ANSWER to Complaint byPlaid Inc.. (Sessions, Justina) (Filed on… — United States v. Visa Inc. and Plaid Inc. (Dkt. 52)

Summary

This is Defendant Plaid Inc.'s Answer to Complaint in United States of America v. Visa Inc. and Plaid Inc., Case No. 4:20-cv-07810-JSW. Plaid states that any allegation in the Complaint not expressly and explicitly admitted is denied, and admits that its technology provides connections to more than 11,000 financial institutions in the United States. Its Preliminary Statement says the case is premised on the government's speculation about an online debit service, and that Plaid has no online debit service and no plans to develop one. In its numbered paragraph responses, Plaid states that it lacks information or knowledge sufficient to respond to the allegations and denies them.

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DEFENDANT PLAID INC.’S ANSWER TO COMPLAINT  
CASE NO.: 4:20-cv-07810-JSW 
 
Jonathan M. Jacobson, SBN 1350495 
WILSON SONSINI GOODRICH & ROSATI 
Professional Corporation 
1301 Avenue of the Americas, 40th Floor 
New York, New York 10019 
Telephone: (212) 497-7758 
Facsimile: (212) 999-5899 
Email: jjacobson@wsgr.com 
 
Justina K. Sessions, SBN 270914 
Benjamin S. Labow, SBN 229443 
WILSON SONSINI GOODRICH & ROSATI 
Professional Corporation 
One Market Plaza, Spear Tower, Suite 3300 
San Francisco, California 94105 
Telephone: (415) 947-2000 
Facsimile: (415) 947-2099 
Email: jsessions@wsgr.com 
Email: blabow@wsgr.com 
 
 
Counsel for Defendant Plaid Inc. 
Scott A. Sher, SBN 190053 
Michelle Yost Hale (pro hac vice) 
Robin S. Crauthers (pro hac vice) 
Katie R. Glynn, SBN 300524 
WILSON SONSINI GOODRICH & ROSATI 
Professional Corporation 
1700 K Street NW, Fifth Floor 
Washington, DC 20006 
Telephone: (202) 973-8800 
Facsimile: (202) 973-8899 
Email: ssher@wsgr.com 
Email: mhale@wsgr.com 
Email: rcrauthers@wsgr.com 
Email: kglynn@wsgr.com 
 
 
 
 
UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF CALIFORNIA 
 
 
UNITED STATES OF AMERICA, 
 
Plaintiff, 
 
v. 
 
VISA INC. and PLAID INC., 
 
Defendants. 
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CASE NO.: 4:20-cv-07810-JSW 
 
DEFENDANT PLAID INC.’S 
ANSWER TO COMPLAINT 
 
 
 
 
 
 
 
 
 
 
Case 4:20-cv-07810-JSW   Document 52   Filed 11/27/20   Page 1 of 16

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DEFENDANT PLAID INC.’S ANSWER TO COMPLAINT  
CASE NO.: 4:20-cv-07810-JSW 
 
ANSWER OF DEFENDANT PLAID INC. 
Defendant Plaid Inc. (“Plaid”), by and through its undersigned counsel, responds to the 
allegations in the Complaint as set forth below.  Any allegation in the Complaint not expressly 
and explicitly admitted herein is denied.  To the extent substantive factual allegations embodied 
in the boldface headings from the Complaint reproduced below require a response, Plaid denies 
them.  To the extent the introductory statement in the Complaint requires a response, Plaid 
admits that its technology provides connections to more than 11,000 financial institutions in the 
United States, and denies the remainder of the allegations therein.  Plaid reserves the right to 
amend this Answer. 
PRELIMINARY STATEMENT 
 
