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Home Court filings United States of America v. Visa Inc. — S.D.N.Y., No. 1:24-cv-07214-JGK Affidavit Declaration of Beth A. Wilkinson — United States v. Visa Inc. (Dkt. 38.1)

Court filing

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

Record facts

CourtU.S. District Court for the Southern District of New York
Filed2024-12-16

U.S. District Court for the Southern District of New York · No. 1:24-cv-07214-JGK · Doc. 38-1 · 2024-12-16 · Docket on CourtListener

Full text

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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