Defendant Visa Inc.'s Amended Answer — United States of America v. Visa Inc. (S.D.N.Y.)

Summary

Defendant Visa Inc.'s Amended Answer to the Complaint in United States of America v. Visa Inc., No. 1:24-cv-7214, in the U.S. District Court for the Southern District of New York, dated August 22, 2025 and filed as Document 109 under Federal Rule of Civil Procedure 15. Answering paragraph by paragraph, Visa admits that debit cards are used billions of times every year and that it competes in a two-sided market, and denies most of the remaining allegations, including Paragraphs 7, 9 and 10. It admits that the Durbin Amendment was passed and signed into law in 2010 and that issuers typically must enable at least one debit card network unaffiliated with Visa. Its Seventh Defense states there was no harm to competition or consumers in a properly defined antitrust market. Visa asks the Court to dismiss the Complaint with prejudice and enter judgment in its favor.

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UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA, 
 
 
Plaintiff,
 
1:24-cv-7214 
v.
 
 
VISA INC.,
 
 
Defendant.
 
 
 
DEFENDANT VISA INC.’S AMENDED ANSWER 
 
Pursuant to Federal Rule of Civil Procedure 15, Defendant Visa Inc. (“Visa”), by and 
through undersigned counsel, submits the following answer to Plaintiff United States of 
America’s Complaint as follows: 
RESPONSE TO NATURE OF THE CASE* 
1. 
Visa admits that debit cards are a type of payment card used in the United States 
by individual and business consumers to, among other things, make purchases both online and 
in-person at merchants, that output of debit card transactions is growing, and that debit cards are 
used billions of times every year.  Visa denies the remaining allegations in Paragraph 1.
2. 
Visa admits that debit transactions include debit card transactions, and that debit 
card transactions involve, among others, a cardholder, the cardholder’s issuing bank, a merchant, 
the merchant’s acquiring bank, and a debit card network.  Visa denies the remaining allegations 
in Paragraph 2. 
3. 
Visa admits that debit card transactions require a connection between a 
 
* For ease of reference, Visa’s Answer replicates the headings in the Complaint.  Although Visa believes no 
response is required to such headings, to the extent a response is deemed required and to the extent those headings 
and titles could be construed to contain factual allegations, those allegations are denied.  
US 254696476 
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cardholder’s bank and a merchant’s bank and that thousands of cardholders’ banks communicate 
through debit card networks with hundreds of merchants’ banks.  Visa denies the remaining 
allegations in Paragraph 3. 
4. 
Visa admits that to facilitate a debit transaction over the Visa network, the 
cardholder’s issuing bank and the merchant’s acquiring bank must be a member of Visa’s 
network.  Visa admits that issuers choose which networks to enable on their cards, merchants 
choose which networks to accept, and merchants or their acquiring banks, processors, or other 
intermediaries may choose which networks to use for a given transaction.  Visa denies that it or 
other networks can compete for transactions only if the network connects to both the issuer and 
the acquirer.  Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the remaining allegations as to other debit networks in Paragraph 4 and on that basis denies 
them.  Visa denies the remaining allegations in Paragraph 4. 
5. 
Visa admits that Visa competes in a two-sided market, in which both issuer 
enablement and merchant acceptance are factors important to attracting cardholders and 
transactions to a network.  Visa admits that the quoted language in Paragraph 5 appears in 
internal Visa correspondence, but Visa denies that the words quoted in Paragraph 5 accurately 
convey the full content and context of the conversation.  Visa lacks knowledge or information 
sufficient to form a belief as to the truth of the allegations as to other debit networks in Paragraph 
5 and on that basis denies them.  Visa denies the remaining allegations in Paragraph 5. 
6. 
Visa admits that Mastercard is a significant debit network that processes many 
U.S. debit transactions.  Visa admits that PIN networks, which originally facilitated transactions 
by requiring accountholders to enter a PIN, are another type of debit network that processes U.S. 
debit transactions. Visa lacks knowledge and information sufficient to form a belief as to the 
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truth of the allegations regarding market share in the United States in Paragraph 6 and on that 
basis denies them.  Visa denies the remaining allegations in Paragraph 6. 
7. 
Visa denies the allegations in Paragraph 7. 
8. 
Visa admits that the Dodd-Frank Wall Street Reform and Consumer Protection 
Act, which included the Durbin Amendment, was passed and signed into law in 2010.  The 
remainder of Paragraph 8 asserts legal conclusions or characterizes a Congressional enactment, 
and no response to those conclusions or characterizations is required.  To the extent any response 
is required, Visa denies the allegations in Paragraph 8 not otherwise admitted. 
9. 
Visa denies the allegations in Paragraph 9. 
10. 
Visa denies the allegations in Paragraph 10. 
11. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the allegations in the first and second sentences of Paragraph 11 and on that basis denies them.  
Visa denies the remaining allegations in Paragraph 11.  
12. 
Visa denies the allegations in Paragraph 12. 
13. 
Visa denies the allegations in Paragraph 13. 
14. 
Visa admits that some digital platforms, including Apple, PayPal, and Square, 
offer payment products that allow cardholders to link their debit card credentials to digital 
payment products.  Visa denies the remaining allegations in Paragraph 14. 
15. 
Visa denies the allegations in Paragraph 15. 
16. 
Visa denies the allegations in Paragraph 16. 
17. 
Visa denies the allegations in Paragraph 17. 
18. 
Visa denies the allegations in Paragraph 18. 
19. 
Visa denies the allegations in Paragraph 19. 
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20. 
Visa admits that payment networks compete in a two-sided market, in which both 
issuer enablement and merchant acceptance are factors important to attracting cardholders and 
transactions to a network.  Visa denies the remaining allegations in Paragraph 20. 
21. 
Visa denies the allegations in Paragraph 21. 
22. 
Visa denies the allegations in Paragraph 22. 
23. 
Paragraph 23 provides a characterization of Plaintiff’s action and Plaintiff’s 
asserted reasons for bringing it, to which no response is required.  To the extent a response is 
required, Visa denies the allegations in Paragraph 23. 
RESPONSE TO DEBIT TRANSACTIONS 
24. 
Visa admits that some payment cards permit a cardholder to, among other things, 
purchase goods and services by debiting from a variety of cardholder accounts.  Visa admits that 
debit transactions may be initiated in various ways, including without limitation in-person at 
merchants or online.  Visa denies the remaining allegations in Paragraph 24. 
25. 
Visa admits that debit cards have been used in the United States since the 1960s.  
Visa admits that ATMs can be used by customers to withdraw funds from their bank accounts 
with their debit cards.  Visa admits that debit card use in the United States has grown since its 
introduction in the 1960s.  Visa denies the remaining allegations in Paragraph 25. 
26. 
Visa admits that some debit card transactions involve the immediate authorization 
of a deduction of funds from, among other types of accounts, a cardholder’s bank account, and 
that debit card transactions are an important and popular payment method with growing output 
within the U.S. financial system.  Visa denies the remaining allegations in Paragraph 26. 
27. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the allegations in Paragraph 27 and on that basis denies them.   
 
