Complaint — Concessions HH, JV v. The United States Small Business Administration (Dkt. 1, N.D. Ga.)
Summary
A petition for judicial review by Concessions HH, JV against the United States Small Business Administration in the U.S. District Court for the Northern District of Georgia, Atlanta Division, dated April 29, 2024. The petitioner, a Georgia joint venture in the food concessions business at the Atlanta airport, seeks review of an Office of Hearings and Appeals order upholding the SBA's denial of forgiveness of its $2 million Second Draw PPP loan. The petition states the SBA applied its Corporate Group Maximum Rule, which caps PPP loans to a single corporate group, even though the CARES Act waives affiliation rules for hospitality businesses with a code beginning with 72. It asks the court to set aside the decision, direct forgiveness of the loan and vacate the rule as contrary to the CARES Act.
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“Complaint — Concessions HH, JV v. The United States Small Business Administration (Dkt. 1, N.D. Ga.).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/complaint-concessions-hh-jv-v-the-united-states-small-business-adminis-799f9a8114/
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IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
CONCESSIONS HH, JV,
Petitioner,
Civil Action File No.
v.
THE UNITED STATES SMALL
BUSINESS ADMINISTRATION,
Respondent.
PETITION FOR JUDICIAL REVIEW
Petitioner Concessions HH, JV (“CHH”) hereby petitions the court for review
of the Order of the Office of Hearings and Appeals (“OHA”) denying CHH’s appeal
of a Paycheck Protection Program (“PPP”) loan review decision issued by the U.S.
Small Business Administration (“SBA”).
INTRODUCTION
1. This action seeks judicial review of the SBA’s decision denying
forgiveness of a Paycheck Protection Program (“PPP”) loan CHH obtained pursuant
to the Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”), Pub.
L. No. 116-136, 134 Stat. 281 (2020), codified at 15 U.S.C. § 636(a)(36)–(37).
Because the SBA’s decision (1) rests on an unlawful SBA regulation that directly
contravenes the governing statute and (2) arbitrarily and capriciously applies the SBA
1
regulation even on its own terms, the Court should review and reverse the SBA’s
decision and direct it to forgive CHH’s PPP loan.
PARTIES
2. Petitioner CHH is a Georgia joint venture headquartered in Atlanta,
Georgia and jointly owned by Concessions Intl., LLC and H&H Hospitality, LLC.
CHH is in the food concessions business: It operates in the Atlanta International
Airport, where it provides food services that allow patrons to select and pay for food
items.
3. Respondent SBA is a federal agency created and governed by 15 U.S.C.
§ 633 et seq. The CARES Act authorizes the SBA to administer the PPP.
VENUE AND JURISDICTION
4. Because CHH brings this petition for judicial review pursuant to the
CARES Act and SBA regulations, this Court has jurisdiction of this dispute under
28 U.S.C. § 1331.
5. Venue is proper in this judicial district pursuant to 28 U.S.C. §
1391(c)(2), (e) and 5 U.S.C § 703 because CHH maintains its principal place of
business in this judicial district.
6. SBA regulations provide that the agency’s “[f]inal decisions may be
appealed to the appropriate Federal district court.” 13 C.F.R. § 134.1211(g); see also
13 C.F.R. § 134.1201(d) (“An appeal to OHA is an administrative remedy that must
2
be exhausted before judicial review of a final SBA loan review decision may be
sought in a Federal district court.”).
7. The SBA’s decision in this matter became final on April 19, 2023, 30 days
after service of the OHA’s March 20, 2023 decision affirming the SBA’s initial loan
review decision. 13 C.F.R. § 134.1211(d).
STATUTORY BACKGROUND & PROCEDURAL HISTORY
I. Recognizing COVID-19’s Particularly Severe Effects on Hospitality
Businesses, Congress Grants Such Businesses More Generous PPP
Conditions, Including Waiving SBA Affiliation Rules
8. The COVID-19 pandemic caused “devastating consequences for lives
and health” and “massive economic disruption.” Camelot Banquet Rooms, Inc. v.
U.S. Small Bus. Admin., 24 F.4th 640, 644 (7th Cir. 2022). “Congress responded
with several rounds of massive economic assistance, including the Paycheck
Protection Program.” Id.
