Judge: Ashfaq G. Chowdhury, Case: 24NNCV04875, Date: 2025-03-27 Tentative Ruling
Case Number: 24NNCV04875 Hearing Date: March 27, 2025 Dept: E
Hearing Date: 03/27/2025-8:30 a.m.
Case No: 24NNCV04875
Trial Date: UNSET
Case Name: BOBBIE JEAN BROWN, an individual; v. UBER TECHNOLOGIES, INC., a
Delaware Corporation; RAISER, LLC., a Delaware Corporation; RAISER-CA, LLC., a
Delaware Corporation; MAHMOUD HAMISA, an Individual; and DOES 1-50, inclusive
TENTATIVE
RULING ON MOTION TO COMPEL ARBITRATION
PROCEDURAL
Moving Party: Defendants, Uber Technologies, Inc.; Rasier-CA,
LLC; and Rasier, LLC
Joining Party: Defendant, Mahmoud Hamisa
Responding Party: Plaintiff, Bobbie Jean Brown
Moving Papers: Notice/Motion; Chenshan Yu Declaration;
Christy M. Kostich Declaration; Proposed Order;
Moving Papers: Joinder by Mahmoud Hamisa [filed
1/22/2025]
Opposing Papers: Opposition
Reply Papers: Reply
[For purposes of this motion, if the Court refers to
“Defendants” or “Movants”, it is referring to Uber Technologies, Inc.;
Rasier-CA, LLC; and Rasier, LLC. If the Court is referring to Defendant,
Mahmoud Hamisa, it will refer to Hamisa as either “Hamisa” or “Joining
Defendant.”]
Additional Papers
Joinder
filed by Mahmoud Hamisa on 2/20/2025
Opposition to Joinder filed 3/6/2025 [hereinafter
referred to as “2nd. Oppo.”]
Reply to Opposition to Joinder filed 3/7/2025
RELIEF REQUESTED
“Defendants UBER
TECHNOLOGIES, INC., RASIER-CA, LLC and RASIER, LLC (collectively, “Defendants”
or “Uber”) will and hereby do move this Court for an Order compelling Plaintiff
BOBBIE JEAN BROWN (“Plaintiff”) to arbitrate her claims against Defendants and
to dismiss or stay this action pending completion of arbitration (“Motion”).
Defendants make this
Motion pursuant to 9 U.S.C., sections 1 et seq., on the grounds Plaintiff is
bound by a written agreement to arbitrate the subject matter of the First
Amended Complaint against Defendants. In addition, while arbitration of
Plaintiff’s claims against Defendants is pending, the filed action should be
stayed. (9. U.S.C., § 3.). This Motion is based on this Notice of Motion, the
attached Memorandum of Points and Authorities, Declarations of Christy Kostich
and Crenshan Yu filed concurrently herewith, all exhibits, all of the
pleadings, files, and records in this proceeding, all other matters of which
the Court may take judicial notice, and any argument or evidence that may be
presented to or considered by the Court prior to its ruling.”
(Mot. p. 1-2.)
BACKGROUND
Plaintiff, Bobbie Jean
Brown, filed the initial Complaint on 10/7/2024.
Plaintiff filed the First
Amended Complaint (FAC) on 10/08/2024 against Defendants – (1) Uber
Technologies, Inc., a Delaware Corporation; (2) Rasier, LLC., a Delaware
Corporation; (3) Rasier-CA, LLC., a Delaware Corporation; (4) Mahmoud Hamisa,
an individual; and (5) Does 1-50.
Plaintiff’s FAC alleges
that on 5/2/2023 Plaintiff was an Uber passenger in Defendant Hamisa’s vehicle,
and Hamisa made an illegal turn that resulted in the vehicle colliding with an
upcoming vehicle. (See Compl. ¶ 18.)
Plaintiff’s Complaint
alleges one cause of action for negligence against all Defendants.