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Response to Overview of Debit Transactions 
28. 
Visa admits that, among other things, debit cards permit cardholders to purchase 
goods and services by debiting from the cardholder’s financial account.  Visa denies the 
remaining allegations in Paragraph 26. 
29. 
Visa admits that it operates debit networks that include infrastructure to facilitate 
the communications related to payment transactions between merchants’ banks and cardholders’ 
banks.  Visa lacks knowledge or information sufficient to form a belief as to the truth of the 
allegations as to other debit networks in Paragraph 29 and on that basis denies them.  
30. 
Visa admits that it has contracts with issuing banks to issue payment cards to 
accountholders and refers to those contracts for their contents and context.  Visa admits that it 
has contracts with acquiring banks to allow merchants to accept its payment cards and refers to 
those contracts for their contents and context.  Visa lacks knowledge or sufficient information to 
form a belief as to the truth of the allegations concerning other debit networks in Paragraph 30 
and on that basis denies them.  Visa denies the remaining allegations in Paragraph 30.  Visa 
admits the allegations concerning issuing banks and acquiring banks in the first sentences of 
Footnotes 1 and 2.  The second sentences of Footnotes 1 and 2 describe how Plaintiff will use 
terms throughout the Complaint, and as such, no response is required.  To the extent a response 
is required, Visa denies the allegations in each second sentence in Footnotes 1 and 2. 
31. 
Visa denies the allegations in Paragraph 31. 
32. 
Visa admits that it operates debit networks that include infrastructure used to 
facilitate the authorization, settlement, and clearing of payment transactions made using Visa’s 
debit networks.  Visa admits that part of its networks’ services includes providing banks with 
settlement reports.  Visa lacks knowledge or information sufficient to form a belief as to the truth 
of the allegations regarding other debit networks in Paragraph 32 and on that basis denies them.  
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Visa denies the remaining allegations in Paragraph 32. 
33. 
Visa admits that it provides operating rules governing debit card transactions 
processed over Visa payment networks. Visa lacks knowledge or information sufficient to form a 
belief as to the truth of the allegations concerning other debit networks in Paragraph 33.  Visa 
denies the remaining allegations in Paragraph 33. 
34. 
Visa admits that debit cards may be used by cardholders to make both in-person 
and online purchases (among other things) using money debited from the cardholder’s financial 
account.  Visa admits that Visa-branded debit cards typically have several forms of identifiable 
information, including a 16-digit card number, an expiration date, and a card verification value, 
and an EMV security chip.  Visa admits that some debit cards display their so-called “front-of-
card” and “back-of-card” networks as illustrated hypothetically in Figure 1.  Visa otherwise lacks 
knowledge and information sufficient to form a belief as to the truth of the allegations in Figure 
1 and on the basis denies them.  Visa denies the remaining allegations in Paragraph 34. 
35. 
Visa admits that in Visa debit network transactions, the acquiring bank or 
acquiring processor sends the cardholder’s account and transaction information to the Visa debit 
network, and Visa facilitates the authorization, clearing, and settlement of the transaction 
payment.  Visa lacks knowledge and information sufficient to form a belief as to the truth of the 
allegations in Paragraph 35 regarding other debit networks and on that basis denies them.  Visa 
lacks knowledge and information sufficient to form a belief as to the truth of the allegations in 
Paragraph 35 regarding cardholders, merchants, acquirers, and issuers and on that basis denies 
them.  Visa denies the remaining allegations in Paragraph 35. 
36. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the allegations in Paragraph 36 and on that basis denies them. 
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37. 
Visa admits that a transaction facilitated while the cardholder is physically present 
at the point-of-sale may be referred to as a card-present transaction.  Visa admits that a 
transaction facilitated when the cardholder is not physically present at the point-of-sale may be 
referred to as a card-not-present transaction. Visa lacks knowledge or information sufficient to 
form a belief as to the truth of the allegations in the fourth and fifth sentences in Paragraph 37 
and on that basis denies them.  Visa admits that a card-not-present transaction may be facilitated 
by manually entering payment card credentials online or using payment card credentials that are 
stored in a digital wallet.  Visa lacks knowledge or information sufficient to form a belief as to 
the truth of the allegations in the seventh and eighth sentences in Paragraph 37 and on that basis 
denies them.  Visa denies the remaining allegations in Paragraph 37. 
Response to Debit Networks 
1. Response to Issuers Select Which Networks Are Enabled on a Debit Card 
38. 
Visa admits that debit cards issued by U.S. financial institutions typically must 
include at least two unaffiliated debit card networks and that issuers typically choose which debit 
card networks to enable on their debit cards.  Visa lacks knowledge or information sufficient to 
form a belief as to the truth of the allegations concerning other debit cards in Paragraph 38 and 
on that basis denies them.  Visa denies the remaining allegations in Paragraph 38. 
39. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the allegations in Paragraph 39 and on that basis denies them. 
40. 
Visa admits to having contractual relationships with issuers and refers to those 
contracts for their contents and context. Visa lacks knowledge and information sufficient to form 
a belief as to the truth of the allegations in the second sentence in Paragraph 40 and on that basis 
denies them.  Visa denies the remaining allegations in Paragraph 40. 
41. 
Visa admits that some Visa-branded debit cards include Interlink as a back-of-
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card network and that U.S. financial institutions that issue Visa-branded debit cards in the United 
States are typically required by the Durbin Amendment regulations to enable at least one debit 
card network unaffiliated with Visa.  Visa lacks knowledge and information sufficient to form a 
belief as to the truth of the remaining allegations in Paragraph 41 and on that basis denies them. 
42. 
Visa admits that issuers of debit cards determine which networks will be enabled 
on the debit cards they issue and which network functionalities to enable for each network they 
choose to enable.  Visa denies the remaining allegations in Paragraph 42. 
2. Response to How Debit Networks Get Paid 