9. This congressional response began in March 2020, when Congress
passed the CARES Act, Title I of which created the PPP. Pub. L. No. 116-136, 134
Stat. 281 (2020), codified at 15 U.S.C. § 636(a)(36).
10. The PPP is a “‘new loan program to be administered by the SBA under
Section 7(a) of the Small Business Act.’” Defy Ventures, Inc. v. U.S. Small Bus.
Admin., 469 F. Supp. 3d 459, 465 (D. Md. 2020) (quoting Camelot Banquet Rooms,
Inc. v. U.S. Small Bus. Admin., 458 F. Supp. 3d 1044, 1050, (E.D. Wis. May 1,
3
2020)). Under the PPP, “many small businesses became eligible for low-interest
loans that would be guaranteed by the federal government and even eligible for
forgiveness if the businesses used them, in essence, to keep employees on the payroll
during the economic downturn.” Camelot Banquet Rooms, 24 F.4th at 644. Through
the PPP, participating banks made SBA-guaranteed loans to eligible entities. See
Defy Ventures, 469 F. Supp. 3d at 465. And the CARES Act provides that these loans
would be forgiven if the borrower used the loan funds for statutorily approved
purposes, such as payroll expenses. See id.; 15 U.S.C. § 636m.
11. Congress initially appropriated $349 billion for the PPP, and then
appropriated an additional $310 billion in April 2020. Pub. L. No. 116-139, 134 Stat.
620 (2020).
12. On December 27, 2020, Congress enacted the Economic Aid Act,
which authorized borrowers who obtained initial PPP loans (“First Draw” loans) to
obtain additional “Second Draw” PPP loans. See Pub. L. 116-260, 134 Stat. 1182,
codified at 15 U.S.C. § 636(a)(37); see generally MoveCorp v. Small Bus. Admin.,
No. CV 20-1739 (CKK), 2021 WL 3144943, at *3 (D.D.C. July 26, 2021); SBA,
Business Loan Program Temporary Changes; Paycheck Protection Program
Second Draw Loans, 86 Fed. Reg. 3,712, 3,712 (Jan. 14, 2021). The Act
appropriated about $284 billion to fund such loans. See 134 Stat. at 2019.
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13. Second Draw loans were subject to the same general statutory
framework as First Draw loans, though with slightly tightened conditions. See 15
U.S.C. § 636(a)(37)(B). For example, the maximum loan amount for a single First
Draw loan was $10 million, 15 U.S.C. § 636(a)(36)(E), while the maximum loan
amount for a single Second Draw loan was $2 million, 15 U.S.C. § 636(a)(37)(C).
Similarly, while a business entity was eligible for First Draw PPP loans if it had 500
or fewer employees, 15 U.S.C. § 636(a)(36)(D)(i)(I), to be eligible for Second Draw
PPP loans the entity must have had 300 or fewer employees, 15 U.S.C.
§ 636(a)(37)(a)(iv)(I)(aa).
14. Congress provided that PPP loans would be made “under the same
terms, conditions, and processes” that applied to the SBA’s preexisting 7(a) Loan
Program. 15 U.S.C. § 636(a)(36)(B); see also, e.g., U.S. Small Bus. Admin. v.
Weather King Heating & Air, Inc., 648 B.R. 200, 205 (N.D. Ohio 2023) (“The PPP
was inserted beneath the umbrella of SBA's robust 7(a) Loan Program.”). The
CARES Act thereby sets a default rule under which many of the SBA regulations
that govern 7(a) loans apply to PPP loans as well. See id. These regulations include
the SBA’s affiliation rules, which among other things determine when multiple
corporate entities are sufficiently closely connected such that the SBA will aggregate
them together for the purposes of assessing eligibility for loan programs. See 13
C.F.R. § 121.103 (imposing detailed affiliation rules and further providing that
5
separate affiliation rules “set forth in § 121.301” apply to “applicants in SBA’s
Business Loan … Programs”)1; 13 C.F.R. § 121.301(f).2
15. For example, just a few weeks after Congress enacted the CARES Act,
the SBA promulgated an interim final rule providing that a business “entity generally
is eligible for the PPP if it, combined with its affiliates [as determined under 13
C.F.R. § 121.103], … has 500 or fewer employees.” SBA, Business Loan Program
Temporary Changes; Paycheck Protection Program, 85 Fed. Reg. 20,817, 20,818
(Apr. 15, 2020) (emphasis added); see also id. at 20,819 (noting that “the detailed
affiliation standards contained in § 121.103 currently do not apply to PPP borrowers,
because § 121.103(a)(8) provides that applicants in SBA’s Business Loan Programs
(which include the PPP) are subject to the affiliation rule contained in 13 CFR
121.301”).