This entire case is premised on the government’s speculation that, if not acquired by 
Visa, Plaid would develop and successfully launch an online debit service that would facilitate 
transactions between consumers and merchants in competition with Visa.  But Plaid, a data 
aggregation company with no prior payments experience, does not have any online debit 
service nor any plans to develop one.  The complaint mischaracterizes Plaid’s research and 
development efforts related to money movement, and grossly overstates Plaid’s potential to 
compete in online debit while conveniently ignoring the many other companies that already 
offer or would be better-suited than Plaid to offer such products and services.  For this and 
many other reasons, Plaid’s acquisition by Visa does not threaten competition or violate the 
antitrust laws.  
RESPONSE TO SPECIFIC ALLEGATIONS 
INTRODUCTION 
1. 
ANSWER:  Plaid lacks information or knowledge sufficient to respond or form a 
belief as to the allegations in Paragraph 1 and on that basis denies them. 
2. 
ANSWER:  Plaid lacks information or knowledge sufficient to respond or form a 
belief as to the allegations in Paragraph 2 and on that basis denies them. 
3. 
ANSWER:  Plaid admits that American consumers use various payment options, 
including debit and credit cards, to purchase goods and services on the internet.  Plaid lacks 
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DEFENDANT PLAID INC.’S ANSWER TO COMPLAINT  
CASE NO.: 4:20-cv-07810-JSW 
 
information or knowledge sufficient to respond or form a belief as to the remainder of the 
allegations in Paragraph 3 and on that basis denies them. 
4. 
ANSWER:  To the extent Paragraph 4 purports to quote Visa documents or 
testimony, Plaid lacks information or knowledge sufficient to respond or form a belief as to these 
allegations and on that basis denies them.  Paragraph 4 states legal arguments, conclusions and 
other non-factual statements to which no response is required.  To the extent a response is 
deemed necessary, Plaid lacks information or knowledge sufficient to respond or form a belief as 
to these allegations and on that basis denies them.   
5. 
ANSWER:  Paragraph 5 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid lacks information or knowledge sufficient to respond or form a belief as to the 
allegations in Paragraph 5 and on that basis denies them. 
6. 
ANSWER:  Paragraph 6 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid lacks information or knowledge sufficient to respond or form a belief as to the 
allegations in the first sentence and on that basis denies them.  Plaid denies the allegations in the 
second sentence of Paragraph 6. 
7. 
ANSWER:  Plaid admits its existing customers include Venmo, Acorns, and 
Betterment.  Plaid admits that its technology helps enable connections to more than 11,000 
financial institutions in the United States, and that over 200 million accounts have been linked 
via Plaid.  Paragraph 7 states legal arguments, conclusions and other non-factual statements to 
which no response is required.  To the extent a response is deemed necessary, Plaid denies the 
remainder of the allegations in Paragraph 7. 
8. 
ANSWER:  Plaid admits that it does not compete with Visa.  To the extent 
Paragraph 8 purports to quote from Plaid documents, Plaintiff’s selective quotation or 
paraphrasing of incompletely identified written material, testimony or communications, offered 
without context, is misleading as framed in the Complaint, and therefore Plaid denies such 
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DEFENDANT PLAID INC.’S ANSWER TO COMPLAINT  
CASE NO.: 4:20-cv-07810-JSW 
 