43. 
Visa admits that Visa generally charges network fees to financial institutions for 
access to the Visa payment card networks and other services.  Visa admits that Visa’s Fixed 
Acquirer Network Fee is charged to acquiring banks.  Visa lacks knowledge or information 
sufficient to form a belief as to the truth of the allegations related to the network fees of other 
debit networks in Paragraph 43 and on that basis denies them.  Visa denies the remaining 
allegations in Paragraph 43. 
44. 
Visa admits that an interchange fee is a transaction fee paid by an acquirer to an 
issuer on transactions processed by Visa’s debit networks.  Visa admits that it establishes default 
interchange reimbursement fee schedules that apply to transactions where issuing and acquiring 
banks have not set their own financial terms for the interchange of Visa transactions.  Visa 
admits that the Durbin Amendment and regulations set caps on debit network interchange fees 
for issuers that are not exempt as that term is defined in the Durbin Amendment and regulations.  
Visa lacks knowledge or information sufficient to form a belief as to the truth of the allegations 
concerning other debit networks in Paragraph 44 and on that basis denies them.  Visa denies the 
remaining allegations in Paragraph 44. 
45. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
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the allegations regarding the division of fees between a merchant and acquirer in Paragraph 45 
and on that basis denies them.  Visa denies the remaining allegations in Paragraph 45. 
3. Response to U.S. Debit Network Evolution Helped Visa Obtain Dominance 
46. 
Visa admits that in the 1960s, certain financial institutions in the United States 
began issuing ATM cards to their customers.   Visa admits that ATM cards can be used by 
customers to withdraw funds from their bank accounts at ATMs using a PIN number.  Visa lacks 
knowledge or information sufficient to form a belief as to the truth of the remaining allegations 
in Paragraph 46 and on that basis denies them. 
47. 
Visa admits that, historically, some ATM networks added point-of-sale 
functionality to become debit card networks and that STAR, NYCE, and Pulse, among others, 
typically operated at the point-of-sale based on the entry of a PIN.  Visa denies the remaining 
allegations in Paragraph 47.   
48. 
Visa admits that before the Visa corporate restructuring leading to its IPO in 
2008, Visa International Service Association and Visa U.S.A. Inc. were membership 
corporations.  Visa admits that it introduced its debit card networks after the introduction of 
ATM cards.  Visa lacks knowledge and information sufficient to form a belief as to the truth of 
the allegations regarding Mastercard and on that basis denies them.  Visa denies the remaining 
allegations in Paragraph 48. 
49. 
Visa admits that in 2003, the Second Circuit affirmed a district court ruling 
enjoining Visa U.S.A.’s then-bylaw 2.10(e).  Visa further admits that in separate and unrelated 
private litigation, Visa reached a private settlement bifurcating its Honor All Cards rules between 
debit card acceptance and credit card acceptance.  Visa denies that the Plaintiff’s description of 
these litigations accurately reflects the full content and context of the cases, court’s opinion, or 
the settlement.  Visa lacks knowledge and information sufficient to form a belief as to the truth 
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of the allegations regarding Mastercard in the first sentence of Paragraph 49 and on that basis 
denies them.  Visa denies the remaining allegations in Paragraph 49. 
50. 
Visa admits that in 2008, Visa Inc. became a publicly traded corporation.  Visa 
lacks knowledge and information sufficient to form a belief as to the truth of the allegations 
regarding Mastercard in Paragraph 50 and on that basis denies them.  Visa denies the remaining 
allegations in Paragraph 50. 
51. 
Paragraph 51 asserts legal conclusions or characterizes a Congressional 
enactment, and no response to those conclusions or characterizations is required.  To the extent 
any response is required, Visa denies the allegations in Paragraph 51. 
52. 
Paragraph 52 asserts legal conclusions or characterizes a Congressional 
enactment, and no response to those conclusions or characterizations is required.  To the extent 
any response is required, Visa denies the allegations in Paragraph 52. 
53. 
Visa admits that the language quoted in the last sentence of Paragraph 53 appears 
in internal correspondence of a former Head of Product North America, but Visa denies that the 
quoted material in Paragraph 53 accurately reflects the full content and context of the document.  
Visa denies the remaining allegations in Paragraph 53. 
4. Response to PIN Networks Lack Scale and Meaningful Opportunities to 
Compete for Debit Transactions 
54. 
Visa admits that a Visa debit network must be enabled on a debit card by the card 
issuer in order for debit transactions originating on the card to be eligible to be routed to Visa.  
Visa lacks knowledge or information sufficient to form a belief as to the truth of the allegations 
regarding other debit networks in Paragraph 54 and on that basis denies them.  Visa denies the 
remaining allegations in Paragraph 54. 
55. 
Visa admits that debit networks compete in a two-sided market, in which both 
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issuer enablement and merchant acceptance are factors important to attracting cardholders and 
transactions to a network.  Visa admits that the words quoted in the last sentence of Paragraph 55 
appear in an executive’s internal correspondence, but Visa denies that the quoted material 
accurately reflects the full content and context of the statements.  Visa denies the remaining 
allegations in Paragraph 55. 
56. 
Visa admits that PIN debit networks have introduced so-called “PINless” 
products.  Visa denies the remaining allegations in Paragraph 56. 
57. 
Visa denies the allegations in Paragraph 57. 
58. 
Visa denies the allegations in Paragraph 58. 
59. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the allegations in Paragraph 59 regarding what merchants “feel” and on that basis denies them.  
Visa denies the remaining allegations in Paragraph 59. 
5. Response to Alternative Debit Networks 
60. 
Visa admits that options other than debit cards exist to make debit purchases. Visa 
admits that certain companies have developed methods through which debit payments may be 
facilitated.  Visa denies the remaining allegations in Paragraph 60. 
61. 
Visa admits that a payment solution provider can use ACH or RTP to facilitate 
consumer-to-merchant transactions.  Visa lacks knowledge or information sufficient to form a 
belief as to the truth of the remaining allegations in the second sentence of Paragraph 61 and on 
that basis denies them.  Visa denies the remaining allegations in Paragraph 61. 
62. 
Visa denies the allegations in Paragraph 62. 
 