ANALYSIS
Code
of Civil Procedure § 1281.2, governing orders to arbitrate controversies,
provides in pertinent part:
On petition of a party to an arbitration
agreement alleging the existence of a written agreement to arbitrate a
controversy and that a party to the agreement refuses to arbitrate that
controversy, the court shall order the petitioner and the respondent to
arbitrate the controversy if it determines that an agreement to arbitrate the
controversy exists, unless it determines that:
(a) The right to compel arbitration
has been waived by the petitioner; or
(b) Grounds exist for rescission of
the agreement.
(CCP § 1281.2(a)-(b).)
The party seeking
arbitration bears the initial burden of demonstrating the existence of an
arbitration agreement. (Pinnacle Museum Tower Assn. v. Pinnacle Market
Development (US), LLC (2012) 55 Cal.4th 223, 236.) In ruling on a
motion to compel arbitration, the Court must first determine whether the
parties actually agreed to arbitrate the dispute, and general principles of
California contract law help guide the court in making this determination. (Mendez
v. Mid-Wilshire Health Care Center (2013) 220 Cal.App.4th 534, 541; Victoria
v. Superior Court (1985) 40 Cal. 3d 734, 835.) Once the Court concludes an
arbitration agreement exists, it must then consider whether the agreement
covers the claims at issue. (Omar v. Ralphs Grocery (2004) 118 Cal.App.4th
966, 960.) Even when the FAA applies, “interpretation of the arbitration
agreement is governed by state law principles.” (Hotels Nevada, LLC v.
Bridge Banc, LLC (2005) 130 Cal.App.4th 1431, 1435.)
Existence of Agreement –
Parties - Uber Technologies, Inc.; Rasier-CA, LLC; and Rasier, LLC
As to Defendants, Uber
Technologies, Inc.; Rasier-CA, LLC; and Rasier, LLC, Plaintiff does not oppose
the existence of the arbitration agreement between them. Therefore, based on the
declaration of Chenshan Yu (Data
Scientist employed with Uber Technologies, Inc.), the Exhibits submitted with
the Yu Declaration, and based on the fact that Plaintiff did not oppose the
existence of the arbitration agreement between Defendants and Plaintiff, Defendants
thus demonstrated the existence of the arbitration agreement between Plaintiff
and Defendants.
Existence of Agreement –
Parties – Mahmoud Hamisa
Joining
Defendant, Hamisa, joins Defendants’ motion to compel arbitration.
Hamisa acknowledges he
was not a signatory to the arbitration agreement between Defendants and
Plaintiff. However, Hamisa argues that the arbitration agreement can be
applicable to him under the theories of agency and equitable estoppel.
As stated in Jensen
v. U-Haul Co. of California:
[A]s a general rule, “[t]he right to
arbitration depends on a contract, and a party can be compelled to submit a
dispute to arbitration only if the party has agreed in writing to do so.” (Matthau
v. Superior Court (2007) 151 Cal.App.4th 593, 598, 60 Cal.Rptr.3d
93 (Matthau).) “Even the strong public policy in favor of
arbitration does not extend to those who are not parties to an arbitration
agreement or who have not authorized anyone to act for them in executing such
an agreement.” (County of Contra Costa v. Kaiser Foundation Health Plan,
Inc. (1996) 47 Cal.App.4th 237, 245, 54 Cal.Rptr.2d 628 (Contra
Costa).)
Nevertheless, there are circumstances under
which persons who have not signed an agreement to arbitrate are bound to do so.
One treatise has stated that there are “six theories by which a nonsignatory
may be bound to arbitrate: ‘(a) incorporation by reference; (b) assumption; (c)
agency; (d) veil-piercing or alter ego; (e) estoppel; and (f) third-party
beneficiary.’ ” (Suh, supra, 181 Cal.App.4th at p. 1513, 105
Cal.Rptr.3d 585 [quoting 2 Oehmke, Commercial Arbitration (3d ed. 2006
update) § 41.57 at pp. 41-195]; see 1 Oehmke, Commercial Arbitration (3d ed.
Aug. 2017 update) § 8.1 [similar].)
(Jensen v. U-Haul Co. of California (2017) 18 Cal.App.5th 295, 300-301.)
Hamisa cites to Thomas
v. Westlake (2012) 204 Cal.App.4th 605, 614 to support his theory of agency,
and Hamisa cites to Garcia v. Pexco, LLC (2017) 11 Cal.App.5th 782, 785-788
to support his theory of equitable estoppel.
