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  • Case Opinion

Carfax, Inc. v. Accu-Trade, LLC

Carfax, Inc. v. Accu-Trade, LLC

United States District Court for the Eastern District of Virginia, Alexandria Division

March 4, 2022, Decided; March 4, 2022, Filed

Civil Action No. 1:21-cv-00361 (RDA/TCB)

Opinion

MEMORANDUM OPINION AND ORDER

This matter comes before this Court on Accu-Trade, LLC and R. Hollenshead Auto Sales & Leasing, Inc.'s ("Defendants") Motion to Dismiss for lack of subject matter jurisdiction and failure to state a claim ("Motion"). Dkt. Nos. 13; 23. This Court has dispensed with oral argument as it would not aid in the decisional process. Fed. R. Civ. P. 78(b); Local Civil Rule 7(J). This matter has been fully briefed and is now ripe for disposition. Considering Defendants' Memorandum in Support of its Motion (Dkt. 14), Plaintiff Carfax, Inc.'s ("Plaintiff") Opposition (Dkt. 16), Defendants' Reply (Dkt. 17), Defendants Supplemental Memorandum in Support of its Motion (Dkt. 23); Plaintiff's Supplemental Opposition (Dkt. 26), and Defendants' Supplemental Reply (Dkt. 27), this Court DENIES the Motion to Dismiss for Lack of Jurisdiction and GRANTS IN PART and DENIES [*2]  IN PART the Motion to Dismiss for Failure to State a Claim for the reasons that follow.

I. BACKGROUND

A. Factual Background

This matter arises from the Complaint Plaintiff filed before this Court alleging six counts against Defendants: (1) infringing the Computer Fraud and Abuse Act, 18 U.S.C. § 1030 ("CFAA"); (2) infringing the Virginia Computer Crimes Act, Va. Code Ann. § 18.2-152.1, et seq. ("VCCA"); (3) fraud; (4) unjust enrichment; (5) conversion; and (6) trespass to chattels. Plaintiff seeks equitable relief and damages, as well as punitive damages.

Plaintiff is a data company, incorporated under the laws of Pennsylvania and headquartered with its principal place of business in Centreville, Virginia. Defendant Accu-Trade, LLC ("Accu-Trade"), which is a valuation platform for auto dealers in calculating offers for potential trade-in vehicles, is part of Defendant R. Hollenshead Auto Sales & Leasing, Inc. ("Hollenshead"), which characterizes itself as a major automobile wholesaler in North America. Accu-Trade is organized under the laws of Delaware, with its principal place of business in Pennsylvania, while Hollenshead is incorporated under the laws of Florida, with its principal place of business in Pennsylvania.

Plaintiff manages [*3]  vehicle history information for participants in the used car and light truck markets. As part of its information sharing technology, Plaintiff owns the QuickVIN® tool ("QV") to allow its users to search Vehicle Identification Numbers ("VINs") in Plaintiff's database and the associated vehicle's year, make, and model by simply searching a license plate state and number. As a result, the QV tool allows its users to efficiently identify VINs in connection with used car transactions at less cost.

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2022 U.S. Dist. LEXIS 38853 *; 2022 WL 657976

CARFAX, INC., Plaintiff, v. ACCU-TRADE, LLC, et al., Defendants.

CORE TERMS

authorization, personal jurisdiction, server, accessed, allegations, contacts, negotiations, courts, exceeds, parties, tortious conduct, motion to dismiss, long-arm, nonresident, forum state, permission, minimum contact, platform, argues, purposefully, proprietary, Internet, effects, pleaded, reasons, holds, principal place of business, reasonable inference, cause of action, computer system

Civil Procedure, Responses, Defenses, Demurrers & Objections, Motions to Dismiss, Jurisdiction, In Rem & Personal Jurisdiction, Constitutional Limits, Constitutional Law, Fundamental Rights, Procedural Due Process, Scope of Protection, In Personam Actions, Long Arm Jurisdiction, Minimum Contacts, Due Process, Motions to Dismiss, Failure to State Claim, Pleadings, Complaints, Requirements for Complaint, Doing Business, Computer & Internet Law, In Personam Jurisdiction, Internet Business, Jurisdiction, Torts, Procedural Matters, Commencement & Prosecution, In Personam Jurisdiction, Criminal Offenses, Computer Fraud & Abuse Act, Business & Corporate Compliance, Computer & Internet Law, Data Crimes & Fraud