16. Importantly, in structuring the PPP Congress recognized that while the
severe consequences of the COVID-19 pandemic and subsequent public-health
1
The version of this regulation applicable here was promulgated on February 23,
2021 and was effective from February 23, 2021 to January 4, 2022. See SBA,
Consolidation of Mentor-Prot´Eg´E Programs and Other Government Contracting
Amendments, 86 Fed. Reg. 10,732 (Feb. 23, 2021). For the Court’s convenience,
CCH has attached this version of the regulation as Exhibit A.
2
The version of this regulation applicable here was promulgated on December 14,
2020 and was effective from March 11, 2020 to September 7, 2021. See SBA,
Express Loan Programs, 85 Fed. Reg. 80,581 (Dec. 14, 2020). For the Court’s
convenience, CCH has attached this version of the regulation as Exhibit B.
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measures were felt across the economy, food-service and other hospitality
businesses were “hit especially hard because in-person gatherings are forbidden.”
Camelot Banquet Rooms, 458 F. Supp. 3d at 1063; see also, e.g., M. Rae, Inc. v.
Wolf, 509 F. Supp. 3d 235, 250 (M.D. Pa. 2020) (“It is beyond peradventure that the
hospitality industry has been devastated by the COVID -19 pandemic.”). And this
economic devastation imposed “significant hardships” on the businesses themselves
and their employees. Oregon Rest. & Lodging Ass’n v. Brown, No. 3:20-CV-02017-
YY, 2020 WL 6905319, at *7 (D. Or. Nov. 24, 2020).
17. In response to these distinctive burdens, Congress extended special
solicitude to the hospitality industry, such as by applying more generous maximum-
loan-calculation rules for any business “assigned a North American Industry
Classification System code beginning with 72,” 15 U.S.C. § 636(a)(36)(C)(iv)—in
other words, businesses in the hospitality industry, see
U.S. Census Bureau, 2017 NAICS Definition, Sector 72,
https://www.census.gov/naics/?input=72&chart=2017&details=72 (explaining that
this code refers to the “Accommodation and Food Services sector[, which]
comprises establishments providing customers with lodging and/or preparing meals,
snacks, and beverages for immediate consumption”).
18. Most significant here, while most businesses had their PPP eligibility
determined in accordance with the SBA’s affiliation rules, Congress provided
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different eligibility rules for hospitality businesses with 500 or fewer employees:
The CARES Act provides that for such businesses, “the provisions applicable to
affiliations under section 121.103 of title 13, Code of Federal Regulations, or any
successor regulation, are waived with respect to eligibility for a covered loan.” 15
U.S.C. § 636(a)(36)(D)(iv)(I) (emphasis added). And Congress repeated this rule
with the Economic Aid Act’s provisions governing Second Draw PPP loans: “The
waiver described in paragraph (36)(D)(iv) shall apply for purposes of determining
eligibility” of any hospitality business with 300 or fewer employees for Second
Draw loans. 15 U.S.C. § 636(a)(37)(E).
II. The SBA Contradicts Congress’s Express Language and Imposes
Affiliation Rules on Hospitality Businesses
19. The SBA initially recognized the significance of the CARES Act’s
waiver of affiliation rules: While the SBA’s April 15, 2020 interim final rule noted
that “[i]n most cases, a borrower will be considered together with its affiliates for
purposes of determining eligibility for the PPP,” it acknowledged that the CARES
Act’s waiver of “affiliation rules” for hospitality businesses “remain[s] in full force
and effect.” 85 Fed. Reg. at 20818 n.1. “As a result,” the SBA noted, “the affiliation
rules contained in section 121.301” and section 121.103 “do not apply to these types
of entities.” Id. (emphasis added).
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20. Just a few weeks later, however, the SBA proceeded to apply affiliation
rules to hospitality businesses notwithstanding Congress’s unequivocal instructions
otherwise. On May 4, 2020, the SBA promulgated another rule—never codified in
the Code of Federal Regulations—known as the “Corporate Group Maximum Rule.”