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RESPONSE TO VISA SYSTEMATICALLY DOMINATES DEBIT TRANSACTIONS IN 
THE UNITED STATES THROUGH EXCLUSIONARY AND ANTICOMPETITIVE 
CONDUCT 
Response To Visa Has Been the Largest, Most Powerful Debit Network for Over a Decade 
63. 
Visa admits that it had a global operating income of $18.8 billion in 2022 and 
denies the remaining allegations in Paragraph 63. 
64. 
Visa admits that Visa generally charges network fees to financial institutions for 
access to the Visa payment card networks and other services.  Visa admits that it earns billions of 
dollars in revenue from its debit transactions.  Visa admits that in 2022, it made more revenue 
from its U.S. debit transactions than it did from its U.S. credit transactions.  Visa denies the 
remaining allegations in Paragraph 64. 
65. 
Visa admits the words quoted appear in a former CFO’s internal documents, but 
Visa denies that the quote accurately reflects the full content and context of the statement.  Visa 
denies the remaining allegations in Paragraph 65. 
66. 
Visa denies the allegations in Paragraph 66. 
67. 
Visa lacks knowledge and information sufficient to form a belief as to the truth of 
the allegations regarding its front-of-card debit card market share in Paragraph 67.  Visa admits 
that the words quoted appear in a former Head of Product North America’s internal document, 
but Visa denies that the quote in Paragraph 67 accurately reflects the full content and context of 
the statement.  Visa denies the remaining allegations in Paragraph 67. 
68. 
Visa denies the allegations in Paragraph 68. 
69. 
Visa denies the allegations in Paragraph 69. 
Response to Visa Entered into a Web of Contracts to Hinder PIN Networks from Competing 
70. 
Visa denies the allegations in Paragraph 70. 
71. 
Visa denies the first sentence in Paragraph 71.  Visa admits that the Federal 
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Reserve’s October 2022 clarification to Regulation II went into effect in 2023.  The remainder of 
Paragraph 71 asserts legal conclusions or characterizes a Congressional enactment and the 
Federal Reserve regulation, and no response to those conclusions or characterizations is required.  
To the extent any response is required, Visa denies the allegations in Paragraph 71 not otherwise 
admitted. 
72. 
Visa admits that the quoted words appear in an internal document, but Visa denies 
that the quote accurately reflects the full content and context of those documents or Visa’s 
position with respect to response to the Durbin Amendment.  Visa denies the remaining 
allegations in 72. 
73. 
Visa denies the allegations in Paragraph 73. 
74. 
Visa denies the allegations in Paragraph 74. 
1. Response to Visa’s Contracts with Merchants and Acquirers Unlawfully 
Inhibit Competition and Stifle Innovation 
75. 
Visa denies the allegations in Paragraph 75. 
76. 
Visa admits that it has entered into agreements with certain merchants and 
acquirers at various times with individually negotiated terms.  Visa refers to those agreements for 
their contents and context.  Visa denies the remaining allegations in Paragraph 76. 
77. 
Visa admits that it has entered into certain agreements with acquirers or 
merchants at various times with individually negotiated terms.  Visa refers to those agreements 
for their contents and context.  Visa denies the remaining allegations in Paragraph 77. 
78. 
Visa admits that it has entered into certain agreements with acquirers or 
merchants at various times with individually negotiated terms.  Visa refers to those agreements 
for their contents and context.  Visa denies the remaining allegations in Paragraph 78. 
79. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
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the allegations regarding merchants’ and acquirers’ motivations in entering contracts with 
networks in Paragraph 79 and on that basis denies them.  Visa lacks knowledge or information 
sufficient to form a belief as to the truth of the allegations regarding PIN networks’ rates in 
Paragraph 79 and on that basis denies them.  Visa denies the remaining allegations in Paragraph 
79. 
80. 
Paragraph 80 does not include any factual allegations, and no response to the 
hypothetical posed in Paragraph 80 is required.  To the extent any response is required, Visa 
denies the allegations in Paragraph 80. 
81. 
Paragraph 81 relies on the same hypothetical posed in Paragraph 80, and as such, 
contains no factual allegations, to which no response is required.  To the extent any response is 
required, Visa denies the allegations in Paragraph 81. 
82. 
Visa admits that Visa has entered into agreements with certain acquirer processors 
at various times with individually negotiated terms.  Visa refers to those agreements for their 
contents and context.  Visa denies the remaining allegations in Paragraph 82. 
83. 
Visa lacks knowledge and information sufficient to form a belief as to the truth of 
the allegations regarding other debit card networks in Paragraph 83 and on that basis denies 
them.  Visa denies the remaining allegations in Paragraph 83. 
84. 
Visa admits that the words quoted in Paragraph 84 appear in internal 
correspondence, but Visa denies that the quote accurately reflects the full content and context of 
the discussion.  Visa denies the remaining allegations in Paragraph 84. 
85. 
Visa denies the allegations in Paragraph 85. 
86. 
Visa admits that the words quoted in Paragraph 86 appear in internal 
correspondence, but Visa denies that the quoted material accurately reflects the full content and 
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context of the correspondence.  Visa denies the remaining allegations in Paragraph 86. 
87. 
Visa admits that in 2012 Visa introduced its Fixed Acquirer Network Fee 
structure, which is charged to acquiring banks and may include a monthly fee that varies based 
on multiple factors.  Visa denies the remaining allegations in Paragraph 87. 
2. Response to Visa’s Contracts with Issuers Unlawfully Restrict the Growth 
of Its Debit Competitors 
88. 
Visa admits that issuers choose which debit networks to enable on their cards.  
Visa also admits that it has an issuing agreement with JPMorgan Chase.  Visa refers to that 
agreement for its contents and context.  Visa denies the remaining allegations in Paragraph 88. 
89. 
Visa admits that it has entered into certain agreements with issuers at various 
times with individually negotiated terms.  Visa refers to those agreements for their contents and 
context.  Visa denies the remaining allegations in Paragraph 89. 
90. 
Visa denies the allegations in Paragraph 90. 
91. 
Visa admits that it has entered into certain agreements with issuers at various 
times with individually negotiated terms.  Visa refers to those agreements for their contents and 
context.  Visa admits that the language quoted in Paragraph 91 appears in internal 
correspondence of a Visa executive, but Visa denies that the quotes in Paragraph 91 accurately 
reflect the full content and context of the statements.  Visa denies the remaining allegations in 
Paragraph 91. 
92. 
Visa denies the allegations in Paragraph 92. 
93. 
Visa admits that it has entered into certain agreements with issuers at various 
times with individually negotiated terms.  Visa refers to those agreements for their contents and 
context.  Visa denies the remaining allegations in Paragraph 93. 
94. 
Visa admits that it has entered into certain agreements with issuers at various 
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times with individually negotiated terms.  Visa refers to those agreements for their contents and 
context.  Visa denies the remaining allegations in Paragraph 94. 
3. Response to Visa’s Response to the Durbin Amendment Successfully 
Protected Its Monopoly from Competition. 
95. 
Visa denies the allegations in Paragraph 95. 
96. 
Visa lacks knowledge and information sufficient to form a belief as to the truth of 
the allegations regarding other debit networks in Paragraph 96 and on that basis denies them.  
Visa denies the remaining allegations in Paragraph 96. 
97. 
Paragraph 97 asserts legal conclusions or characterizes a Congressional 
enactment, and no response to those conclusions or characterizations is required.  To the extent 
any response is required, Visa denies the allegations in Paragraph 97 not otherwise admitted. 
98. 
Visa denies the allegations in Paragraph 98. 
99. 
Visa denies the allegations in Paragraph 99. 
4. Response to Visa Uses Its Monopoly Power to Deprive Its Rivals of Scale 
100. 
Visa denies the allegations in Paragraph 100. 
101. 
Visa denies the allegations in Paragraph 101. 
102. 
Visa lacks knowledge and information sufficient to form a belief as to the truth 
regarding other PIN networks’ competitive strategies in Paragraph 102 and on that basis denies 
them.  Visa denies the remaining allegations in Paragraph 102. 
103. 
Visa lacks knowledge and information sufficient to form a belief as to the truth of 
the allegations in the third and fourth sentences of Paragraph 103 and on that basis denies them.  
Visa denies the remaining allegations in Paragraph 103. 
104. 
Visa lacks knowledge and information sufficient to form a belief as to the truth of 
the allegations concerning other networks in Paragraph 104 and on that basis denies them.  Visa 
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denies the remaining allegations in Paragraph 104. 
105. 
Visa denies the allegations in Paragraph 105. 
106. 
Visa admits that the words quoted appear in internal correspondence, but Visa 
denies that the quoted material accurately reflects the full content and context of the discussion.  
Visa denies the remaining allegations in Paragraph 106.  
107. 
Visa admits that in connection with its compliance with the Durbin Amendment’s 
regulations, JPMorgan Chase requested and received a waiver of certain provisions of its 
contract with Visa in 2023.  Visa lacks knowledge and information sufficient to form a belief as 
to the truth of the allegations regarding Chase’s relationship with Mastercard in Paragraph 107 
and on that basis denies them.  Visa lacks knowledge and information sufficient to form a belief 
as to the truth of the allegations regarding Maestro’s PINless offerings in Paragraph 107 and on 
that basis denies them.  Visa denies the remaining allegations in Paragraph 107. 
Response to Visa Uses Its Monopoly Power to Squash Innovative Alternatives to Its Debit 
Network 
 
