Willis v. Fitbit, Inc.

CourtDistrict Court, S.D. California
DecidedJanuary 27, 2020
Docket3:19-cv-01377
StatusUnknown

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

Bluebook
Willis v. Fitbit, Inc., (S.D. Cal. 2020).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 BARON WILLIS, Case No.: 19-cv-01377-DMS (WVG)

12 Plaintiff, ORDER GRANTING MOTION TO 13 v. COMPEL ARBITRATION AND STAY THE ACTION 14 FITBIT, INC., 15 Defendant. 16 17 Pending before the Court is Defendant Fitbit, Inc.’s motion to compel arbitration and 18 to dismiss or stay the action. Plaintiff Baron Willis filed an opposition to Defendant’s 19 motion, and Defendant filed a reply. For the following reasons, the Court grants 20 Defendant’s motion and stays further proceedings pending arbitration. 21 I. 22 BACKGROUND 23 In May of 2015, Plaintiff purchased his first Fitbit device, a Fitbit Flex. (Compl. ¶ 24 23). Plaintiff alleges he wore his Fitbit Flex for its intended purpose and in a manner 25 consistent with its intended use, yet “the band separated from the device, resulting in it 26 falling off his wrist, multiple times.” (Id.). Plaintiff returned his Fitbit Flex later that month 27 and replaced it with a Fitbit Charge. (Id.). Plaintiff alleges he experienced the same issue 28 with the Charge as he did with the Flex—specifically, the wristband separated from the 1 device and the device fell off his wrist. (Id. at ¶ 24). One year later, Plaintiff returned his 2 Fitbit Charge and replaced it with a Fitbit Charge HR. (Id.). Plaintiff alleges he again 3 experienced the same issue. (Id.). A few months later, Plaintiff replaced his Fitbit Charge 4 HR with a Fitbit Blaze. (Id. at ¶ 25). Plaintiff alleges the Fitbit Blaze also fell off his wrist. 5 (Id. at ¶ 26). Finally, one year later, Plaintiff returned his Fitbit Blaze and replaced it with 6 an upgraded edition of the Blaze. (Id.). Plaintiff alleges this device also fell off his wrist 7 and was eventually lost. (Id. at ¶ 27). Plaintiff alleges he “purchased and replaced his 8 Fitbit devices because of representations Defendant made about the devices being wearable 9 and capable of tracking, monitoring, and storing his personal data.” (Id. at ¶ 28). 10 According to Plaintiff, however, the devices were not wearable and because of “the 11 ‘popping-off’ problem[,]” the devices were unable to track Plaintiff’s steps, calories 12 burned, or heartrate. (Id. at ¶ 29). 13 Upon purchasing his first Fitbit device, Plaintiff created an account with Fitbit and 14 registered his device. (Mot. to Compel Arbitration at 10). This sign-up process required 15 Plaintiff to affirmatively accept Fitbit’s Terms of Service agreement. (Id.). Fitbit’s Terms 16 of Service includes an arbitration agreement, which requires that “any dispute arising out 17 of the Terms of Service or the use of Fitbit’s devices or services must be resolved by 18 binding arbitration.” (Id. at 12). The arbitration agreement further provides: “The 19 American Arbitration Association (AAA) will administer the arbitration under its 20 Commercial Arbitration Rules and Supplementary Procedures for Consumer Related 21 Disputes.” (Id. at 12–13). The Commercial Arbitration Rules require the arbitrator to 22 decide threshold questions, including arbitrability. (Id. at 13). Specifically, Commercial 23 Rule R-7(a) and (b) state: 24 (a) The arbitrator shall have the power to rule on his or her own jurisdiction, including any objections with respect to the existence, scope, or validity of the 25 arbitration agreement or to the arbitrability of any claim or counterclaim. 26 Plaintiff registered, or “paired,” each of his five Fitbit devices and agreed to Fitbit’s Terms of Service each time. 27 (b) The arbitrator shall have the power to determine the existence or validity of a 28 contract of which an arbitration clause forms a part. Such an arbitration clause 1 shall be treated as an agreement independent of the other terms of the contract. A decision by the arbitrator that the contract is null and void shall not for that 2 reason alone render invalid the arbitration clause. 