Under Thomas v.
Westlake:
There are, however, “exceptions to
the general rule that a nonsignatory ... cannot invoke an agreement to
arbitrate, without being a party to the arbitration agreement.” (Westra,
supra, 129 Cal.App.4th at p. 765, 28 Cal.Rptr.3d 752.) One such
exception provides that when a plaintiff alleges a defendant acted as an agent
of a party to an arbitration agreement, the defendant may enforce the agreement
even though the defendant is not a party thereto.
(Thomas
v. Westlake (2012) 204 Cal.App.4th 605, 614.)
Plaintiff’s FAC alleges
as follows:
Plaintiff is informed and believes, and
based upon such information and belief alleges that at all times relevant
hereto, each Defendant, including DOES 1 through 50, was the owner, servant,
agent, joint-venturer, employee or employer of each of its co-Defendants, and
in doing the acts hereinafter mentioned, each Defendant was acting within the
scope of its authority and with the permission and consent of its
co-Defendants, and each of them, and that said acts of each Defendant was
ratified by said Defendant's co-Defendants, and each of them and every
Defendant, as aforesaid, when acting as a principal, was negligent in the selection
and hiring of each and every other Defendant as an agent, employee and/or joint
venturer.
(FAC. ¶ 12.)
Here, it appears that
Hamisa can in fact join Defendants’ arbitration agreement, despite not being a
signatory, based on the theory of agency, since Plaintiff alleges that Hamisa
acted as an agent of a party to an arbitration agreement.
Plaintiff opposes
Hamisa’s joinder on several grounds.
Plaintiff argues as
follows:
Hamisa attempts to circumvent this by
arguing that Plaintiff’s claims against him arise out of her use of the Uber
platform, but this is a mischaracterization. Plaintiff's claims are based on Hamisa’s
independent acts of negligence while operating a motor vehicle, not any
contractual obligations stemming from the Uber agreement.
(2nd Oppo., p. 2)
Here, the Court fails to
understand what Plaintiff is trying to argue. The entire premise of Hamisa’s
arguments regarding agency and equitable estoppel is that Hamisa can join the
arbitration despite the fact that Hamisa did not sign the arbitration
agreement. Therefore, if Plaintiff wants to clarify their argument at the
hearing, Plaintiff should plan to do so, otherwise the Court finds this
argument unavailing.
Plaintiff also argues as
follows:
Furthermore, Uber’s arbitration agreement
explicitly limits arbitration to disputes between Uber and the rider, without
any language extending enforcement rights to independent contractors such as
Hamisa. Courts have consistently held that independent drivers working under
platforms such as Uber do not have standing to compel arbitration absent
express inclusion in the agreement. (See O’Hanlon v. Uber Techs., Inc.
(3d Cir. 2022) 990 F.3d 757, 764.)
(2nd Oppo., p. 2.)
Plaintiff’s argument is
unavailing.
First, O’Hanlon v. Uber Techs., Inc. (3d Cir. 2022) 990
F.3d 757, 764 did not hold that independent drivers working under platforms
such as Uber do not have standing to compel arbitration absent express
inclusion in the agreement.
Second, O’Hanlon v.
Uber Techs., Inc. (3d Cir. 2022) 990 F.3d 757, 764 is entirely inapposite
and not on point to the instant circumstances. In O’Hanlon, wheelchair
users, who were non-signatories to Uber’s arbitration clause brought suit under
the Americans with Disabilities Act for discrimination for not offering
wheelchair accessible vehicle options. Uber argued that the wheelchair users
did not have standing to sue. The portion of the case cited by Plaintiff dealt
with the United States Court of Appeals discussing how it had no independent
duty to review the District Court’s ruling on Plaintiffs’ standing. Here, the
instant circumstances have nothing to do with the circumstances in O’Hanlon.
Plaintiff also argues
that the agency exception does not apply because Uber has consistently
maintained that its drivers are independent contractors, not employees or
agents.
The Court fails to
understand Plaintiff’s argument.