108. 
Visa admits that debit cards are not the only way for consumers to pay with 
money in their financial accounts and that consumers may use alternative debit networks to 
those offered by Visa.  Visa admits that the quoted words were used by its CEO, but Visa 
denies that the quote accurately reflects the full content and context of the statement. Visa 
lacks knowledge and information sufficient to form a belief as to the truth of the allegations 
regarding other debit networks in Paragraph 108 and on that basis denies them.  Visa denies 
the remaining allegations in Paragraph 108. 
109. 
Visa admits that Apple Pay, Google Pay, and PayPal are examples of digital 
wallets.  Visa lacks knowledge and information sufficient to form a belief as to the truth of the 
allegations regarding the functioning of digital wallets in Paragraph 109 and on that basis denies 
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them.  Visa denies the remaining allegations in Paragraph 109. 
110. 
Visa admits that the words quoted in Paragraph 110 were said by its former CFO 
at a conference, but denies that the quotes accurately reflect the full content and contexts of the 
statements.  Visa denies the remaining allegations in Paragraph 110. 
111. 
Visa admits that debit transactions that occur online and the volume associated 
with those transactions have substantially increased over at least the past decade, although 
paragraph 111 does not accurately describe these industry developments. Visa denies the 
remaining allegations in Paragraph 111. 
112. 
Visa admits that the quoted words in Paragraph 112 appear in various internal 
documents, but Visa denies that the quotes are fully accurate or accurately reflect the full content 
and context of those documents.  Visa denies the remaining allegations in Paragraph 112. 
1. Response to Visa Fears that Fintech Debit Networks Will Disintermediate 
Its Lucrative Debit Business 
113. 
Visa lacks knowledge and information sufficient to form a belief as to the truth of 
the allegations regarding the functioning and capabilities of other companies’ debit networks in 
Paragraph 113 and on that basis denies them.  Visa denies the remaining allegations in Paragraph 
113. 
114. 
Visa lacks knowledge and information sufficient to form a belief as to the truth of 
the allegations regarding other participants in the payments ecosystems in Paragraph 114 and on 
that basis denies them.  Visa denies the remaining allegations in Paragraph 114. 
115. 
Visa admits that The Clearing House and the Federal Reserve have successfully 
introduced bank transfer alternatives to ACH to the market.  Visa denies the remaining 
allegations in Paragraph 115. 
116. 
Visa admits that digital wallets can be used to complete cardholder-to-merchant 
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transactions, sometimes with funds in the wallet.  Visa admits that PayPal and Square’s Cash 
App operate as staged digital wallets in the United States.  Visa admits that there is another type 
of digital wallet, called a pass-through wallet, and Apple Pay and Google Pay are examples.  
Visa lacks information and knowledge sufficient to form a belief as to the truth of the remaining 
allegations in Paragraph 116 and on that basis denies them. 
117. 
  Visa lacks information and knowledge sufficient to form a belief as to the truth 
of the allegations in the third, fourth, and fifth sentences of Paragraph 117 and on that basis 
denies them.  Visa denies the remaining allegations in Paragraph 117. 
118. 
Visa denies the allegations in Paragraph 118. 
2. Response to Visa Leveraged Its Debit Monopoly to Prevent PayPal and 
Others from Disintermediating Visa with Staged Digital Wallets 
119. 
Visa admits that it has an agreement with PayPal signed in 2016 and refers to that 
agreement for its content and context.  Visa denies the remaining allegations in Paragraph 119. 
120. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the allegations regarding merchants’ acceptance of PayPal in the 2000s and early 2010s and on 
that basis denies them.  Visa denies the remaining allegations in Paragraph 120. 
121. 
Visa admits that the quoted words in the third sentence of Paragraph 121 were 
used in two internal documents, but Visa denies that the quotes accurately reflect the full content 
and context of those documents.  Visa admits that the quoted words in the fourth sentence of 
Paragraph 121 were used by a Visa employee, but Visa denies that the quote accurately reflects 
the full content and context of the discussion.  Visa lacks information and knowledge sufficient 
to form a belief as to the truth of the allegations regarding PayPal’s product and offerings in 
Paragraph 121 and on that basis denies them.  Visa denies the remaining allegations in Paragraph 
121. 
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122. 
Visa denies the allegations in Paragraph 122. 
123. 
Visa lacks knowledge and information sufficient to form a belief as to the 
allegations regarding PayPal’s partnerships with merchants in Paragraph 123 and on that basis 
denies them.  Visa denies the remaining allegations in Paragraph 123. 
124. 
Visa admits that it entered into a new contract with PayPal in 2022.  Visa refers to 
the agreement for its contents and context.  Visa denies the remaining allegations in Paragraph 
124. 
125. 
Visa denies the allegations in Paragraph 125. 
126. 
Visa admits having a contractual relationship with Square and refers to the 
contracts for content and context.  Visa denies the remaining allegations in Paragraph 126. 
127. 
Visa lacks knowledge and information sufficient to form a belief as to the truth of 
the allegations regarding Square Cash in the first and second sentences of Paragraph 127 and on 
that basis denies them.  Visa denies the remaining allegations in Paragraph 127. 
128. 
Visa admits that it signed an agreement with Square to participate in Square Cash 
and refers to the contract for content and context.  Visa denies the remaining allegations in 
Paragraph 128. 
129. 
Visa admits that the words quoted in Paragraph 129 were used by a Visa 
employee, but denies that the quote accurately portrays the full content and context of the 
discussion and Visa’s position on its agreement with Square. 
130. 
Visa lacks knowledge and information sufficient to form a belief as to the truth of 
the allegations of the first sentence in Paragraph 130 and on that basis denies them.  Visa denies 
the remaining allegations of Paragraph 130. 
131. 
Visa admits that it communicated with Square concerning Cash Drawer and 
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Square Cash, but Paragraph 131 mischaracterizes those communications and on that basis Visa 
denies the allegations about those communications in Paragraph 131.  Visa denies the remaining 
allegations in Paragraph 131.   
132. 
Visa admits that the words quoted in the fourth sentence of Paragraph 132 were 
used by a Visa employee, but Visa denies that the quoted language accurately reflects the full 
content and context of the statement.  Visa lacks knowledge and information sufficient to form a 
belief as to the truth of the allegations in the first sentence of Paragraph 132 and on that basis 