allegations.  Paragraph 8 states legal arguments, conclusions and other non-factual statements to 
which no response is required.  Plaid denies the remainder of the allegations in Paragraph 8.   
9. 
ANSWER:  To the extent Paragraph 9 purports to quote Visa documents or 
testimony, Plaid lacks information or knowledge sufficient to respond or form a belief as to these 
allegations and on that basis denies them.  Paragraph 9 states legal arguments, conclusions and 
other non-factual statements to which no response is required.  To the extent a response is 
deemed necessary, Plaid lacks information or knowledge sufficient to respond or form a belief as 
to the remainder of the allegations and on that basis denies them.   
10. 
ANSWER:  To the extent Paragraph 10 purports to quote Visa documents or 
testimony, Plaid lacks information or knowledge sufficient to respond or form a belief as to these 
allegations and on that basis denies them.  Plaid lacks information or knowledge sufficient to 
respond or form a belief as to the remainder of the allegations in Paragraph 10 and on that basis 
denies them.   
11. 
ANSWER:  To the extent Paragraph 11 purports to quote Visa documents or 
testimony, Plaid lacks information or knowledge sufficient to respond or form a belief as to these 
allegations and on that basis denies them.  Plaid lacks information or knowledge sufficient to 
respond or form a belief as to the remainder of the allegations in Paragraph 11 and on that basis 
denies them.   
12. 
ANSWER:  Plaid admits that Visa agreed to acquire Plaid for $5.3 billion on 
January 13, 2020.  To the extent Paragraph 12 purports to quote Visa documents or testimony, 
Plaid lacks information or knowledge sufficient to respond or form a belief as to these 
allegations and on that basis denies them.  Paragraph 12 states legal arguments, conclusions and 
other non-factual statements to which no response is required.  To the extent a response is 
deemed necessary, Plaid lacks information or knowledge sufficient to respond or form a belief as 
to the remainder of the allegations in Paragraph 12 and on that basis denies them.   
13. 
ANSWER:  Paragraph 13 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid denies the allegations in Paragraph 13. 
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DEFENDANT PLAID INC.’S ANSWER TO COMPLAINT  
CASE NO.: 4:20-cv-07810-JSW 
 
14. 
ANSWER:  Paragraph 14 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid denies the allegations in Paragraph 14. 
JURISDICTION 
15. 
ANSWER:  Paragraph 15 states legal conclusions and other non-factual 
statements to which no response is required.  To the extent a response is deemed necessary, Plaid 
does not contest that the court has subject-matter jurisdiction over this dispute and on that basis 
admits that the Court has jurisdiction in this matter.  Plaid denies that Visa’s acquisition of Plaid 
violates Section 2 of the Sherman Act or Section 7 of the Clayton Act. 
16. 
ANSWER:  Paragraph 16 states legal conclusions and other non-factual 
statements to which no response is required.  To the extent a response is deemed necessary, Plaid 
denies that it “sell[s] online debit” services.  Plaid admits that it provides data aggregation 
services throughout the United States.  Plaid lacks information or knowledge sufficient to 
respond or form a belief as to the remainder of the allegations in Paragraph 16 and on that basis 
denies them. 
17. 
ANSWER:  Paragraph 17 states legal conclusions and other non-factual 
statements to which no response is required.  To the extent a response is deemed necessary, Plaid 
denies that it transacts business through the “sales of online debit transactions.”  Plaid admits the 
remainder of the allegations pertaining to Plaid in Paragraph 17.  Plaid otherwise lacks 
information or knowledge sufficient to respond or form a belief as to the remainder of the 
allegations in Paragraph 17 and on that basis denies them. 
VENUE 
18. 
ANSWER:  Paragraph 18 states legal conclusions and other non-factual 
statements to which no response is required.  To the extent a response is deemed necessary, Plaid 
does not contest that venue is proper in this district and on that basis admits the allegations in 
Paragraph 18 pertaining to Plaid.  Plaid otherwise lacks information or knowledge sufficient to 
respond or form a belief as to the remainder of the allegations in Paragraph 18 and on that basis 
denies them.  
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DEFENDANT PLAID INC.’S ANSWER TO COMPLAINT  
CASE NO.: 4:20-cv-07810-JSW 
 
