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Home Court filings Oto Analytics, LLC v. Benworth Capital Partners LLC Womply's Response to FRBSF Motion to Intervene — OTO Analytics v. Benworth (N.D. Cal. No. 3:24-cv-03975)

Court filing

Womply's Response to FRBSF Motion to Intervene — OTO Analytics v. Benworth (N.D. Cal. No. 3:24-cv-03975)

Filed July 24, 2024 in Oto Analytics v. Benworth; one of 111 filings from this case.

Record facts

CourtU.S. District Court for the District of Puerto Rico
Filed2024-07-24

U.S. District Court for the District of Puerto Rico · No. 3:23-cv-01034-GMM · Doc. 140 · 2024-07-24 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF PUERTO RICO 
 
OTO ANALYTICS, LLC, 
Plaintiff, 
v. 
BENWORTH CAPITAL PARTNERS PR 
LLC, BENWORTH CAPITAL PARTNERS 
LLC, BERNARDO NAVARRO and 
CLAUDIA NAVARRO, 
Defendants. 
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Civil Action No. 23-01034 
 
 
 
 
  
 
PLAINTIFF OTO ANALYTICS, LLC’S RESPONSE TO FEDERAL RESERVE BANK 
OF SAN FRANCISCO’S MOTION TO INTERVENE 
 
In accordance with this Court’s July 10, 2024 Order (ECF No. 134), Plaintiff Womply, 
through its undersigned counsel, respectfully submits this Response to the Federal Reserve Bank 
of San Francisco’s (“Reserve Bank”) Motion to Intervene (“Motion” or “Mot.”; ECF No. 127).1  
Womply does not oppose the Reserve Bank’s Motion.  However, Womply submits this 
Response in order to provide the Court with important context and clarity regarding two issues 
raised in the Motion:  (i) the Reserve Bank’s stated concern that “Womply is affirmatively seeking 
to attach and collect against” the Reserve Bank’s collateral, which would “cripple the ability of 
Benworth to continue to service” PPP loans and “threaten to impair the Reserve Bank’s preexisting 
secured interest” (Mot. at 2); and (ii) the Reserve Bank’s impression that Benworth FL has failed 
to satisfy its debt to the Reserve Bank “either due to Womply’s withholding of the appropriate 
documentation” related to certain PPP loans “or due to other problems internal to Benworth FL” 
(id. ¶ 18).   
 
1 Capitalized terms have the same meanings as in Womply’s Amended Complaint (“Am. Compl.”; 
ECF No. 125), unless otherwise indicated. 
Case 3:23-cv-01034-GMM     Document 140     Filed 07/24/24     Page 1 of 6

 
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First, Womply does not seek to interfere with the Reserve Bank’s collateral.  
Understanding the scope of the relief that Womply seeks and the scope of the Reserve Bank’s 
collateral requires some understanding of how the PPP worked and the fees Benworth FL received 
for making PPP loans.  As alleged in Womply’s Amended Complaint, the PPP involved businesses 
receiving loans from private lenders that were both:  (i) potentially forgivable if the borrower 
complied with program rules and (ii) guaranteed by the SBA if the lender complied with program 
rules.  (Am. Compl. ¶¶ 3, 36.)  In other words, as long as the lender complied with the rules of the 
PPP, it bore no risk for making the PPP loans.  (Id.)  In addition to the SBA guarantee, lender 
incentives for making PPP loans included lucrative “Lender Processing Fees” from the SBA, 
which lenders received upon funding a loan, and interest accruing on the loans, which lenders 
received when the principal on the loan was repaid by the borrower or the loan was repurchased 
by the SBA pursuant to the guarantee.  See Business Loan Program Temporary Changes; Paycheck 
Protection Program as Amended by Economic Aid Act, 86 Fed. Reg. 3,692, 3,706–09 (Jan. 14, 
2021).  
Benworth FL processed more than 300,000 PPP loans using Womply’s PPP Fast Lane 
Technology in 2021.  (Am. Compl. ¶ 124.)  Pursuant to its agreements with Womply, Benworth 
FL agreed that, promptly after it received its Lender Processing Fees from the SBA, Benworth FL 
would pay a portion of those fees to Womply.  (Id. ¶ 120.)  However, instead of paying Womply 
the portion of the Lender Processing Fees to which it was entitled, Benworth FL fraudulently 
transferred the Lender Processing Fees to Benworth PR in the summer of 2021.  Based on 
agreements between Benworth FL and Benworth PR, as well as Defendant Bernardo Navarro’s 
deposition testimony from the Arbitration, Womply understands that Benworth FL transferred to 
Benworth PR far more in Lender Processing Fees than the approximately $118 million that 
Case 3:23-cv-01034-GMM     Document 140     Filed 07/24/24     Page 2 of 6

 
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Benworth FL now owes to Womply2—possibly as much as $170 million (or more).  (Am. Compl. 
¶¶ 183, 212–14.)  The Reserve Bank does not have a lien on those Lender Processing Fees (nor 
does it claim to in its filings in this action). 
As explained in the Motion, the Reserve Bank’s “first-priority lien” is on (among other 
things) “all proceeds and products” of the PPP loans that Benworth FL funded, which includes 
principal and interest payments that Benworth FL receives.  (Mot. ¶¶ 4–8 & n.4.)  Benworth 
received those “proceeds and products” after it received the Lender Processing Fees that Womply 
is entitled to be paid from.  In other words, the Reserve Bank does not have a lien on the money 
Womply is owed.  Womply understands that any principal payments that Benworth FL has already 
received were paid to the Reserve Bank.3  To the extent there are outstanding PPP loans for which 
Benworth FL has not received principal or interest payments, those loans (and any future principal 
and interest payments on those loans) are part of the Reserve Bank’s collateral.  The Reserve 
Bank’s collateral also includes any interest payments that Benworth FL already received, the 
amount of which, Womply understands, likely is less than the approximately $67 million Benworth 
FL owes to the Reserve Bank. 
Womply commenced this action in order to recover the portion of Benworth FL’s Lender 
Processing Fees to which it is entitled.  Womply does not seek to interfere with the Reserve Bank’s 
 