denies them.  Visa admits that it negotiated with Square regarding staged digital wallet fees.  
Visa refers to the agreement with Square for its content and context.  Visa denies the remaining 
allegations in Paragraph 132. 
3. Response to Visa Uses Its Leverage Over Its Potential Debit Competitors, 
Including Apple, Paying Them Not to Create or Promote Competitive 
Products 
133. 
Visa denies the allegations in Paragraph 133. 
134. 
Visa denies the allegations in Paragraph 134. 
135. 
Visa admits that it has entered into individually negotiated agreements with 
merchants, and refers to those agreements for content and context.  Visa admits that the quoted 
words in Paragraph 135 were used by a Visa employee, but Visa denies that the quotes in 
Paragraph 135 accurately reflect the full content and context of the statement.  Visa denies the 
remaining allegations in Paragraph 135. 
136. 
Visa admits it has agreements with Apple, and refers to those agreements for 
content and context.  Visa denies the remaining allegations in Paragraph 136. 
137. 
Visa admits that the quoted language in Paragraph 137 was used internally, but 
Visa denies that the quotes in Paragraph 137 accurately reflect the full content and context of the 
discussions.  Visa denies the remaining allegations in Paragraph 137. 
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RESPONSE TO ANTICOMPETITIVE EFFECTS 
138. 
Visa denies the allegations in Paragraph 138. 
139. 
Visa denies the allegations in Paragraph 139. 
140. 
Visa denies the allegations in Paragraph 140. 
141. 
Visa denies the allegations in Paragraph 141. 
142. 
Visa denies the allegations in Paragraph 142. 
143. 
Visa denies the allegations in Paragraph 143. 
144. 
Visa denies the allegations in Paragraph 144. 
145. 
Paragraph 145 is made up of three normative statements and no factual 
allegations, and as such, no response is required.  To the extent any response is required, Visa 
denies the allegations in Paragraph 145. 
146. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the allegations concerning Maestro’s PINless program in Paragraph 146 and denies them on this 
basis.  Visa denies the remaining allegations in Paragraph 146. 
RESPONSE TO NO COUNTERVAILING FACTORS 
147. 
Visa denies the allegations in Paragraph 147. 
RESPONSE TO THE RELEVANT U.S. DEBIT MARKETS 
148. 
Paragraph 148 contains legal conclusions to which no answer is required.  To the 
extent that a response is required, Visa denies the allegations in Paragraph 148. 
149. 
Paragraph 149 contains legal conclusions to which no answer is required.  To the 
extent that a response is required, Visa denies the allegations in Paragraph 149. 
Response to The United States Is a Relevant Geographic Market 
150. 
Visa states that the allegations in the first two sentences are legal conclusions to 
which no response is required.  To the extent a response is required, Visa denies those 
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allegations.  Visa denies the remaining allegations in Paragraph 150. 
Response to Relevant Product Markets 
151. 
Visa denies the allegations in Paragraph 151. 
1. Response to General Purpose Debit Network Services Are a Relevant 
Product Market 
152. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the allegations concerning other debit card networks and other companies’ product and service 
offerings and on that basis denies them.  Visa denies the remaining allegations in Paragraph 152.  
153. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the allegations in Paragraph 153 and on that basis denies them.   
154. 
Visa admits that payment networks are a two-sided market, in which both issuer 
enablement and merchant acceptance are factors important to attracting cardholders and 
transactions to a network.  Visa denies the remaining allegations in Paragraph 154. 
155. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the allegations concerning the beliefs of consumers, issuers, merchants, and acquirers in 
Paragraph 155 and on that basis denies them.  Visa denies the remaining allegations in Paragraph 
155.  
156. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the allegations concerning other companies’ debit networks in Paragraph 156 and on that basis 
denies them.  Visa denies the remaining allegations in Paragraph 156.  
157. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the allegations concerning other card networks and accountholders in Paragraph 157 and on that 
basis denies them. Visa denies the remaining allegations in Paragraph 157. 
158. 
Visa denies the allegations in Paragraph 158. 
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159. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the allegations regarding ACH transfers and whether they are inconvenient for consumers and 
merchants in Paragraph 159 and on that basis denies them. Visa denies the remaining allegations 
in Paragraph 159. 
160. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the allegations regarding cash and check payments and how they are viewed by merchants and 
accountholders in Paragraph 160 and on that basis denies them. Visa denies the remaining 
allegations in Paragraph 160. 
2. Response to General Purpose Card-Not-Present Debit Network Services Are 
a Relevant Product Market 
161. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the allegations regarding how other industry participants categorize debit network services in 
Paragraph 161 and on that basis denies them. Visa denies the remaining allegations in Paragraph 
161. 
162. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the allegations in Paragraph 162 and on that basis denies them. 
163. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the allegations in the second sentence of Paragraph 163 and on that basis denies them.  Visa 
denies the remaining allegations in Paragraph 163. 
RESPONSE TO VISA HAS MONOPOLY POWER IN THE U.S. DEBIT MARKETS 
164. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the allegations in the second and third sentences of Paragraph 164 and on that basis denies them.  
Visa denies the remaining allegations in Paragraph 164. 
165. 
Visa denies the allegations in Paragraph 165. 
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166. 
Visa denies the allegations in Paragraph 166. 
167. 
Visa lacks knowledge or information sufficient to form a belief as to the truth of 
the allegations in the third sentence of Paragraph 167 and on that basis denies them.  Visa denies 
the remaining allegations in Paragraph 167. 
168. 
Visa denies the allegations in Paragraph 168. 
169. 
Visa denies the allegations in Paragraph 169. 
170. 
Visa admits that many merchants accept Visa and Mastercard debit cards.  Visa 
lacks knowledge or information sufficient to form a belief as to the truth of the allegations in the 
second sentence of Paragraph 170 and on that basis denies them.  Visa denies the remaining 
allegations in Paragraph 170. 
171. 
Visa admits that Visa operates in a two-sided market for its payment network 
services.  Visa denies the remaining allegations in Paragraph 171. 
172. 
Visa admits that issuers generally only issue debit cards under a single “front-of-