INTRADISTRICT ASSIGNMENT 
19. 
ANSWER:  Paragraph 19 states legal conclusions and other non-factual 
statements to which no response is required.  To the extent a response is deemed necessary, Plaid 
admits its headquarters and principal place of business is located in San Francisco County.  Plaid 
lacks information or knowledge sufficient to respond or form a belief as to the remainder of the 
allegations in Paragraph 19 and on that basis denies them. 
DEFENDANTS AND THE PROPOSED ACQUISITION 
20. 
ANSWER:  Plaid lacks information or knowledge sufficient to respond or form a 
belief as to the allegations in Paragraph 20 and on that basis denies them.   
21. 
ANSWER:  Plaid admits that it is a Delaware company headquartered in San 
Francisco, California, and that it operates a financial data aggregation platform in the United 
States.  Plaid admits that its technology allows people to connect data from their financial 
institutions to financial technology (“fintech”) apps.  As a private company, Plaid’s revenue is 
not public information and the Complaint’s allegation regarding Plaid’s revenue is not precise; 
on these bases, Plaid denies the allegation.  Plaid denies the remainder of the allegations in 
Paragraph 21. 
22. 
ANSWER:  Plaid admits the allegations in Paragraph 22. 
BACKGROUND 
23. 
ANSWER:  Plaid lacks information or knowledge sufficient to respond or form a 
belief as to the allegations in Paragraph 23 and on that basis denies them. 
24. 
ANSWER:  Plaid lacks information or knowledge sufficient to respond or form a 
belief as to the allegations in Paragraph 24 and on that basis denies them. 
A. 
Visa is a Monopolist in Online Debit Services 
25. 
ANSWER:  Paragraph 25 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid lacks information or knowledge sufficient to respond or form a belief as to the 
factual allegations in Paragraph 25 and on that basis denies them. 
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DEFENDANT PLAID INC.’S ANSWER TO COMPLAINT  
CASE NO.: 4:20-cv-07810-JSW 
 
26. 
ANSWER:  Paragraph 26 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid lacks information or knowledge sufficient to respond or form a belief as to the 
remainder of the allegations in Paragraph 26 and on that basis denies them.  
27. 
ANSWER:  Paragraph 27 states legal conclusions and other non-factual 
statements to which no response is required.  To the extent a response is deemed necessary, Plaid 
lacks information or knowledge sufficient to respond or form a belief as to the factual allegations 
in Paragraph 27 and on that basis denies them. 
28. 
ANSWER:  Plaid lacks information or knowledge sufficient to respond or form a 
belief as to the allegations in Paragraph 28 and on that basis denies them. 
29. 
ANSWER:  Plaid lacks information or knowledge sufficient to respond or form a 
belief as to the allegations in Paragraph 29 and on that basis denies them. 
30. 
ANSWER:  Plaid admits that Congress enacted the Durbin Amendment of the 
2010 Dodd-Frank Wall Street Reform and Consumer Protection Act, Pub. L. No. 111-203, 124 
Stat. 1376 (2010).  Paragraph 30 states legal conclusions and other non-factual statements to 
which no response is required.  To the extent a response is deemed necessary, Plaid lacks 
information or knowledge sufficient to respond or form a belief as to the remainder of the 
allegations in Paragraph 30 and on that basis denies them. 
31. 
ANSWER: Paragraph 31 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid lacks information or knowledge sufficient to respond or form a belief as to the 
allegations in Paragraph 31. 
32. 
ANSWER:  Plaid admits the allegations in the first sentence.  Paragraph 32 states 
legal arguments, conclusions and other non-factual statements to which no response is required.  
To the extent a response is deemed necessary, Plaid lacks information or knowledge sufficient to 
respond or form a belief as to the remainder of the allegations in Paragraph 32 and on that basis 
denies them. 
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DEFENDANT PLAID INC.’S ANSWER TO COMPLAINT  
CASE NO.: 4:20-cv-07810-JSW 
 