First, Plaintiff provides
no evidence or support for its argument that “Uber has consistently maintained
that its drivers are independent contractors, not employees or agents.”
Second, Plaintiff’s
argument does not address Thomas v. Westlake and how Plaintiff alleged
that all the Defendants were agents to one another.
Plaintiff also argues
that “Courts have repeatedly rejected efforts by Uber drivers to claim agency
status for purposes of arbitration enforcement. (See O’Hanlon
v. Uber Techs., Inc. (3d Cir. 2022) 990 F.3d 757, 764; Gondal v. Uber
Techs., Inc. (N.D. Cal. 2021) 2021 WL 1204153, at *4.).”
As the Court previously
addressed, O’Hanlon is not on point.
As to Gondal, the
Court cannot find the Gondal case that Plaintiff cites.
Plaintiff also argues
that “Plaintiff’s claims of vicarious liability do not transform Hamisa into an
agent for purposes of enforcing the arbitration clause.” (2nd Oppo. p. 3.) To
support Plaintiff’s argument, Plaintiff cites to Thomas v. Westlake
(2012) 204 Cal.App.4th 605, 614.
Here, the Court does not
find Plaintiff’s argument availing. Thomas v. Westlake seems to directly
support Hamisa’s argument in favor or Hamisa being able to join the arbitration
agreement. Based on the Court’s reading of Thomas v. Westlake, the Court
is unsure how Plaintiff is arguing that Thomas v. Westlake does not
support compelling arbitration for Hamisa.
Overall, Hamisa has
demonstrated his ability to join Defendants’ motion to compel arbitration based
on the theory of agency. The Court will not address the equitable-estoppel
theory because Hamisa successfully demonstrated that the agency exception was
applicable, and Plaintiff did not successfully attack the agency exception.
Lastly, Plaintiff’s
argument – that public policy favors keeping negligence claims in court, where
plaintiffs have full discovery rights and access to a jury – is unavailing. To
support Plaintiff’s argument, Plaintiff cites to Armendariz v. Found. Health
Psychcare Servs., Inc. (2000) 24 Cal.4th 83, 100. The Court is not clear
how Plaintiff’s citation to Armendariz is on point in the instant
scenario, when Hamisa has demonstrated a basis to join the arbitration
agreement based on the agency exception in Thomas v. Westlake (2012) 204
Cal.App.4th 605, 614.
Scope
Once
the Court concludes an arbitration agreement exists, it must then consider
whether the agreement covers the claims at issue. (Omar v. Ralphs Grocery
(2004) 118 Cal.App.4th 966, 960.)
Plaintiff argues that
Plaintiff’s claims fall outside the scope of the arbitration agreement.
Plaintiff argues:
The incident giving rise to this lawsuit
is a motor vehicle collision caused by Defendant Hamisa— an independent
contractor who was using Uber’s platform. Personal injury claims stemming from
the negligence of independent contractors are not the type of disputes
contemplated by Uber’s arbitration agreement. To the extent there is any
ambiguity regarding the scope of the arbitration clause, such ambiguity must be
construed against Uber as the drafter (Sandquist v. Lebo Automotive, Inc.
(2016) 1 Cal.5th 233, 248).
(Oppo. p. 4.)
In relevant part, the
arbitration agreement provides:
Except as expressly provided below in
Section 2(b), you and Uber agree that any dispute, claim or controversy in any
way arising out of or relating to (i) these Terms and prior versions of these
Terms, or the existence, breach, termination, enforcement, interpretation,
scope, waiver, or validity thereof, (ii) your access to or use of the Services
at any time, (iii) incidents or accidents resulting in personal injury that you
allege occurred in connection with your use of the Services, whether the
dispute, claim or controversy occurred or accrued before or after the date you
agreed to the Terms, or (iv) your relationship with Uber, will be settled by
binding arbitration between you and Uber, and not in a court of law. This
Agreement survives after your relationship with Uber ends.
(Yu Decl., Ex. D, Section
2.)
Here, the Court does not
find Plaintiff’s argument availing as it fails to see how the claims fall
outside the scope of the arbitration agreement.