card network,” but denies the remaining allegations and characterizations in Paragraph 172. 
173. 
Visa denies the allegations of Paragraph 173. 
174. 
Visa denies the allegations in Paragraph 174. 
175.  Visa admits that in 2012 it implemented a Fixed Acquirer Network Fee, and in 
2023, Visa implemented a Digital Commerce Service fee.  Visa denies the remaining allegations 
in Paragraph 175. 
RESPONSE TO JURISDICTION, VENUE, AND COMMERCE 
176. 
Visa admits that the Complaint purports to have been filed under Section 4 of the 
Sherman Act, 15 U.S.C. § 4, to prevent and restrain violations of Sections 1 and 2 of the 
Sherman Act, 15 U.S.C. §§ 1,2, but denies that these claims are proper and denies that the United 
States is entitled to any relief whatsoever.  Visa denies the remaining allegations in Paragraph 
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176. 
177. 
The allegations in Paragraph 177 are legal conclusions to which no response is 
required. 
178. 
Visa admits that it transacts business in this District.  The remaining allegations in 
Paragraph 178 are legal conclusions to which no response is required.  
179. 
Visa admits that Visa is a Delaware corporation with its principal place of 
business in the San Francisco Bay Area, California.  Visa admits that its networks are accepted in 
many countries globally, and that Visa’s global networks processed billions of debit card 
transactions valued at trillions of U.S. dollars in 2023.  Visa admits that it operates two-sided 
transaction platform networks that include infrastructure used to facilitate the authorization, 
settlement, and clearing of debit card transactions.  Visa admits to reporting approximately $32.7 
billion in net revenues for fiscal year 2023, including approximately $14.1 billion from United 
States operations, as reported stated in Visa’s Annual Report.  Visa denies the remaining 
allegations in Paragraph 179. 
180. 
Visa admits that it provides and offers services throughout the United States, 
including within this District.  Visa denies the remaining allegations in Paragraph 180. 
RESPONSE TO VIOLATIONS ALLEGED 
Response to First Claim for Relief: Monopolization of the Markets for General Purpose Debit 
Network Services and General Purpose Card-Not-Present Debit Network Services in the 
United States in Violation of Sherman Act § 2 
181. 
Visa incorporates its responses to the allegations of paragraphs 1 through 180 
above. 
182. 
Visa denies the allegations in Paragraph 182. 
183. 
Visa denies the allegations in Paragraph 183. 
184. 
Visa denies the allegations in Paragraph 184. 
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185. 
Visa denies the allegations of Paragraph 185. 
186. 
Visa denies the allegations in Paragraph 186. 
Response to Second Claim for Relief: Attempted Monopolization of the Markets for General 
Purpose Debit Network Services and General Purpose Debit Card- Not-Present Debit Network 
Services in the United States in Violation of Sherman Act § 2 
187. 
Visa responds to the allegations in Paragraph 187 of the Complaint as it did when 
those allegations were made separately. 
188. 
Visa denies the allegations in Paragraph 188. 
189. 
Visa denies the allegations in Paragraph 189. 
190. 
Visa denies the allegations in Paragraph 190. 
191. 
Visa denies the allegations in Paragraph 191. 
192. 
Visa denies the allegations in Paragraph 192. 
Response to Third Claim for Relief: Unlawful Agreements Not to Compete in Violation of 
Sherman Act § 1 
193. 
Visa responds to the allegations in Paragraph 193 of the Complaint as it did when 
those allegations were made separately. 
194. 
Visa denies the allegations of Paragraph 194. 
195. 
Visa denies the allegations of Paragraph 195. 
196. 
Visa denies the allegations in Paragraph 196. 
197. 
Visa denies the allegations in Paragraph 197. 
Response to Fourth Claim for Relief: Unlawful Agreements that Restrain Trade in Violation 
of Sherman Act § 1 
198. 
Visa responds to the allegations in Paragraph 198 of the Complaint as it did when 
those allegations were made separately. 
199. 
Visa denies the allegations in Paragraph 199. 
200. 
Visa denies the allegations in Paragraph 200. 
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201. 
Visa denies the allegations in Paragraph 201. 
202. 
Visa denies the allegations in Paragraph 202. 
RESPONSE TO REQUEST FOR RELIEF 
203. Visa denies that Plaintiff is entitled to any and all relief whatsoever and further 
denies all allegations in Paragraph 203. 
Visa denies any and all allegations in the Complaint, whether express or implied and 
including in all headers, not expressly admitted or qualified herein. 
AFFIRMATIVE OR OTHER DEFENSES 
 Without assuming any burden of proof it would not otherwise bear, Visa asserts the 
following affirmative or other defenses.  Visa reserves the right to assert further defenses or amend, 
withdraw, supplement, or modify these defenses as the case proceeds. 
FIRST DEFENSE 
Plaintiff’s claims are barred in whole or in part because Visa had legitimate business 
justifications for the conduct at issue, including in response to the Durbin Amendment and the new 
regulations impacting the industry, its conduct was procompetitive and outweighed any alleged 
anticompetitive effects, and its practices were and are reasonably justified. 
SECOND DEFENSE 
Plaintiff’s claims are barred in whole or in part because Plaintiffs’ allegations and 
evidence do not establish a valid relevant antitrust market. 
THIRD DEFENSE 
Plaintiff’s claims are barred in whole or in part because Visa does not have monopoly 
and/or market power in a properly defined antitrust market. 
FOURTH DEFENSE 
Plaintiff’s exclusive dealing claims are barred in whole or in part because Visa’s 
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contracts are pro-competitive discounting arrangements, are reflective of common industry 
practices, are responsive to demands from sophisticated customers, and have not resulted in 
substantial foreclosure in a properly defined antitrust market. 
FIFTH DEFENSE 
Plaintiff’s claims are barred in whole or in part because Visa’s contracts are not 
“predatory” or otherwise below an appropriate measure of Visa’s costs in a properly defined 
antitrust market. 
SIXTH DEFENSE 
Plaintiff’s claims are barred in whole or in part because Visa has no agreements that pay 
competitors not to compete or agreements that pay potential competitors not to develop 
alternatives to debit card networks or adopt technologies to disintermediate debit card networks.  
SEVENTH DEFENSE 
Plaintiff’s claims are barred in whole or in part because there was no harm to competition 
or consumers in the form of increased prices, reduced output, reduced quality, or reduced 
innovation in a properly defined antitrust market. 
EIGHTH DEFENSE 
The relief sought by Plaintiff would be contrary to the public interest, harm consumers, 
and is otherwise inequitable, impractical, and unworkable. 
WHEREFORE, Defendant Visa Inc. respectfully requests that the Court: 
a. 
dismiss the Complaint with prejudice; 
b. 
enter judgment in Visa’s favor and against Plaintiff; and  
c. 
grant Visa such other and further relief, at law or in equity, as the Court 
deems just and proper. 
 