B. 
Pay-by-Bank is a New Form of Online Debit Service that Threatens Visa’s  
 
 
Monopoly 
33. 
ANSWER:  Plaid denies the allegations in the first sentence of Paragraph 33.  
Plaid lacks information or knowledge sufficient to respond or form a belief as to the remainder of 
the allegations in Paragraph 33. 
34. 
ANSWER:  Plaid admits that pay-by-bank services are available in other 
countries.  Plaid admits that pay-by-bank debit services can utilize Automated Clearing House.  
Plaid lacks information or knowledge sufficient to respond or form a belief as to the remainder of 
the allegations in Paragraph 34. 
35. 
ANSWER:  The second sentence of Paragraph 35 states legal arguments, 
conclusions and other non-factual statements to which no response is required.  To the extent a 
response is deemed necessary, Plaid denies the allegations.  Plaid lacks information or 
knowledge sufficient to form a belief as to the remainder of the allegations in Paragraph 35. 
36. 
ANSWER:  Plaid lacks information or knowledge sufficient to respond or form a 
belief as to the allegations in Paragraph 36 and on that basis denies them.  
C. 
Plaid is Uniquely Situated to Challenge Visa 
37. 
ANSWER:  Plaid admits that it provides technology that enables end users to 
share data from their financial accounts with the fintech apps of their choosing.  Plaid admits that 
fintech apps using Plaid’s technology include apps that offer personal financial management 
tools, manage bill payments or other expenses, support loan underwriting, and transfer funds.  
Plaid admits that the data Plaid retrieves from financial institutions, with end-users’ permission, 
varies depending on the specific Plaid product used by the fintech app, as well as the information 
made available by the applicable financial institution, but can include account information (e.g., 
account and routing number), transaction history, and account balances.  Plaid denies the 
remainder of the allegations in Paragraph 37. 
38. 
ANSWER:  Plaid admits that it connects to more than 11,000 financial 
institutions in the US, that it supports over 2,600 fintech apps, and that over 200 million accounts 
have been linked via Plaid.  Paragraph 38 states legal arguments, conclusions and other non-
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DEFENDANT PLAID INC.’S ANSWER TO COMPLAINT  
CASE NO.: 4:20-cv-07810-JSW 
 
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid denies them.  Plaid denies the remainder of the allegations in Paragraph 38. 
39. 
ANSWER:  Plaid denies that its fintech customers face substantial switching 
costs once they integrate with Plaid.  To the extent Paragraph 39 purports to quote Visa 
documents or testimony, Plaid lacks information or knowledge sufficient to respond or form a 
belief as to these allegations and on that basis denies them.  Paragraph 39 states legal arguments, 
conclusions and other non-factual statements to which no response is required.  To the extent a 
response is deemed necessary, Plaid lacks information or knowledge sufficient to respond to the 
remainder of the allegations in Paragraph 39 and on that basis denies them.   
40. 
ANSWER:  Plaid denies the allegations in Paragraph 40.  To the extent 
Paragraph 40 purports to quote from Plaid documents, Plaintiff’s selective quotation or 
paraphrasing of incompletely identified written material, testimony or communications, offered 
without context, is misleading as framed in the Complaint, and therefore Plaid denies such 
allegations.   
41. 
ANSWER:  Plaid admits that it has not deployed a pay-by-bank solution.  Plaid 
denies the remaining allegations in Paragraph 41.  Paragraph 41 states legal arguments, 
conclusions and other non-factual statements to which no response is required.  To the extent a 
response is deemed necessary, Plaid denies them. 
D.  
Visa Intends to Buy Plaid to Extinguish this Threat and Protect its U.S.  
 
 
Online Debit Monopoly 
42. 
ANSWER:  Plaid admits the facts in the first and the third sentences of Paragraph 
42.  Plaid denies the allegations in the second sentence of Paragraph 42.  Paragraph 42 states 
legal arguments, conclusions and other non-factual statements to which no response is required.  
To the extent a response is deemed necessary, Plaid lacks information or knowledge sufficient to 
respond or form a belief as to the allegations in the fourth sentence of Paragraph 42 and on that 
basis denies them. 
43. 
ANSWER:  To the extent Paragraph 43 purports to quote Visa documents or 
testimony, Plaid lacks information or knowledge sufficient to respond or form a belief as to these 
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DEFENDANT PLAID INC.’S ANSWER TO COMPLAINT  
CASE NO.: 4:20-cv-07810-JSW 
 
