known as the Federal Reserve System. See (Docket No. 1 at ¶5). Beginning in May 2020, the Reserve Bank provided approximately $4.3 billion in credit advances to Benworth FL under the Paycheck Protection Program (“PPP”) which provided

small businesses with funds to pay certain business costs during the COVID-19 pandemic. See (id. at ¶2). The Reserve Bank holds a properly perfected, valid first-priority security interest in certain PPP loans pledged as collateral (“PPP Collateral”) to secure those advances, as well as all “proceeds and products” thereof and other collateral. See (id.). The agreements that provided for such credit advances were the Paycheck Protection Program Liquidity Facility Letters of Agreement dated May 4, 2020, January 14, 2021, and January 30, 2023 (collectively, the “Letters of Agreement”). See (id. at ¶¶ 19, 20). The Letters of Agreement incorporate the Reserve Bank’s

Operating Circular No. 10 (the “Operating Circular” and, together P age -4- with the Letters of Agreement, the “Program Agreements”), which together set forth the relevant terms and conditions that govern Benworth FL’s relationship with the Reserve Bank. See (id. at ¶20). Under the Program Agreements, Benworth FL was authorized to request credit advances (“Advances”) from the Reserve Bank. Those Advances were secured by PPP loans pledged as collateral to the Reserve Bank (the “Pledged PPP Loans”) and set to mature on the maturity dates of the Pledged PPP Loans, subject to the terms of the Program Agreements. See (id. at ¶ 21). The maturity date of all Advances is accelerated upon the occurrence of an event of default, and all Advances become due and owing. See (id. at ¶ 25).

Additionally, if Benworth FL “(i) has breached any of the representations, warranties, or covenants made under the [Program Agreements] or (ii) has engaged in any fraud or misrepresentation in connection with any Advance or any request to obtain an Advance under the [Paycheck Protection Program Liquidity Facility (“PPPLF”),” all Advances made to Benworth FL immediately become recourse obligations, regardless of the value of the PPP Collateral. See (id. at ¶ 27). In addition, failure by a PPPLF borrower to meet any of the requirements of the Program Agreements, including if the PPP Collateral fails to satisfy the requirements for guaranty purchase of PPP loans by the Small Business

Administration (“SBA”), may, at the sole discretion of the Reserve P age -5- Bank, void the non-recourse provisions of the Program Agreements and any related provisions. The Reserve Bank’s rights therefore become full recourse with respect to the portion of any Advance equal to the amount of the valuation of the non-conforming PPP Collateral. See (id. at ¶ 28). Beginning in February 2021, Benworth FL contracted with Oto Analytics, LLC (“Womply”) to use its services to collect loan files from borrowers to originate PPP loans. See (id. at ¶¶ 39, 42). In August 2021, Womply commenced JAMS arbitration against Benworth FL in San Francisco, California (the “Arbitration”), seeking payment of unpaid fees that Benworth FL allegedly owes Womply under the

parties’ agreements. See (id. at ¶ 40). On December 21, 2023, the arbitrator overseeing the Arbitration issued an interim award (the “Interim Award”) that, if finalized and not set aside, would require Benworth FL to pay Womply over $86 million on account of unpaid fees, plus contractual interest and Womply’s costs of collection of the debt. See (id. at ¶ 41). On June 11, 2024, the arbitrator issued a final award requiring Benworth FL to pay Womply nearly $118 million in unpaid fees, interest, and costs. See (id.). Pursuant to the Final Award, Womply is required to promptly transmit numerous loan files related to Benworth FL’s PPP loan portfolio that it had failed to return, and which are necessary P age -6- for the SBA to provide payment to Benworth FL for PPP loans that are not eligible for forgiveness. See (id. at ¶¶ 42-44). Benworth FL informed the Reserve Bank that the loan files were not in its possession and that they were necessary to process guaranty purchase applications that were pending or were on appeal with the SBA. See (id. at ¶ 34). If an application for guaranteed purchase of a PPP loan was not approved by the SBA, Benworth FL would not receive any payment on the loan thereby likely affecting its ability to repay the Reserve Bank. See (id. at ¶ 43). Based on the information acquired by Womply during discovery in the arbitration proceedings, it filed an action in this Court

to, inter alia, unwind an alleged fraudulent transfer (the “Fraudulent Transfers”) of approximately $171 million from Benworth FL to Benworth PR, both of which the Navarros own and control. See (id. at ¶ 45). Plaintiff alleges the funds at issue in the Fraudulent Transfers include PPP Collateral over which the Reserve Bank hold a first-priority lean. As a result of the Fraudulent Transfers, Benworth FL did not have access to sufficient funds to service the Pledged PPP Loans and pay its debt to the Reserve Bank. See (id. at ¶ 63). On or about December 27, 2023, Benworth FL informed the Reserve Bank of certain developments impacting its financial

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Oto Analytics, LLC v. Benworth Capital Partners PR LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oto-analytics-llc-v-benworth-capital-partners-pr-llc-prd-2025.