Spacil v. Home Away, Inc

CourtDistrict Court, D. Nevada
DecidedJanuary 13, 2020
Docket2:19-cv-00983
StatusUnknown

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

Bluebook
Spacil v. Home Away, Inc, (D. Nev. 2020).

Opinion

1 UNITED STATES DISTRICT COURT

2 DISTRICT OF NEVADA

3 * * *

4 LINDA SPACIL, and all similarly situated Case No. 2:19-CV-00983-GMN-EJY individuals, 5 Plaintiff, ORDER 6 v. 7 HOME AWAY, INC., 8 Defendant. 9 10 Before the Court is Defendant HomeAway.com, Inc.’s (“HomeAway” or “Defendant”) 11 Motion to Compel Arbitration (ECF No. 7). The Court has considered Defendant’s Motion, Plaintiff 12 Linda Spacil’s (“Spacil” or “Plaintiff”) Response (ECF No. 17), and Defendant’s Reply (ECF No. 13 18), and finds the following. 14 BACKGROUND 15 It is uncontested that HomeAway operates an online platform allowing property owners and 16 managers to list properties for relatively short-term rent by individuals and families traveling to the 17 location of the property rented.1 VRBO.com is one of the services offered by HomeAway. 18 According to Plaintiff’s Complaint, as supported by the Motion to Compel, on April 3, 2019, 19 Plaintiff submitted a request to book a property in Switzerland using VRBO, which she cancelled 20 after receiving a discounted offer from the alleged property owner. Plaintiff apparently then sent 21 money directly to the purported owner of the Switzerland property. However, when Plaintiff became 22 concerned that she was the victim of a scam, she contacted HomeAway. HomeAway investigated 23 Plaintiff’s concern but, because Plaintiff chose to cancel her booking request made through the 24 VRBO website, and instead chose to work directly with the supposed property owner, Defendant 25 did not reimburse Plaintiff for her loss. 26