allegations and on that basis denies them.  Paragraph 43 states legal arguments, conclusions and 
other non-factual statements to which no response is required.  To the extent a response is 
deemed necessary, Plaid lacks information or knowledge sufficient to respond or form a belief as 
to the remainder of the allegations in Paragraph 43 and on that basis denies them.   
44. 
ANSWER:  Plaid admits that Visa and Plaid convened a meeting involving 
executives from both companies in early November 2019, and that Plaid’s co-founder attended.  
To the extent Paragraph 44 purports to quote Visa documents or testimony, Plaid lacks 
information or knowledge sufficient to respond or form a belief as to these allegations and on 
that basis denies them.  Paragraph 44 states legal arguments, conclusions and other non-factual 
statements to which no response is required.  To the extent a response is deemed necessary, Plaid 
lacks information or knowledge sufficient to respond or form a belief as to the remainder of the 
allegations in Paragraph 44 and on that basis denies them.   
E. 
Visa Has a History of Impeding Entry and Expansion into Online Debit  
 
 
Services 
45. 
ANSWER:  Plaid lacks information or knowledge sufficient to respond or form a 
belief as to the factual allegations in Paragraph 45 and on that basis denies them. 
46. 
ANSWER:  To the extent Paragraph 46 purports to quote Visa documents or 
testimony, Plaid lacks information or knowledge sufficient to respond or form a belief as to these 
allegations and on that basis denies them.  Paragraph 46 states legal arguments, conclusions and 
other non-factual statements to which no response is required.  To the extent a response is 
deemed necessary, Plaid lacks information or knowledge sufficient to respond or form a belief as 
to the remainder of the allegations in Paragraph 46 and on that basis denies them. 
47. 
ANSWER:  To the extent Paragraph 47 purports to quote Visa documents or 
testimony, Plaid lacks information or knowledge sufficient to respond or form a belief as to these 
allegations and on that basis denies them.  Plaid lacks information or knowledge sufficient to 
respond or form a belief as to the remainder of the allegations in Paragraph 47 and on that basis 
denies them.   
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DEFENDANT PLAID INC.’S ANSWER TO COMPLAINT  
CASE NO.: 4:20-cv-07810-JSW 
 
48. 
ANSWER:  To the extent Paragraph 48 purports to quote Visa documents or 
testimony, Plaid lacks information or knowledge sufficient to respond or form a belief as to these 
allegations and on that basis denies them.  Plaid lacks information or knowledge sufficient to 
respond or form a belief as to the remainder of the allegations in Paragraph 48 and on that basis 
denies them. 
49. 
ANSWER:  Plaid lacks information or knowledge sufficient to respond or form a 
belief as to the allegations in Paragraph 49 and on that basis denies them. 
50. 
ANSWER:  Paragraph 50 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid lacks information or knowledge sufficient to respond or form a belief as to the 
factual allegations in Paragraph 50 and on that basis denies them. 
RELEVANT MARKET 
A. 
Product Market 
51. 
ANSWER:  Plaid lacks information or knowledge sufficient to respond or form a 
belief as to the allegations in the first, second, and third sentences.  Paragraph 51 states legal 
conclusions and other non-factual statements to which no response is required.  To the extent a 
response is deemed necessary, Plaid denies the remainder of the allegations in Paragraph 51. 
52. 
ANSWER:  Paragraph 52 states legal conclusions and other non-factual 
statements to which no response is required.  To the extent a response is deemed necessary, Plaid 
denies the allegations in Paragraph 52. 
53. 
ANSWER:  Paragraph 53 states legal conclusions and other non-factual 
statements to which no response is required.  To the extent a response is deemed necessary, Plaid 
denies the allegations in Paragraph 53. 
54. 
ANSWER:  Paragraph 54 states legal conclusions and other non-factual 
statements to which no response is required.  To the extent a response is deemed necessary, Plaid 
denies them.   
55. 
ANSWER:  Plaid lacks information or knowledge sufficient to respond or form a 
belief as to the allegations in the third and fourth sentences and on that basis denies them.  
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DEFENDANT PLAID INC.’S ANSWER TO COMPLAINT  
CASE NO.: 4:20-cv-07810-JSW 
 