SBA, Business Loan Program Temporary Changes; Paycheck Protection
Program—Requirements—Corporate Groups and Non-Bank and Non-Insured
Depository Institution Lenders, 85 Fed. Reg. 26,324 (May 4, 2020). Without any
significant elaboration, this rule simply provides that “businesses that are part of a
single corporate group shall in no event receive more than $20,000,000 of PPP loans
in the aggregate,” and deems businesses to be “part of a single corporate group if
they are majority owned, directly or indirectly, by a common parent.” Id. at 26,325
(emphasis added). And remarkably, the SBA insisted this rule’s treatment of
corporate affiliates applies to all businesses, even those in the hospitality industry:
Without any explanation or justification whatsoever, the SBA announced that
“[b]usinesses are subject to this [Corporate Group Maximum] limitation even if the
businesses are eligible for the waiver-of-affiliation provision under the CARES Act.”
Id. (emphasis added).
21. On January 14, 2021, the SBA promulgated another regulation—which
the agency refers to as its “Consolidated First Draw PPP IFR”—intended to
incorporate the Economic Aid Act and consolidate in one place the myriad “interim
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final rules (and important guidance)” the agency had issued over the prior nine
months regarding eligibility for First Draw PPP loans. SBA, Business Loan Program
Temporary Changes; Paycheck Protection Program as Amended by Economic Aid
Act, 86 Fed. Reg. 3692, 3692 (Jan. 14, 2021). In doing so, the SBA double downed
on its defiance of the CARES Act’s waiver of affiliation rules—again without
offering any explanation. See id. at 3702 (restating the $20 million Corporate Group
Maximum Rule and reiterating that “[b]usinesses are subject to this limitation even
if the businesses are eligible for the waiver-of-affiliation provision under the CARES
Act”).
22. The same day, the SBA promulgated a regulation addressing Second
Draw PPP loans. SBA, Business Loan Program Temporary Changes; Paycheck
Protection Program Second Draw Loans, 86 Fed. Reg. 3712 (Jan. 14, 2021). This
regulation acknowledged that, under the Economic Aid Act, “[t]he affiliation rules
under 13 CFR 121.301(f) are waived with respect to eligibility for a Second Draw
PPP Loan” for hospitality businesses with 300 or fewer employees. Id. at 3718. At
the same time, however, the regulation adopted a Corporate Group Maximum Rule
for Second Draw loans, this time with a $4 million aggregate cap. Id. at 3720. The
regulation does not provide any detail on how this Corporate Group Maximum Rule
works and does not directly address whether this Rule also purports to trump the
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statutory waiver of affiliation rules: It simply provides that “Corporate group has the
same meaning as in … the Consolidated First Draw PPP IFR.” Id.
III. The SBA Applies the Corporate Group Maximum Rule to Wrongfully
Deny Forgiveness of CHH’s Second Draw Loan
23. This case involves the SBA’s denial of forgiveness of CHH’s Second
Draw PPP loan, for which CHH applied on May 29, 2021.
24. At that point, CHH had already successfully applied for a First Draw
loan. CHH is one of a group of 98 family-owned entities (collectively known as the
“Russell Group”), that together employ more than 1,100 individuals. But because
CHH is a hospitality business—it is assigned a North American Industry
Classification code beginning with 72 (722513)—and itself has fewer than 500
employees, it was plainly eligible for a First Draw loan under the CARES Act’s
waiver of affiliation rules. 15 U.S.C. § 636(a)(36)(D)(iv).
25. Accordingly, CHH applied for a $2 million Second Draw PPP loan, and
CHH’s lender, Citizens Trust Bank, approved and disbursed the loan on June 1,
2021.
26. On July 19, 2022, CHH filed PPP Loan Forgiveness Application Form
3508S, seeking full forgiveness of the Second Draw loan.
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27. On November 21, 2022, CHH received the SBA’s Final Loan Review
Decision entirely denying forgiveness of the loan.3 Notably, the SBA did not dispute
that CHH used the Second Draw loan for the statutorily prescribed purposes—
namely, to ensure the continued employment of its employees. See 15 U.S.C.
