Affidavit Declaration of Beth A. Wilkinson — United States v. Visa Inc. (Dkt. 38.1)

Summary

Beth A. Wilkinson, a partner with the law firm Wilkinson Stekloff, LLP, attorneys for Defendant Visa Inc., declares under penalty of perjury in support of Visa's Motion to Dismiss the Complaint. The declaration attaches Exhibit 1, the Payment Platform Agreement between Visa and Apple Inc. dated August 29, 2014, and Exhibit 2, Amendment No. 9 to the Apple-Visa Payment Platform Agreement dated June 3, 2021. It also attaches agreements with PayPal, Inc. and Block Inc. as Exhibits 4 and 5, and Exhibit 6, an excerpt of the official transcript of the Court's November 12, 2024 conference. It is signed /s/ Beth A. Wilkinson and dated December 16, 2024.

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
VISA INC., 
Defendant. 
Case No. 1:24-cv-07214-JGK-SLC 
 
DECLARATION OF BETH A. WILKINSON 
Beth A. Wilkinson declares, under penalty of perjury, pursuant to 28 U.S.C. § 1746, as 
follows: 
1. I am a member of the bar of this Court and a partner with the law firm Wilkinson Stekloff, 
LLP, attorneys for Defendant Visa Inc. (Visa) in the above-captioned action. I submit this 
declaration in support of Visa’s Motion to Dismiss the Complaint. 
2. Attached hereto as Exhibit 1 is a true and correct copy of the Payment Platform Agreement 
(“Apple Technology Agreement”), a contract between Visa and Apple Inc. dated August 
29, 2014. This document is referenced at Paragraph 136 of the Complaint. 
3. Attached hereto as Exhibit 2 is a true and correct copy of Amendment No. 9 to the Apple-
Visa Payment Platform Agreement, a contract between Visa and Apple Inc. dated June 3, 
2021. The Apple-Visa Payment Platform Agreement is referenced at Paragraph 136 of the 
Complaint.  
4. Attached hereto as Exhibit 3 is a true and correct copy of the Visa Global Strategic 
Merchant Initiative Agreement (“Apple Merchant Agreement”), a contract between Visa 
Case 1:24-cv-07214-JGK     Document 38-1     Filed 12/16/24     Page 1 of 2

 
2 
and Apple Inc. dated April 1, 2022. This document is referenced at Paragraph 136 of the 
Complaint. 
5. Attached hereto as Exhibit 4 is a true and correct copy of the Amended and Restated Visa-
PayPal Strategic Partnership Agreement (“PayPal Agreement”), a contract between Visa 
and PayPal, Inc. dated July 1, 2022. This document is referenced at Paragraph 124 of the 
Complaint. 
6. Attached hereto as Exhibit 5 is a true and correct copy of the Amended and Restated Visa 
Direct Agreement, a contract between Visa and Block Inc. (formerly called Square) dated 
May 1, 2023. This document is referenced at Paragraph 132 of the Complaint. 
7. Attached hereto as Exhibit 6 is a true and correct excerpt of the official transcript of the 
Court’s November 12, 2024 conference in this matter. 
I declare under penalty of perjury that the foregoing is true and correct. 
 
DATED:  December 16, 2024 
Washington, D.C. 
 
 
 
 
 
/s/ Beth A. Wilkinson  
 
Beth A. Wilkinson 
 
 
Case 1:24-cv-07214-JGK     Document 38-1     Filed 12/16/24     Page 2 of 2

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