Paragraph 55 states legal arguments, conclusions and other non-factual statements to which no 
response is required.  To the extent a response is deemed necessary, Plaid denies them.  Plaid 
denies the remainder of the allegations in Paragraph 55. 
56. 
ANSWER:  Paragraph 56 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid denies them. 
57. 
ANSWER:  Paragraph 57 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid denies them. 
58. 
ANSWER:  Paragraph 58 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid denies them.  Plaid lacks information or knowledge sufficient to respond or 
form a belief as to the remainder of the allegations in Paragraph 58 and on that basis denies 
them. 
B.  
Geographic Market 
59. 
ANSWER:  Paragraph 59 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid denies the factual allegations in Paragraph 59. 
ANTICOMPETITIVE EFFECTS 
60. 
ANSWER:  Paragraph 60 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid denies the factual allegations in Paragraph 60. 
A. 
Visa’s Proposed Acquisition of Plaid Would Result in Higher Prices for  
 
 
Online Debit Transactions 
61. 
ANSWER:  Plaid denies the allegations in Paragraph 61. 
62. 
ANSWER:  Plaid lacks information or knowledge sufficient to respond or form a 
belief as to the allegations in sentences one, two, and five in paragraph 62.  Plaid denies the 
allegation in sentence three which states that a consumer could switch to Plaid’s pay-by-bank 
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DEFENDANT PLAID INC.’S ANSWER TO COMPLAINT  
CASE NO.: 4:20-cv-07810-JSW 
 
service during the check-out process.  Plaid lacks information or knowledge sufficient to respond 
or form a belief as to the remainder of the allegations in sentence three.  Plaid denies the 
allegations in sentence four. 
63. 
ANSWER:  Plaid denies the allegations in Paragraph 63.  To the extent 
Paragraph 63 purports to quote from Plaid documents, Plaintiff’s selective quotation or 
paraphrasing of incompletely identified written material, testimony or communications, offered 
without context, is misleading as framed in the Complaint, and therefore Plaid denies such 
allegations.  To the extent Paragraph 63 purports to quote Visa documents or testimony, Plaid 
lacks information or knowledge sufficient to respond or form a belief as to such allegations and 
on that basis denies them. 
64. 
ANSWER:  Plaid denies the allegations in Paragraph 64. 
65. 
ANSWER:  Paragraph 65 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid denies the allegations in Paragraph 65. 
B. 
Visa’s Proposed Acquisition of Plaid Would Result in Less Innovation 
66. 
ANSWER:  To the extent Paragraph 66 purports to quote Visa documents or 
testimony, Plaid lacks information or knowledge sufficient to respond or form a belief as to these 
allegations and on that basis denies them.  Plaid denies the remainder of the allegations in 
Paragraph 66. 
67. 
ANSWER:  To the extent Paragraph 67 purports to quote Visa documents or 
testimony, Plaid lacks information or knowledge sufficient to respond or form a belief as to these 
allegations and on that basis denies them.  Plaid denies the allegations in the last sentence of 
Paragraph 67.  Plaid lacks information or knowledge sufficient to respond or form a belief as to 
the remainder of the allegations in Paragraph 67 and on that basis denies them.   
C. 
Visa’s Proposed Acquisition of Plaid Would Raise Entry Barriers 
68. 
ANSWER:  Paragraph 68 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
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DEFENDANT PLAID INC.’S ANSWER TO COMPLAINT  
CASE NO.: 4:20-cv-07810-JSW 
 
