Wilson v. Hatch Bank

District Court, S.D. California·Decided March 29, 2024·No. 3:23-cv-00813·Unknown

Opinion

AMBER WILSON, individually and on Case No.: 23cv813-JES (MPP) behalf of all others similarly situated, ORDER: Plaintiff, v. (1) GRANTING DEFENDANT’S MOTION TO COMPEL HATCH BANK, ARBITRATION; and Defendant. (2) DISMISSING CASE WITHOUT

[ECF No. 7] Pending before the Court is Defendant Hatch Bank’s (“Defendant”) Motion to Compel Arbitration and Dismiss the Complaint. ECF No. 7, “Mot.”. Plaintiff Amber Wilson (“Plaintiff”) has filed a response in opposition to the Motion, ECF No. 9, “Opp’n”, and Defendant has filed a reply. ECF No. 11, “Reply”. After a thorough review of the record and the relevant case law, and for the reasons set forth below, the Court GRANTS Hatch Bank’s Motion to Compel Arbitration and DISMISSES the case without prejudice. //// //// On January 20, 2023, Wilson applied for a loan from Hatch Bank, a digital bank that serves financial technology, small businesses, financial companies, and individuals. See ECF No. 1, “Complaint” ¶ 2; see also ECF No. 7-2, “Gu Dec.” ¶ 6. Wilson submitted her loan application through an online loan portal hosted by Wisetack, Inc. (“Wisetack”), Defendant’s program manager and servicer. See Gu Dec. ¶¶ 4, 6. Wisetack provides consumer credit technology solutions, marketing, and servicing for consumer loans originated by lenders such as Hatch Bank, as well as a platform through which consumers can submit applications to and obtain loan financing. See id. ¶ 4. To receive applicant data from Wisetack, Hatch Bank utilizes a third-party hosted file transfer site, GoAnywhere, which is owned and operated by a third party, Fortra. Id. ¶ 7. To submit her application, Wilson was required to assent to Wisetack’s General Terms of Service (“TOS”), E-Sign Consent, and Privacy Policy (collectively, “The Agreements”), by selecting a “click box” which read, “I agree” and was presented with links from which she could view The Agreements. See Id. ¶¶ 9-10. Wilson did not ultimately obtain a loan or any other financial product from Hatch Bank. See Id. ¶ 8. Between January 30, 2023, and January 31, 2023, Hatch Bank’s files, which included Wilson’s personal identifiable information,1 stored on Fortra’s GoAnywhere site were subject to unauthorized access by cybercriminals. See Complaint ¶¶ 4, 6. Accordingly, Plaintiff brings this putative class action against Defendant asserting claims for (1) negligence; (2) breach of contract; (3) breach of implied contract; (4) invasion of privacy; (5) violation of California’s Unfair Competition Law; (6) unjust enrichment; and (7) declaratory and injunctive relief. See Id. ¶ 18.

1 Personal identifiable information (PII) is data that can be used to detect a specific individual. Such data can be used to apply for employment, lines of credit, and purchase or lease real property. See Complaint ¶¶ 66-67. The following clauses of Wisetack’s TOS are related to the parties and pertinent to arbitration. The preamble of the TOS states: These General Terms of Service (“Terms”) are a legally binding agreement between you (“you” or “User”) and Wisetack, Inc., and our affiliates, agents, and assigns (“Wisetack,” “we,” or “us”) regarding your use of Wisetack’s services, including our platform, online services, and software applications (collectively, the “Service” or “Services”). Please read the Terms carefully. By using the Service you acknowledge that you have read, understood, and agree to be bound by the Terms, including the Wisetack Privacy Policy. These Terms provide that all disputes between you and Wisetack with respect to your use of the Service will be resolved by binding arbitration, to the fullest extent permitted under applicable law. ECF No. 7-4 at 2. Section 1 of the TOS states: The Service is intended to provide consumer financing through third-party merchant websites, in-person transactions, software platforms, retail stores, or any other method that we or our partners make the Services available (collectively, “Merchants”), and through which individual persons (“Customers”) may apply for a loan from Hatch Bank, the lender for Wisetack loans (“Hatch Bank”). Hatch Bank will pay the Merchant from whom a Customer has purchased goods or services in exchange for the Customer’s promise to repay the loan used for such purchase plus a finance charge, as detailed herein. Id. Section 19(a), the (“Arbitration Clause”), of the TOS states: In the interest of resolving disputes in the most expedient and cost-effective manner, you and Wisetack agree that every dispute arising in connection with these Terms or the Services will be resolved by binding arbitration, to the fullest extent permitted under applicable law. Arbitration is less formal than a lawsuit in court. Arbitration uses a neutral arbitrator instead of a judge or jury, may allow for more limited discovery than in court, and can be subject to very limited review by courts. Arbitrators can award the same damages and relief that a court can award. This agreement to arbitrate disputes includes all claims arising out of or relating to any aspect of these Terms or the use of the Services, whether based in contract, tort, statute, fraud, misrepresentation, or any other legal theory, and regardless of whether a claim arises during or after the termination of these Terms or any use of the Service. YOU UNDERSTAND AND AGREE THAT, BY USING THE SERVICES, YOU AND WISETACK ARE EACH WAIVING THE RIGHT TO A TRIAL BY JURY OR TO PARTICIPATE IN A CLASS ACTION, TO THE FULLEST Id. at 5. Finally, Section 19(c), the (“Delegation Clause”), of the TOS, states: To the fullest extent permitted under applicable law, any arbitration related to these Terms or the Service will be settled under the Federal Arbitration Act, and governed by the Commercial Dispute Resolution Procedures and the Supplementary Procedures for Consumer Related Disputes (collectively, “AAA Rules”) of the American Arbitration Association (“AAA”), as modified by these Terms, and will be administered by the AAA. Id. A. The Federal Arbitration Act Agreements “evidencing a transaction involving commerce” are subject to the Federal Arbitration Act (“FAA”). See Chiron Corp. v. Ortho Diagnostic Sys., Inc., 207 F.3d 1126, 1130 (9th Cir. 2000) (citing 9 U.S.C. § 2). The FAA provides that an arbitration agreement “shall be valid, irrevocable, and enforceable, save upon such grounds as exist at law or in equity for the revocation of any contract.” 9 U.S.C. § 2. “[A] party aggrieved by the alleged failure, neglect, or refusal of another to arbitrate under a written agreement for arbitration may petition any United States district court ... for an order directing that ... arbitration proceed in the manner provided for in [the arbitration] agreement.” 9 U.S.C. § 4. If the district court finds a party has failed to comply with a valid arbitration agreement, it must issue an order compelling arbitration. Id. Under the FAA, the court’s role is “limited to determining (1) whether a valid agreement to arbitrate exists and, if it does, (2) whether the agreement encompasses the dispute at issue.” Chiron Corp., 207 F.3d at 1130. “If the response is affirmative on both counts, then the Act requires the court to enforce the arbitration agreement in accordance with its terms.” Id. Courts must apply ordinary state law principles in determining whether to invalidate an agreement to arbitrate. Ferguson v. Countrywide Credit Indus., 298 F.3d 778, 782 (9th Cir. 2002). Accordingly, arbitration agreements may be invalidated by generally applicable contract defenses, such as fraud, duress, or unconscionability. AT&T Mobilit

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Wilson v. Hatch Bank, (S.D. Cal. 2024).

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