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Dated:  August 22, 2025 
Respectfully submitted,  
/s/ Anne P. Davis                                 
Anne P. Davis (admitted pro hac vice) 
Jonathan Ian Gleklen (admitted pro hac vice) 
Margaret A. Rogers (SBN NY 4647087) 
ARNOLD & PORTER  
   KAYE SCHOLER LLP 
601 Massachusetts Avenue NW 
Washington, D.C. 20001 
Telephone: (202) 942-6197 
Facsimile: (202) 942-5999 
anne.davis@arnoldporter.com 
jonathan.gleklen@arnoldporter.com 
margaret.rogers@arnoldporter.com 
 
Beth Wilkinson (SBN NY 2181592) 
Brian Stekloff (admitted pro hac vice) 
Kieran Gostin (SBN NY 4847653) 
Roxana Guidero (admitted pro hac vice) 
WILKINSON STEKLOFF LLP 
2001 M Street NW, 10th floor 
Washington, DC 20036 
Telephone: (202) 847-4000 
Facsimile: (202) 847-4005 
bwilkinson@wilkinsonstekloff.com 
bstekloff@wilkinsonstekloff.com 
kgostin@wilkinsonstekloff.com 
rguidero@wilkinsonstekloff.com 
 
Jeremy Barber (SBN NY 5344304) 
WILKINSON STEKLOFF LLP 
130 W 42nd Street, Floor 24 
New York, NY 10036 
Telephone: (212) 294 8910 
Facsimile: (202) 847-4005 
jbarber@wilkinsonstekloff.com 
 
Counsel for Defendant Visa Inc. 
 
Case 1:24-cv-07214-JGK     Document 109     Filed 08/22/25     Page 30 of 30

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