necessary, Plaid lacks information or knowledge sufficient to respond or form a belief as to the 
allegations in Paragraph 68 and on that basis denies them. 
69. 
ANSWER:  Paragraph 69 states legal conclusions and other non-factual 
statements to which no response is required.  To the extent a response is deemed necessary, Plaid 
denies the allegations in Paragraph 69. 
70. 
ANSWER:  To the extent Paragraph 70 purports to quote Visa documents or 
testimony, Plaid lacks information or knowledge sufficient to respond or form a belief as to these 
allegations and on that basis denies them.  Plaid lacks information or knowledge sufficient to 
respond or form a belief as to the remainder of the allegations in Paragraph 70 and on that basis 
denies them. 
71. 
ANSWER:  To the extent Paragraph 71 purports to quote Visa documents or 
testimony, Plaid lacks information or knowledge sufficient to respond or form a belief as to these 
allegations and on that basis denies them.  Plaid lacks information or knowledge sufficient to 
respond or form a belief as to the remainder of the allegations in Paragraph 71 and on that basis 
denies them. 
72. 
ANSWER:  Plaid denies the allegations in Paragraph 72. 
73. 
ANSWER:  Paragraph 73 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid denies the factual allegations in Paragraph 73. 
LACK OF COUNTERVAILING FACTORS 
74. 
ANSWER:  Plaid admits that the proposed acquisition would generate synergies 
by combining the operations of Visa and Plaid.  To the extent Paragraph 74 purports to quote 
Visa documents or testimony, Plaid lacks information or knowledge sufficient to respond or form 
a belief as to these allegations and on that basis denies them.  Paragraph 74 states legal 
arguments, conclusions and other non-factual statements to which no response is required.  To 
the extent a response is deemed necessary, Plaid lacks information or knowledge sufficient to 
respond or form a belief as to the allegations  and on that basis denies them.  Plaid denies the 
remainder of the allegations in Paragraph 74. 
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DEFENDANT PLAID INC.’S ANSWER TO COMPLAINT  
CASE NO.: 4:20-cv-07810-JSW 
 
75. 
ANSWER:  Paragraph 75 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid denies the allegations in Paragraph 75. 
VIOLATIONS ALLEGED 
76. 
ANSWER:  Paragraph 76 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid denies the allegations in Paragraph 76. 
77. 
ANSWER:  Paragraph 77 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid denies the allegations in Paragraph 77. 
78. 
ANSWER:  Paragraph 78 states legal arguments, conclusions and other non-
factual statements to which no response is required.  To the extent a response is deemed 
necessary, Plaid denies the allegations in Paragraph 78. 
REQUEST FOR RELIEF 
79. 
ANSWER:  The allegations in Paragraph 79 are requests for relief to which no 
response is required.  To the extent a response is deemed necessary, Plaid denies the allegations. 
DEFENSES 
Plaid reserves the right to assert and rely upon any other defenses that may become 
available or known to Plaid throughout the course of this action, and to amend, or seek to 
amend, its answer or defenses. 
PRAYER FOR RELIEF 
WHEREFORE, having fully answered the Complaint, Plaid respectfully requests that 
the Court:  
(1) deny the Complaint’s contemplated relief;  
(2) dismiss the Complaint in its entirety with prejudice;  
(3) award Plaid its costs of suit, including expert’s fees and reasonable attorneys’ fees, 
 
as may be allowed by law; and  
(4) award each other or further relief as the Court may deem just and proper. 
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DEFENDANT PLAID INC.’S ANSWER TO COMPLAINT  
CASE NO.: 4:20-cv-07810-JSW 
 
DATED: November 27, 2020  
WILSON SONSINI GOODRICH & ROSATI P.C. 
   /s/ Justina Sessions   
 
.           
Justina Sessions 
Counsel for Defendant Plaid Inc. 
Case 4:20-cv-07810-JSW   Document 52   Filed 11/27/20   Page 16 of 16

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