Defense to Arbitration -
Waiver
“The party seeking
arbitration bears the burden of proving the existence of an arbitration
agreement, and the party opposing arbitration bears the burden of proving any
defense, such as unconscionability. [Citation.]” (Marenco v. DirectTV LLC (2015)
233 Cal.App.4th 1409, 1416.) “Code of Civil Procedure section 1281.2 provides
that one ground for denying a petition to compel arbitration is that “[t]he
right to compel arbitration has been waived by the petitioner.”” (Iskanian
v. CLS Transportation Los Angeles, LLC (2014) 59 Cal.4th 348, 374.)
Plaintiff opposes
compelling arbitration based on the defense of waiver.
Plaintiff argues that
Uber waived its right to compel arbitration because:
In this case, Uber waived its right to
arbitration by filing answers to the Complaint, serving and responding to
discovery, and objecting to Plaintiff’s CCP § 998 settlement offer. In
addition, Uber objected on December 30, 2024, to Plaintiff’s Notice of
Deposition of its Person Most Qualified (PMQ) and accompanying Request for
Production of Documents (RFPs), which were scheduled for January 6, 2025. These
objections were served after Uber had already responded to written discovery on
December 26, 2024, further embedding itself in the litigation process.
(Oppo. p. 2-3.)
Plaintiff also argues
that Uber’s actions have caused undue prejudice to Plaintiff by “creating an
imbalance that cannot be ignored by this Court.” (Oppo., p. 3.)
Plaintiff cites to St.
Agnes Medical Center v. PacifiCare of California (2003) 31 Cal.4th 1187,
1196 and Iskanian v. CLS Transportation Los Angeles, LLC (2014) 59
Cal.4th 348, 376 to support Plaintiff’s argument that Defendants waived their
ability to compel arbitration.
Plaintiff’s arguments on
waiver are unavailing for several reasons.
First, St. Agnes
Medical Center and Iskanian are two cases in which the Supreme Court
of California did not find waiver.
Second, Defendants’
actions don’t demonstrate that they waived their ability to compel arbitration.
As explained in Iskanian
v. CLS Transportation Los Angeles, LLC:
“California courts have found a waiver of
the right to demand arbitration in a variety of contexts, ranging from
situations in which the party seeking to compel arbitration has previously
taken steps inconsistent with an intent to invoke arbitration [citations]
to instances in which the petitioning party has unreasonably delayed in
undertaking the procedure. [Citations.] The decisions likewise hold that the
‘bad faith’ or ‘willful misconduct’ of a party may constitute a waiver and thus
justify a refusal to compel arbitration. [Citation.]” (Davis v. Blue Cross
of Northern California (1979) 25 Cal.3d 418, 425–426, 158 Cal.Rptr.
828, 600 P.2d 1060.) The fact that the party petitioning for arbitration has
participated in litigation, short of a determination on the merits, does not by
itself constitute a waiver. (St. Agnes Medical Center, supra, 31
Cal.4th at p. 1203, 8 Cal.Rptr.3d 517, 82 P.3d 727.)
We have said the following factors are
relevant to the waiver inquiry: “ ‘ “(1) whether the party's actions are
inconsistent with the right to arbitrate; (2) whether ‘the litigation machinery
has been substantially invoked’ and the parties ‘were well into preparation of
a lawsuit’ before the party notified the opposing party of an intent to
arbitrate; (3) whether a party either requested arbitration enforcement close
to the trial date or delayed for a long period before seeking a stay; (4)
whether a defendant seeking arbitration filed a counterclaim without asking for
a stay of the proceedings; (5) ‘whether important intervening steps [e.g.,
taking advantage of judicial discovery procedures not available in arbitration]
had taken place’; and (6) whether the delay ‘affected, misled, or prejudiced’
the opposing party.” ' ” (St. Agnes Medical Center, supra, 31
Cal.4th at p. 1196, 8 Cal.Rptr.3d 517, 82 P.3d 727.)
In light of the policy in favor of
arbitration, “waivers are not to be lightly inferred and the party seeking to
establish a waiver bears a heavy burden of proof.” (St. Agnes Medical
Center, supra, 31 Cal.4th at p. 1195, 8 Cal.Rptr.3d 517, 82 P.3d 727.)