3 4 (Id. at 13). Plaintiff registered, or “paired,” each of his five Fitbit devices and agreed to 5 Fitbit’s Terms of Service, including the arbitration agreement, all five times. (Id. at 13). 6 Based on these alleged facts, Plaintiff brought suit on behalf of himself and others 7 similarly situated against Defendant. Plaintiff asserts six causes of action: (1) violation of 8 the Consumer Legal Remedies Act (“CLRA”), Cal. Civ. Code §§ 1750, et seq.; (2) 9 violation of the Unfair Competition Law (“UCL”), Cal. Bus. & Prof. Code §§ 17200, et 10 seq.; (3) violation of the False Advertising Law (“FAL”), Cal. Bus. & Prof. Code § 17500 11 et seq.; (4) breach of express warranty; (5) breach of implied warranty; and (6) violation of 12 the Magnuson-Moss Warranty Act, 15 U.S.C. §§ 2301, et seq. Defendant now moves to 13 enforce the arbitration agreement in the Terms of Service, which Plaintiff opposes. 14 II. 15 LEGAL STANDARD 16 The Federal Arbitration Act (“FAA”), 9 U.S.C. § 1 et seq., governs the enforcement 17 of arbitration agreements involving interstate commerce. Am. Express Co. v. Italian Colors 18 Rest., 570 U.S. 228, 232–33 (2013). “The overarching purpose of the FAA . . . is to ensure 19 the enforcement of arbitration agreements according to their terms so as to facilitate 20 streamlined proceedings.” AT&T Mobility LLC v. Concepcion, 563 U.S. 333, 344 (2011). 21 “The FAA ‘leaves no place for the exercise of discretion by a district court, but instead 22 mandates that district courts shall direct the parties to proceed to arbitration on issues as to 23 which an arbitration has been signed.’ ” Kilgore v. KeyBank, Nat. Ass’n, 718 F.3d 1052, 24 1058 (9th Cir. 2013) (quoting Dean Witter Reynolds, Inc. v. Byrd, 470 U.S. 213, 218 25 (1985)). 26 “The standard for demonstrating arbitrability is not a high one; in fact, a district court 27 has little discretion to deny an arbitration motion, since the [FAA] is phrased in mandatory 28 terms.” Republic of Nicaragua v. Standard Fruit Co., 937 F.2d 469, 475 (9th Cir. 1991). 1 “Moreover, the scope of an arbitration clause must be interpreted liberally and ‘as a matter 2 of federal law, any doubts concerning the scope of arbitrable disputes should be resolved 3 in favor of arbitration.’ ” Concat LP v. Unilever, PLC, 350 F. Supp. 796, 804 (N.D. Cal. 4 2004) (quoting Moses H. Cone Mem’l Hosp. v. Mercury Constr. Corp., 460 U.S. 1, 24–25 5 (1983)). In determining whether to compel arbitration, a court must determine two 6 “gateway” issues: “ ‘(1) whether a valid agreement to arbitrate exists and, if it does, (2) 7 whether the agreement encompasses the dispute at issue.’ ” Kilgore, 673 F.3d at 955–56 8 (quoting Chiron Corp. v. Ortho Diagnostic Sys., Inc., 207 F.3d 1126, 1130 (9th Cir. 2000)). 9 If both requirements are satisfied, “the [FAA] requires the court to enforce the arbitration 10 agreement in accordance with its terms.” Id. The burden of proving that the claims at issue 11 are not suitable for arbitration is on the party resisting arbitration. Green Tree Fin. Corp- 12 Ala. v. Randolph, 531 U.S. 79, 91 (2000). 13 III.

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

Related

Dean Witter Reynolds Inc. v. Byrd
470 U.S. 213 (Supreme Court, 1985)
Green Tree Financial Corp.-Alabama v. Randolph
531 U.S. 79 (Supreme Court, 2000)
Momot v. Mastro
652 F.3d 982 (Ninth Circuit, 2011)
Matthew Kilgore v. Keybank, National Association
718 F.3d 1052 (Ninth Circuit, 2013)
American Express Co. v. Italian Colors Restaurant
133 S. Ct. 2304 (Supreme Court, 2013)
United States v. Kahan
350 F. Supp. 784 (S.D. New York, 1972)
Carey Brennan v. Opus Bank
796 F.3d 1125 (Ninth Circuit, 2015)
Mohamed v. Uber Technologies, Inc.
848 F.3d 1201 (Ninth Circuit, 2016)
Snyder v. Upper Elk Coal Co.
228 F. 21 (Fourth Circuit, 1915)

Cite This Page — Counsel Stack

Bluebook (online)
Willis v. Fitbit, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/willis-v-fitbit-inc-casd-2020.