2 That debt was confirmed in a final award issued by the arbitrator in the JAMS Arbitration 
between Womply and Benworth FL conducted in San Francisco, CA.  Womply has filed a petition 
to confirm that final award in the United States District Court for the Northern District of 
California.  See Petition to Confirm Arbitration Award and For Entry of Judgment, Oto Analytics, 
LLC v. Benworth Capital Partners LLC, No. 3:24-cv-03975 (N.D. Cal. July 1, 2024). 
3 See Motion at 7 n.6 (indicating that the Reserve Bank moved “Benworth FL to a ‘direct pay’ 
structure whereby the SBA remits payments associated with loan forgiveness reimbursement and 
loan guarantee amounts for the Pledged PPP Loans directly to the Reserve Bank instead of 
Benworth FL”). 
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collateral, nor is it in Womply’s interest to disrupt Benworth FL’s servicing of PPP loans.  If 
Benworth FL can continue servicing its outstanding PPP loans and obtain the SBA’s guarantee 
repurchase of those loans, Benworth FL should be able to satisfy its debts to both Womply and the 
Reserve Bank.  That is, of course, unless Defendants have improperly disposed of assets in further 
fraudulent transfers.   
Second, Benworth FL’s excuses for why the SBA has so far refused to repurchase certain 
PPP loans, leaving Benworth FL with an outstanding debt of approximately $67 million to the 
Reserve Bank, are not relevant to the claims and defenses in this action.  Womply does not have 
visibility into Benworth FL’s efforts to have the SBA repurchase its outstanding loans, including 
the extent to which the SBA is refusing to repurchase certain loans or the reasons why.  However, 
according to the Reserve Bank’s Motion, Benworth FL has claimed that the SBA is refusing to 
repurchase loans because Womply is refusing to provide Benworth FL with documentation 
regarding those loans (and because of certain unidentified “internal problems” at Benworth FL).  
(Mot. ¶ 18.)  Womply will spare the Court the lengthy history of this issue, because it is irrelevant 
to the present action.  Suffice it to say that, pursuant to an arbitration agreement, Benworth FL 
sought relief regarding this issue in the Arbitration, Womply consented to the declaratory relief 
Benworth FL sought,4 and Womply provided Benworth FL with all of the documentation that 
Benworth FL requested.  Indeed, on May 20, 2024, Benworth FL identified specific documentation 
that it claimed to need from Womply and, on June 13, 2024, Benworth FL’s counsel confirmed 
 
4 See Ex. 1 at 4 (Arbitrator Brainerd’s Feb. 20, 2024 Order) (“[I]n the January 29, 2024 joint 
statement, Womply consents to declaratory judgment being entered.  Thus, the Arbitrator’s 
December 21, 2023 Interim Award shall be amended to reflect that Benworth’s Counterclaim 1, 
as it pertains to the transmission of loan records, is GRANTED and the Final Award will reflect 
this ruling.”). 
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that it received “the package” from Womply containing those documents.  (Ex. 2.)5  Since June 
13, 2024, Benworth FL has not indicated that that it needs any other documentation from Womply. 
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Womply does not oppose the Reserve Bank’s Motion and, should this Court permit the 
Reserve Bank to intervene, intends to meet and confer with the Reserve Bank and Defendants 
regarding a stipulation to consolidate the Reserve Bank’s separate lawsuit against Defendants into 
this action.  Womply looks forward to coordinating with the Reserve Bank on discovery efforts.  
Womply further reserves all of its rights, including to respond to the Reserve Bank’s pleadings in 
this action.  
 
 
5 All references to “Exhibit” or “Ex.” refer to exhibits to the accompanying declaration of 
Alexander L. Cheney. 
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Dated: July 24, 2024 
 
 
Of Counsel 
 
Willkie Farr & Gallagher LLP 
 
By: /s/ Alexander L. Cheney_______ 
 
Alexander L. Cheney (admitted pro hac vice) 
333 Bush St 
San Francisco, CA 94104 
(415) 858-7400 
acheney@willkie.com 
 
Stuart R. Lombardi (admitted pro hac vice) 
Willkie Farr & Gallagher LLP 
787 7th Avenue 
New York, NY 10019 
(212) 728-8000 
slombardi@willkie.com 
 
Joshua S. Levy (admitted pro hac vice) 
1875 K Street, N.W. 
Washington, D.C. 20006 
(202) 303-1000 
jlevy@willkie.com 
 
 
 
 
 
 
Respectfully submitted, 
 
By: /s/Alejandro J. Cepeda Diaz ______ 
 
Alejandro J. Cepeda Diaz 
USDC-PR 222110 
McConnell Valdés LLC 
270 Muñoz Rivera Ave. 
Hato Rey PR 00918 
Tel: (787) 250-5637 
Email: ajc@mcvpr.com 
 
 
 
Attorneys for Plaintiff Oto Analytics, LLC  
 
 
CERTIFICATE OF SERVICE 
The undersigned certifies that on July 24, 2024, the foregoing document was filed with the 
Clerk of the Court using CM/ECF, which sent notices to all parties receiving notifications through 
the CM/ECF system. 
 
Dated: July 24, 2024   
 
 
 
By: /s/ Alejandro J. Cepeda Diaz _______ 
Attorney for Plaintiff Oto Analytics, LLC 
 
Case 3:23-cv-01034-GMM     Document 140     Filed 07/24/24     Page 6 of 6

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