“Generally, the determination of waiver is a question of fact, and the trial
court's finding, if supported by sufficient evidence, is binding on the
appellate court. [Citation.] ‘When, however, the facts are undisputed and only
one inference may reasonably be drawn, the issue is one of law and the
reviewing court is not bound by the trial court's ruling.’ ” (Id. at
p. 1196, 8 Cal.Rptr.3d 517, 82 P.3d 727.)
(Iskanian v. CLS
Transportation Los Angeles, LLC (2014) 59 Cal.4th 348, 374-75.)
Here, Plaintiff has not
established waiver, and many of the factors relevant to the waiver inquiry do
not lean in Plaintiff’s favor of establishing waiver.
First, Defendants’
actions are not inconsistent with the right to arbitrate. Defendants’ actions
were reacting to Plaintiff’s actions. For example, Plaintiff propounded several
different types of discovery onto Defendants, and Defendants objected to the
discovery on the grounds that arbitration was the proper forum. Defendants’
actions here are not inconsistent with the right to arbitrate as they argued
that arbitration was the proper forum.
Further, Defendants
filing an Answer was not inconsistent with the right to arbitrate as they
asserted the affirmative defense concerning Uber’s right to arbitrate.
Second, the litigation
machinery had not been substantially invoked, and the parties were not well
into preparation of the lawsuit before Uber notified the opposing party of an
intent to arbitrate. Plaintiff’s FAC was filed on 10/8/2024, and Uber’s Answer
(asserting the affirmative defense of arbitration) was filed on 12/6/2024.
Additionally, Uber’s motion to compel arbitration was filed on 1/13/2025.
Third, Uber did not
request arbitration close to the trial date or delay for a long period.
Fourth, Uber did not file
a counterclaim without asking for a stay of proceedings.
Fifth, important
intervening steps had not taken place. Uber did not take advantage of judicial
discovery procedures; Uber objected to Plaintiff’s discovery on the basis that
arbitration was the proper forum.
And lastly, Uber did not
prejudice the Plaintiff, as this case has not even been set for trial.
Therefore, Plaintiff did
not demonstrate that Defendants waived their ability to compel arbitration.
Defense to Arbitration –
Unconscionability (Procedural and Substantive)
Unconscionability
generally includes the absence of meaningful choice on the part of one of the
parties together with contract terms that unreasonably favor the other party. (Carboni
v. Arrospide (1991) 2 Cal.App.4th 76, 82-83.) Unconscionability has both a
“procedural” and a “substantive” element. (A & M Produce Co. v. FMC Corp.
(1982) 135 Cal.App.3d 473, 486.) An agreement to arbitrate is unenforceable only if both
procedural and substantive unconscionability is shown. (Stirlen v.
Supercuts, Inc. (1997) 51 Cal.App.4th 1519, 1533.) Plaintiff has the
burden of proving both procedural and substantive unconscionability. (Crippen
v. Central Valley RV Outlet. Inc. (2004) 124 Cal.App.4th 1159, 1165.)
Procedural
Unconscionability
“The party seeking
arbitration bears the burden of proving the existence of an arbitration
agreement, and the party opposing arbitration bears the burden of proving any
defense, such as unconscionability. [Citation.]” (Marenco v. DirectTV LLC (2015)
233 Cal.App.4th 1409, 1416.)
Plaintiff argues that
Uber waived its right to compel arbitration because the agreement was
procedurally unconscionable because it was buried in multiple layers of
hyperlinks and did not require Plaintiff to actively acknowledge or review the
specific terms before providing consent.
To support Plaintiff’s
argument, Plaintiff cites to Nguyen v. Barnes & Noble Inc. (9th Cir.
2014) 763 F.3d 1171, 1177 and Specht v. Netscape Communications Corp.
(2d Cir. 2002) 306 F.3d 17, 30.
Plaintiff’s arguments are
unavailing for several reasons.
First, based on the
factual record that will be explained below, Plaintiff did in fact have to
actively provide consent to the arbitration agreement. Second, the cases that
Plaintiff cited are not on point in the instant scenario.