§ 636(a)(37)(J). Nor did it dispute that, pursuant to the statutory waiver of affiliation
rules, CHH satisfied the 300-employee limit applicable to Second Draw loans;
indeed, the SBA expressly “recommend[ed] denial even though borrower has a
NAICS 72 waiver of the affiliation rules.” Rather, the SBA rested its decision on a
single ground—that CHH “exceeded corporate group limit at the time of
disbursement.”
28. On December 21, 2022, CHH timely appealed the SBA’s Final Loan
Review Decision to SBA’s OHA.
29. On March 20, 2023, the OHA issued its decision affirming the SBA’s
Final Loan Review Decision.4 Again, the OHA’s conclusion relied solely on the
Corporate Group Maximum Rule. The OHA explained that when CHH’s Second
Draw loan was disbursed on June 1, 2021, the affiliates in CHH’s “corporate group”
had already obtained about $3.4 million in Second Draw loans. Because CHH’s $2
3
CCH has attached a true and accurate copy of the SBA’s Final Loan Review
Decision as Exhibit C.
4
CCH has attached a true and accurate copy of the OHA’s decision as Exhibit D.
12
million loan put the “corporate group” total at $5.4 million (and thus over the $4
million maximum), the OHA affirmed the denial of forgiveness of CHH’s entire $2
million loan. The OHA Decision, in other words, determined that CHH’s affiliates
rendered it ineligible for any Second Draw PPP loan.
IV. The SBA’s Decision to Apply the Corporate Group Maximum Rule to
CHH Violates the Plain Statutory Text
30. The SBA’s application of the Corporate Group Maximum Rule to CHH
is contrary to the plain text, purpose, and context of the CARES Act and the
Economic Aid Act. It directly contravenes 15 U.S.C. §§ 636(a)(36)(D)(iv) and
636(a)(37)(E), which specifically waive the SBA’s “provisions applicable to
affiliations … with respect to [CHH’s] eligibility” for PPP loans.
31. The SBA recognizes that the statutory waiver of affiliation rules applies
to CHH and that CHH therefore falls under the 300-employee cap for Second Draw
loans. Yet it concluded—without explaining why—that this statutory waiver does
not apply to its Corporate Group Maximum Rule.
32. The SBA’s unreasoned decision flies in the face of the statutory text.
The waiver of affiliation rules applies broadly to the then-existing SBA affiliation
rules and “any successor regulation.” 15 U.S.C. §§ 636(a)(36)(D)(iv) (emphasis
added). The Corporate Group Maximum Rule is plainly such a “successor
regulation,” since it imposes a cap on PPP Loans based on an entity’s corporate
13
affiliates. Indeed, the Rule adopts the same affiliate test (majority ownership by a
common parent) included in the expressly waived affiliation rules. See 13 C.F.R.
§§ 121.103(a)(1), (c)(1), 121.301(f).
33. The SBA’s decision also contradicts the underlying purpose of the
statutory waiver of affiliation rules: In response to the dire circumstances faced by
hospitality businesses and their employees, Congress sought to preserve such
businesses’ eligibility for PPP loans by directing the SBA to treat hospitality
businesses as distinct entities without regard to their affiliates.
34. Because the SBA’s application of the Corporate Group Maximum Rule
to CHH violates Congress’s command, its decision is “not in accordance with law”
and “in excess of statutory jurisdiction, authority, or limitations, or short of statutory
right.” 5 U.S.C. § 706(2)(A), (C). The SBA’s Final Loan Review Decision and the
OHA Decision to affirm should therefore be set aside. 5 U.S.C. § 706(2)(A).
V. The SBA’s Manner of Applying the Corporate Group Maximum Rule
Was Not Required by the Rule and Was Arbitrary and Capricious
35. Beyond resting on the plainly unlawful Corporate Group Maximum
Rule, the SBA’s decision applied the Rule in an arbitrary and capricious manner not
required by the Rule’s sparse text.
36. First, to conclude that CHH’s loan exceeded the $4 million cap, the
SBA determined that CHH’s affiliates had already obtained $3.4 million in Second
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Draw loans. And this $3.4 figure includes an affiliate’s $2 million Second Draw loan
that the SBA thinks is invalid and not forgivable because that affiliate (combined
with its affiliates) exceeds the 300-employee cap, and because that affiliate is not in
the hospitality industry and (in the SBA’s view) is therefore not subject to the
statutory waiver of affiliation. Notably, if the SBA had not counted this purportedly
invalid loan towards the $4 million cap, CHH’s loan would have been eligible for
forgiveness even under the Corporate Group Maximum Rule. This approach—not
required by the text of the Rule—is arbitrary and capricious.