1 At no point in Plaintiff’s Response to Defendant’s Motion to Compel does Plaintiff take issue with any fact 27 pertaining to HomeAway’s business or HomeAway’s representations regarding Spacil’s request to book a property in 1 In support of its Motion to Compel, HomeAway offers the declaration of Lee Huberman 2 (“Huberman”), employed by HomeAway since at least May 2, 2016, who reviewed and is familiar 3 with HomeAway’s booking processes.2 ECF No. 7-1. Huberman attaches to his declaration 4 exemplars of the VRBO booking request screens that are “materially similar” to the booking request 5 screens Plaintiff “would have experienced on or about April 3, 2019.” Declaration of Lee Huberman 6 (“Huberman Dec.”) ¶ 7; Exs. A through C. Huberman also explains the booking process in detailed. 7 Id. ¶¶ 8-12. Huberman states that HomeAway does not own or operate the properties listed on its 8 website and is not a party to the agreements between those offering rentals and those accepting such 9 offers. Id. ¶ 5. 10 The booking process begins by selecting a property, identifying the dates of the proposed 11 stay, and identifying the number of guests in the booking party. Id. ¶ 9. Once that information is 12 entered by the person using the website, the user must click the “Request to Book” button to get to 13 the “Begin your booking” page. Id. and Ex. A. 14 Toward the bottom of the “Begin your booking page” (Exhibit A) is a blue button against a 15 grey background with white text that reads “Agree & continue.” Id. The following pertinent 16 language appears right above this button: “By clicking ‘Agree & continue’ you are agreeing to our 17 Terms and Conditions, Privacy Policy, and to receive booking-related texts.” Id. The letters in this 18 sentence appears in black with the exception of the words “Terms & Conditions,” and “Privacy 19 Policy” that appear in blue text. Huberman Dec. ¶ 10. The blue text operates as hyperlinks and, 20 when clicked, take the user to the full Terms & Conditions or Privacy Policy then in effect. Id. 21 Unlike the examplars about which Plaintiff complains, there is no dispute that, in April 2019, a 22 person using the VRBO website could not continue to the next step of the booking process without 23 clicking on “Agree & continue.” Huberman Dec. ¶ 13. 24 Once a user clicks on “Agree & continue,” the individual is taken to the “Review rules & 25 policies” page. Huberman Dec. ¶ 11; Exhibit B. The person must check the box stating “I have read 26 and agree to comply with all rental policies and terms,” and then must click the “Continue” button, 27 1 which is blue with white writing. Huberman Dec. 11. If a user does not check the box indicating 2 he/she has read and agrees to comply with the rental policies and terms, a red circle containing an 3 exclamation point appears next to the following (also in red): “You must review and agree to all 4 Rules and Policies to continue.” Id. Defendant points out that at the bottom of this page the words 5 “Terms and Conditions” and “Privacy Policy” appear in blue typeface and are hyperlinks. Id. These 6 words are relatively small and are easy to miss if a user does not scroll down to the bottom of the 7 page. Huberman Dec. Ex. B. 8 After the user checks the box, and clicks the “Continue” button, the user is taken to the next 9 page, which states at the top: “ Enter payment information.” Huberman Dec. ¶ 12 and Ex. C. The 10 user then enters the payment information requested and must click the “Submit Request” button to 11 complete the booking request process. Huberman Dec. ¶ 12.3 Huberman is unequivocal when he 12 states that no one seeking to request a booking through VRBO in April 2019 could have done so 13 without going through each of the steps described above. Id. ¶ 13. Importantly, neither Plaintiff’s 14 brief in opposition to the Motion to Compel nor her declaration say anything about the booking 15 request process in which Plaintiff engaged. 16 Since, November 14, 2017, the “Terms and Conditions” to which each person seeking to 17 book a property through VRBO must agree are attached to Huberman’s Declaration as Exhibit D 18 (see id. at 1 for effective date at top). Paragraph 19 on the bottom of page 15 of Exhibit D is titled 19 “Disputes; Arbitration.” The second paragraph on page 16 of Exhibit D begins with the bolded 20 words “Any and all Claims will be resolved by binding arbitration rather than in court . . ..” 21 This sentence goes on to except small claims from arbitration “if they qualify.” 22 The very next sentences state:

23 This includes any Claims you assert against us, our subsidiaries, users or any companies offering products or services through us (which are beneficiaries of the 24 arbitration agreement). This also includes any Claims that arose before you accepted the Terms, regardless of whether prior versions of the Terms required 25 arbitration. 26 27 1 Id. at 16. The term “Claims” is defined at the top of page 16 as “any disputes or claims relating in 2 any way to the Site, any dealings with out customer experience agents, any services or products 3 provided, any representation made by us, or our Privacy Policy . . ..” Id. 4 The “Disputes; Arbitration” section of the Terms and Conditions is not subject to 5 amendment, in whole or part, by HomeAway. Id. Instead, “[t]he version of this ‘Dispute; 6 Arbitration’ section in effect on the date … [the user] last accepted the Terms controls.” Id. 7 Arbitration is to be performed by the American Arbitration Association (“AAA”) or the Judicial 8 Arbitration Mediation Services, and HomeAway will reimburse an individual for filing fees and 9 arbitration fees paid to AAA if the claim asserted seeks less than $10,000. Id. Arbitration will take 10 place where the individual-user lives unless another location is mutually agreed upon. Id. The 11 AAA Arbitration Consumer Rules, together with the AAA general rules, apply to any arbitration 12 under the dispute-arbitration provision. Id. 13 Defendant seeks to enforce the arbitration agreement through its Motion to Compel. 14 Defendant argues that Plaintiff completed a request to book on VRBO that necessarily required her 15 to agree to the Terms and Conditions, which includes the arbitration agreement. Plaintiff does not 16 contest these facts.

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Spacil v. Home Away, Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/spacil-v-home-away-inc-nvd-2020.