As to the factual record
provided by Yu in support of Defendants’ motion to compel arbitration, there is
no procedural unconscionability here.
In relevant part of the
Yu Declaration regarding Plaintiff’s consent to the arbitration agreement:
9. On January 6, 2025, I personally
searched Uber’s database for Plaintiff’s account by entering their unique
identifying number and/or email address. In reviewing their account, I
determined that, on February 2, 2021, February 8, 2022, May 16, 2022, January
14, 2023, January 21, 2023 and January 22, 2023, Plaintiff was presented with
an in-app blocking pop-up screen with the header “We’ve updated our terms.” It
also stated in large type, “We encourage you to read our Updated Terms in full”
and under that message had the phrases “Terms of Use” and “Privacy Notice,”
which were displayed underlined and in bright blue text, all of which set the
text apart from other text on the screen and indicated a hyperlink. When a user
clicked either hyperlink, the Terms of Use or Privacy Notice, that were
published on Uber’s website respectively, were displayed. The hyperlink was
linked to the following address:
https://www.uber.com/legal/document/?name=general-terms-of-use. The in-app
blocking pop-up screen expressly stated that: “By checking the box, I have
reviewed and agreed to the Terms of Use and acknowledge the Privacy Notice.” It
also states that: “I am at least 18 years of age.”
10. Based upon my personal knowledge
arising from my position and job duties at Uber, the in-app blocking pop-up
screen precluded the use of the Uber app unless and until a user clicked the
checkbox on the screen and clicked the large “Confirm” button at the bottom of
the screen. Attached hereto as Exhibit C is a true and correct copy of a
representation of the in-app blocking pop-up screen.
11. Based upon my personal knowledge
arising from my position and job duties at Uber, when a user presented with the
in-app blocking pop-up screen, described in the prior paragraph of this
declaration, clicks the checkbox and clicks the “Confirm” button a record of
this consent is simultaneously and electronically captured, recorded,
maintained, safeguarded, and stored in the regular course of Uber’s business at
the time of the events being recorded. This record is linked to the user’s
unique identifier associated with the user’s account, which is located through
the email address and/or mobile telephone number used to access the Uber
platform.
12. I personally searched Uber’s database
for Plaintiff’s account by entering their unique identifying number and/or
email address1 . I located Uber’s record of Plaintiff’s consent to the January
18, 2021, December 16, 2021 , April 4, 2022, August 16, 2022, and January 17,
2023 Terms. I am personally familiar with the contents of the January 18, 2021,
December 16, 2021 , April 4, 2022, August 16, 2022, and January 17, 2023 Terms.
Attached hereto as Exhibit A is a true and correct copy of Uber’s
record of Plaintiff’s consent to the January 18, 2021, December 16, 2021 ,
April 4, 2022, August 16, 2022, and January 17, 2023 Terms. That record
confirms that, on February 2, 2021, February 8, 2022, May 16, 2022, January 14,
2023, January 21, 2023 and January 22, 2023, Plaintiff accessed their Uber app,
was presented with the in-app blocking popup screen regarding the January 18,
2021, December 16, 2021 , April 4, 2022, August 16, 2022, and January 17, 2023
Terms described above, and clicked the checkbox and tapped the “Confirm”
button.
13. Based upon my personal knowledge
arising from my position and job duties at Uber, Uber maintains and stores all
prior versions of Terms that have been in effect at various points of time in
the past and which were published on its website. On January 6, 2025, I
accessed Uber’s business records to obtain the Terms which were in effect for
United States users on or about January 18, 2021, December 16, 2021 , April 4,
2022, August 16, 2022, and January 17, 2023. I am personally familiar with the
contents of the January 18, 2021, December 16, 2021 , April 4, 2022, August 16,
2022, and January 17, 2023 Terms. Attached hereto as Exhibit D is
a true and correct copy of the January 18, 2021, December 16, 2021 , April 4,
2022, August 16, 2022, and January 17, 2023 Terms. The January 18, 2021,
December 16, 2021 , April 4, 2022, August 16, 2022, and January 17, 2023 Terms
contain an Arbitration Agreement.