37. Second, the SBA concluded that CHH’s entire loan was ineligible for
forgiveness even though on the SBA’s view CHH was still eligible for about
$600,000 of Second Draw loans. Again, this approach is both inequitable and not
required by the text of the Corporate Group Maximum Rule. Indeed, this approach
implies that the SBA would deny forgiveness of a restaurant’s entire $2 million PPP
loan if, when that loan was disbursed, its affiliates had already collectively received
$2,000,001 in loans—even if the restaurant had used the loan as intended to keep its
employees on payroll in extremely difficult economic circumstances. This result is
irreconcilable with both the statutory text, the purpose of the PPP, and elementary
principles of fairness.
38. For each of these reasons, the SBA’s decision to completely deny
forgiveness of CHH’s Second Draw loan was arbitrary, capricious, and (to the extent it
15
constituted an exercise of discretion at all) an abuse of discretion in violation of
5 U.S.C. § 706(2)(A). The SBA’s Final Loan Review Decision and the OHA
Decision to affirm should therefore be set aside. 5 U.S.C. § 706(2)(A).
FIRST CLAIM FOR RELIEF (JUDICIAL REVIEW)
39. This Court is authorized and empowered to review the SBA’s Final
Loan Review Decision and the OHA Decision for errors.
40. The SBA’s Final Loan Review Decision and the OHA Decision both
were erroneous as a matter of law, constituted arbitrary and capricious conduct by
the SBA, were made based upon a rule established through an excess of statutory
authorization, and constituted an abuse of discretion, all in violation of 5 U.S.C.
§ 706(2)(A), (C).
41. The Court should hold that the Final Loan Review Decision and the
OHA Decision were unlawful, should set aside the Final Loan Review Decision and
the OHA Decision, and should direct the SBA to grant forgiveness to CHH regarding
its PPP Loan.
SECOND CLAIM (DECLARATORY JUDGMENT)
42. There is an actual and existing controversy between the parties as to the
correctness of the SBA’s decision to apply the Corporate Group Maximum Rule to
deny forgiveness of CHH’s Second Draw loan in its entirety.
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43. The SBA’s application of the Corporate Group Maximum Rule to
CHH’s Second Draw PPP loan was legal error, was arbitrary and capricious, was
made in excess of SBA’s statutory authority, and constituted an abuse of discretion
in violation of 5 U.S.C. § 706(2)(A), (C).
44. CHH is therefore entitled to a judgment declaring that the Corporate
Group Maximum Rule cannot be applied to businesses protected by the statutory
waiver of affiliation rules, and declaring that the SBA’s application of the Corporate
Group Maximum Rule to CHH’s Second Draw PPP loan was legal error, was
arbitrary and capricious, was made in excess of SBA’s statutory authority, and
constituted an abuse of discretion.
PRAYER FOR RELIEF
WHEREFORE, CHH respectfully prays that the Court grant it the following
relief:
i. Grant CHH’s Petition for Review;
ii. Reverse and set aside the Final Decision and OHA Decision, and
direct the SBA to issue a new decision on CHH’s forgiveness
application forgiving its PPP Loan;
iii. Vacate the Corporate Group Maximum Rule and declare that it is not
authorized by, and is contrary to, the CARES Act;
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iv. Award costs and reasonable attorneys’ fees to the extent permitted
by law; and
v. Grant such other relief as this Court may deem just and proper.
Respectfully submitted, this 29th day of April, 2024.
/s/ Eric S. Fisher
Eric S. Fisher
Georgia Bar No. 250428
BARNES & THORNBURG LLP
3340 Peachtree Road N.E., Suite 2900
Atlanta, GA 30326-1092
Tel. (404) 264-4045
EFisher@btlaw.com
Kian J. Hudson
(pro hac vice application forthcoming)
BARNES & THORNBURG LLP
11 South Meridian Street
Indianapolis, IN 46204
Tel. (317) 229-3111
Kian.Hudson@btlaw.com
Counsel for Petitioner Concessions HH, JV
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