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Home Court filings United States of America v. Visa Inc. — S.D.N.Y., No. 1:24-cv-07214-JGK LETTER MOTION for Conference on January 6, 2025 to Remain Scheduled addressed to… — Uni…

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LETTER MOTION for Conference on January 6, 2025 to Remain Scheduled addressed to… — United States v. Visa Inc. (Dkt. 28)

Record facts

CourtU.S. District Court for the Southern District of New York
Filed2024-11-08

U.S. District Court for the Southern District of New York · No. 1:24-cv-07214-JGK · Doc. 28 · 2024-11-08 · Docket on CourtListener

Full text

Liberty Square Building 
 
450 5th Street, N.W. 
Washington, DC 20530 
 
November 8, 2024 
 
Via ECF 
 
Honorable John G. Koeltl 
United States District Judge 
Southern District of New York 
500 Pearl Street 
New York, NY 10007 
 
Re: 
United States of America v. Visa Inc., Case No. 1:24-cv-07214-JGK 
 
Dear Judge Koeltl: 
 
Plaintiff, the United States, requests that discovery proceed while Defendant Visa’s 
anticipated motion to dismiss is pending.  The Parties jointly proposed a briefing schedule for 
Visa’s anticipated motion to dismiss, which, if amenable to the Court, contemplates briefing 
concluding on February 7, 2025.  ECF No. 23.  During conferrals regarding this schedule, a 
dispute has arisen regarding the status of discovery while Visa’s anticipated motion to dismiss is 
pending.  Because this dispute may impact other upcoming deadlines, namely the Initial 
Conference currently scheduled for January 6, 2025, the United States writes now to request that 
discovery proceed while Visa’s motion to dismiss is pending and that the January 6 Initial 
Conference go forward as scheduled.  The conduct described in the Complaint is ongoing, 
significant, and affects over $4 trillion in commerce annually.  Proceeding expeditiously in this 
matter, even in the face of a motion to dismiss, is not only routine in similar public enforcement 
matters, but is expressly contemplated by Congress for antitrust matters. Should the Court have 
any concerns about the United States’ proposed approach, we are available to address any of 
those concerns at Tuesday’s pre-motion conference or after the Court has reviewed Visa’s pre-
motion to dismiss letter, which it will file on November 20, 2024. 
 
“Congress recognizes ‘the primacy of antitrust enforcement actions brought by the 
United States, and that such actions are of special urgency and serve a different purpose than 
private damages suits because they seek to enjoin ongoing anticompetitive conduct.’” United 
States v. Agri Stats, Inc., Case No. 0:23-cv-03009-JRT-JFD, 2024 U.S. Dist. LEXIS 109388, at 
*21 (D. Minn. May 17, 2024) (quoting United States v. Dentsply, 190 F.R.D. 140, 144–45 (D. 
Del. 1999)).  For this reason, Congress directed in Section 4 of the Sherman Act that federal 
courts “shall proceed, as soon as may be, to the hearing and determination” of antitrust cases 
Case 1:24-cv-07214-JGK     Document 28     Filed 11/08/24     Page 1 of 3

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brought by the United States. 15 U.S.C. § 4.  The Parties’ ability to conduct discovery is an 
essential element to the expeditious administration of these matters. 
   
 
Courts have recognized the importance of discovery in connection with this 
Congressional direction.  In Agri Stats, the court relied on Section 4 of the Sherman Act in 
denying a request to stay discovery pending resolution of a motion to dismiss.  The court 
recognized the “public interest in swift determination of the action,” which involved alleged 
“ongoing harm to consumers.”  2024 U.S. Dist. LEXIS 109388, at *22.  As that court held, “[a] 
delay in discovery will delay judgment in this action, which is exactly what Congress sought to 
avoid.”  Id. at *21-22; see also United States v. Google, LLC, 661 F. Supp. 3d 480, 489 (E.D. Va. 
2023) (denying motion to transfer venue to district where private multi-district litigation was 
pending, recognizing that “Congress made the decision to subordinate concerns about judicial 
economy to the government and public’s interest in efficient resolution of antitrust enforcement 
actions without delay”); United States v. Google, LLC, No. 1:20-cv-3010 (D.D.C. Nov. 18, 2020) 
(ordering parties to hold Rule 26(f) conference by December 11, 2020 – 51 days after complaint 
filed); United States v. Live Nation Entertainment, Inc., No. 1:24-cv-3973 (S.D.N.Y. June 27, 
2024) (entering case management plan and scheduling order 35 days after complaint filed, even 
though defendant filed motion to transfer and motion to dismiss).  This case is also a civil 
antitrust enforcement case brought by the United States.  Here, the United States seeks to enjoin 
ongoing conduct affecting millions of American consumers.  The conduct challenged here 
specifically impacts the entire debit industry in the United States, a market in which consumers 
make, on average, over $10 billion in purchases daily.   
 