(Yu Decl. ¶¶ 9-13.)
Based on the Yu
declaration, Plaintiff would have had to actively acknowledge consent by
clicking the checkbox and tapping the “Confirm” button. In Opposition,
Plaintiff does not submit a declaration by Plaintiff indicating otherwise.
Additionally, Plaintiff’s
citation to Nguyen v. Barnes & Noble Inc. (9th Cir. 2014) 763 F.3d
1171, 1177 is not on point. In Nguyen, the plaintiff did not have to
check a box or assent to the terms of use. In Nguyen, the terms of use
were displayed via a hyperlink located at the bottom of the screen on the
website, but Nguyen was not prompted to assent to the Terms of Use.
Likewise, Plaintiff’s
citation to Specht v. Netscape Communications Corp. (2d Cir. 2002) 306
F.3d 17, 30 is not on point. In Specht, the plaintiffs were not required
to express unambiguous assent nor even view the license terms.
Here, Plaintiff had to
click a checkbox and click confirm, further, Plaintiff could not use the app
unless the user clicked the checkbox to confirm the terms of use.
“A ‘clickwrap’ agreement
is one in which an internet user accepts a website’s terms of use by clicking
an ‘I agree’ or ‘I accept’ button, with a link to the agreement readily
available.” (Sellers v. JustAnswer LLC (2021) 73 Cal.App.5th 444, 463.)
“Courts have generally enforced agreements to arbitrate formed via
‘clickwrap[.]’” (Weeks v. Interactive Life Forms, LLC (2024) 100
Cal.App.5th 1077, 1084.)
“Clickwrap agreements
have been held to manifest assent, even on consumers who did not read them,
because “the website [has] put[ ] the consumer on constructive notice of the
contractual terms.”” (Weeks v. Interactive Life Forms, LLC (2024) 100
Cal.App.5th 1077, 1085.)
Therefore, Plaintiff has
not demonstrated procedural unconscionability.
Substantive
Unconscionability
An agreement to arbitrate
is unenforceable only if both procedural and substantive unconscionability is
shown. (Stirlen v. Supercuts, Inc. (1997) 51 Cal.App.4th 1519, 1533.)
As a preliminary matter,
Plaintiff’s unconscionability argument fails because Plaintiff did not
demonstrate procedural unconscionability.
Additionally, Plaintiff
did not demonstrate substantive unconscionability.
Plaintiff argues:
In addition to procedural flaws, the
arbitration agreement is substantively unconscionable. Its overly broad scope
purports to cover all claims “arising out of or related to” Uber’s services,
including personal injury claims unrelated to the core purpose of Uber’s
platform. Furthermore, the delegation clause improperly assigns threshold
determinations regarding arbitrability to the arbitrator, further
disadvantaging Plaintiff and stripping the Court of its authority to resolve
foundational issues of enforceability (Rent-A-Center, W., Inc. v. Jackson
(2010) 561 U.S. 63, 70).
(Oppo. p. 4. )
Here, the Court does not
understand Plaintiff’s argument on substantive unconscionability. Not only does
the Court not understand Plaintiff’s argument, but the Court does not
understand how Plaintiff is arguing that the case it cited supports Plaintiff’s
argument. In Rent-A-Center, the Supreme Court of the United States held
that the provision of the employment agreement which delegated to an arbitrator
exclusive authority to resolve any dispute relating to the agreement’s
enforceability was a valid delegation under the FAA. This seems to undercut
Plaintiff’s own argument.
Therefore, Plaintiff did
not demonstrate substantive unconscionability.
TENTATIVE RULING
Defendants’
motion to compel arbitration and stay this action pending completion of
arbitration is GRANTED. Likewise, Joining Defendant, Hamisa’s, joinder to
compel arbitration is GRANTED.
Defendants demonstrated
the existence and scope of the arbitration agreement between them and the
Plaintiff. Likewise, Joining Defendant demonstrated that the agency exception
applied so that Hamisa could also compel arbitration. Further, Plaintiff’s
arguments on waiver and unconscionability were unavailing.