Another court in this district has also recognized that “the Sherman Act grants priority 
status to the Government’s claims” in antitrust cases.  Texas v. Penguin Grp. (USA), Inc., No. 12 
Civ. 3394 (DLC), 2013 U.S. Dist. LEXIS 58925, at *4 (S.D.N.Y. Apr. 24, 2013).  In holding that 
the antitrust action brought by the federal government “may not be slowed as a result of any 
related [] action,” Judge Cote relied on Section 4 of the Sherman Act: “It instructs that in 
antitrust actions commenced by the Government, ‘the court shall proceed, as soon as may be, to 
the hearing and determination of the case.’” Id. (quoting 15 U.S.C. § 4). 
 
As courts in this district have repeatedly held, “discovery should not be routinely stayed 
simply on the basis that a motion to dismiss has been filed.”  Republic of Turkey v. Christie’s, 
Inc., 316 F. Supp. 3d 675, 677 (S.D.N.Y. 2018) (citing Hong Leong Fin. Ltd. (Singapore), 297 
F.R.D. 69, 72 (S.D.N.Y. 2013)) (alterations in original).  Rather, a party seeking a stay of 
discovery bears the burden to show good cause.  Id. (citing Brown v. Astoria Fed. Sav. & Loan 
Ass’n, 444 Fed. Appx. 504, 505 (2d Cir. 2011).  In considering such a motion, courts consider the 
strength of the pending motion, the breadth of discovery and burden of responding, and the 
prejudice that would result to the party opposing the stay.  Id.  The court in Agri Stats applied 
similar factors and concluded a motion to stay was not warranted.  Notwithstanding the 
defendant’s argument that discovery imposed a “real burden,” the court denied the stay because 
of the “low likelihood” the motion to dismiss would dispose of discovery and because 
“[r]equiring the United States and other Plaintiffs to wait to gather evidence and pursue their case 
Case 1:24-cv-07214-JGK     Document 28     Filed 11/08/24     Page 2 of 3

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will burden not only Plaintiffs, but the public interest in swift determination of the action.”  2024 
U.S. Dist. LEXIS 109388, at *21-22. 
 
The Parties conferred on October 24, November 5, and November 8 about their 
respective positions regarding the timing and scope of discovery and disagree as to whether 
discovery should begin while any motion to dismiss is pending.  The United States has proposed 
holding the Rule 26(f) conference at any time convenient for Visa before December 16, 2024 (21 
days prior to the Initial Conference scheduled for January 6, 2025) and opening discovery, as 
contemplated by the Federal Rules of Civil Procedure, in January 2025.  Given the ongoing harm 
to consumers, we believe that any delay in commencing discovery, which Visa has suggested, 
fails to serve the public interest and is contrary to Congress’s intent.   
 
 
As set forth in the Complaint, the United States contends that Visa has maintained its 
monopoly in debit card markets by foreclosing its smaller rivals’ ability to compete effectively 
through its contracts with banks and merchants, which penalize them if they use smaller 
networks instead of Visa.  The United States further contends that Visa has entered agreements 
with potential competitors—such as Apple—that provide lucrative incentives but only if those 
potential competitors do not develop products that would compete with Visa.  Although the 
United States will propose an expeditious schedule for litigating this case, preparing this case for 
trial will still require many months.  During that time, Visa’s anticompetitive conduct will 
continue, and the public will bear the harm of any delay, including delay in gathering evidence. 
 
Because Congress has directed that antitrust actions brought by the federal government 
should “proceed, as soon as may be” to trial (see 15 U.S.C. § 4), the United States respectfully 
requests that the Initial Conference remain as scheduled on January 6, 2025 so that the Rule 26(f) 
conference may occur in December.  As set forth in the jointly submitted briefing schedule, Visa 
will submit its letter requesting permission to file its motion to dismiss by November 20, 2024.  
ECF No. 23.  The United States will provide its own response to that letter no later than 
November 25, 2024 and will be prepared to discuss the importance of expeditiously commencing 
discovery at Tuesday’s conference and any pre-motion conference the Court may schedule after 
Visa files its letter on November 20.  These submissions will make clear that the Complaint 
states well-founded claims that implicate serious public concern.  This is why, consistent with (1) 
Congress’s directive that antitrust enforcement actions like this one be resolved expeditiously, 
and (2) relevant legal authority both in this District as well as in similar litigated matters, the 
United States should maintain the ability to commence fact-gathering consistent with Fed. R. 
Civ. P. 26.   
 
 
 
Sincerely, 
 
/s/ Edward Duffy 
Edward Duffy 
U.S. Department of Justice  
Antitrust Division 
 
Case 1:24-cv-07214-JGK     Document 28     Filed 11/08/24     Page 3 of 3

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