Jason E. Manning (VSB No. 74306)

Maryia Y. Jones (VSB No. 78645)

TROUTMAN SANDERS LLP

222 Central Park Avenue, Suite 2000

Virginia Beach, Virginia 23462

Telephone: (757) 687-7564

Facsimile: (757) 687-1524

E-mail: jason.manning@troutmansanders.com

E-mail: maryia.jones@troutmansanders.com

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

In re: Dori Danyelle Wingate Case No. 15-35033-KLP

Chapter 13

Debtors,

Dori Danyelle Wingate, Individually and on 

Behalf of a class of similarly situated individuals, APN: 17-04453-KLP

Plaintiff,

v.

BLUECHIP FINANCIAL,

d/b/a SPOTLOAN, 

and 

AMERICAN INFOSOURCE LP,

Defendants.

MEMORANDUM IN SUPPORT OF MOTION TO COMPEL ARBITRATION

AND DISMISS OR STAY THIS ACTION PENDING BINDING ARBITRATION

Defendant American Infosource LP (“AIS”), by counsel, hereby moves this Court, 

pursuant to the Federal Arbitration Act (“FAA”), 9 U.S.C. § 1 et seq., to compel arbitration of 

this proceeding and either stay or dismiss this action, for the reasons set forth below. 

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INTRODUCTION

This putative Class Action Complaint arises from a loan agreement (the “Loan 

Agreement) between Plaintiff Dori Danyelle Wingate (“Plaintiff”) and Defendant Blue Chip 

Financial d/b/a Spotloan (“Spotloan”) which is organized under the laws of the Turtle Mountain 

Band of Chippewa Indians. 

As an agent for Spotloan, AIS filed Proofs of Claim in Plaintiff’s ongoing Chapter 13 

bankruptcy case. In re Wingate, No. 15-bk-3503. In this adversary proceeding, Plaintiff alleges 

that the Proofs of Claim “intentionally and willfully misrepresented that no interest was 

included” in the claimed amount. Compl. ¶ 28. On the basis of these allegations, Plaintiff brings 

claims against AIS for violations of the Fair Debt Collections Practices Act, 15 U.S.C. § 1692, et 

seq., and claims for violations of Fed. R. Bankr. P. 3001 against Spotloan. Id. ¶¶ 48-79.

Plaintiff filed the instant adversary proceeding on June 13, 2017. AIS’ responsive 

pleading is due today and is being filed concurrently herewith. On July 28, AIS’ counsel

contacted Plaintiff’s counsel to request Plaintiff’s consent to arbitration pursuant to a binding 

Arbitration Clause and Jury Waiver (the “Arbitration Clause”) included in the Loan Agreement. 

Plaintiff’s counsel responded the same day by declining to submit this matter to arbitration. AIS 

now moves this Court to compel arbitration under the Arbitration Clause and the Federal 

Arbitration Act, 9 U.S.C. § 1, et seq. (“FAA”).

This Court should compel arbitration of Plaintiff’s FDCPA claims against AIS because 

these claims plainly fall within the scope of the valid and enforceable Arbitration Clause and 

meet each of the four prerequisites to arbitration. 

(1) a dispute exists between Plaintiff and AIS as evidenced by the Complaint; 

(2) the dispute is subject to a written, binding Arbitration Clause; 

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(3) the loan transaction at issue involves interstate commerce—a loan was extended

to Plaintiff who is a citizen of Virginia by Spotloan which is located in North Dakota and Proofs 

of Claim were filed by AIS which is located in Texas; and 

(4) Plaintiff refused to arbitrate the dispute. 

Despite Plaintiff’s contentions in the Complaint to the contrary, the Arbitration Clause is 

valid and enforceable, and Plaintiff’s reliance on the decision by the Fourth Circuit Court of 

Appeals in Dillon v. BMO Harris Bank, N.A., 856 F.3d 330 (4th Cir. 2017) is inapposite because 

the Arbitration Clause does not attempt to waive Plaintiff’s federal substantive rights in favor of 

the tribal law. Thus, a doctrine of prospective waiver is not implicated and does not bar 

enforcement of the Arbitration Clause. Should the Court find the choice of law clause

unenforceable, the appropriate remedy is to sever the clause and compel arbitration. 

ARGUMENT

“State and federal courts must enforce the FAA with respect to all arbitration agreements 

covered by that statute.” Marmet Health Care Ctr., Inc. v. Brown, 565 U.S. 530, 530-31 (2012). 

The FAA provides, in relevant part:

[i]f any suit or proceeding be brought in any of the courts of the 

United States upon any issue referable to arbitration under an 

agreement in writing for such arbitration, the court in which such 

suit is pending, upon being satisfied that the issue involved in such 

suit or proceeding is referable to arbitration under such an 

agreement, shall on application of one of the parties stay the trial 

of the action until such arbitration has been had in accordance with 

the terms of the agreement.

9 U.S.C. § 3.

The Supreme Court of the United States has emphasized that the FAA represents a 

“liberal federal policy favoring arbitration” and has clearly recognized a presumption that 

disputes between parties to an arbitration agreement should be resolved in an arbitral forum. See

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Green Tree Fin. Corp.-Alabama v. Randolph, 531 U.S. 79, 91 (2000). The presumption that 

parties to an arbitration agreement intended their disputes to be resolved through arbitration is so 

strong that “any doubts concerning the scope of arbitrable issues should be resolved in favor of 

arbitration.” Potenciano Aggarao v. MOL Ship Mgmt. Co., Ltd., 675 F.3d 355, 368-69 (4th Cir 

2012) (quoting Moses H. Cone Mem’l Hosp., 460 U.S. 1, 24-25 (1983)). 

“Agreements to arbitrate are construed according to the ordinary rules of contract 

interpretation, as augmented by a federal policy requiring that all ambiguities be resolved in 

favor of arbitration.” Choice Hotels, 252 F.3d 707, 710 (4th Cir. 2001) (citing First Options of 

Chi., Inc. v. Kaplan, 514 U.S. 938, 944–45 (1995)). Parties to a contract are generally “free 

within bounds to use a choice of law clause in an arbitration agreement to select which local law 

will govern the arbitration” because such provisions contribute to “predictability and thus 

efficiency” to help resolve parties’ disputes. Hayes v. Delbert Servs. Corp., 811 F.3d 666, 675 

(4th Cir. 2016) (citing Rota-McLarty v. Santander Consumer USA, Inc., 700 F.3d 690, 697 n.7 

(4th Cir. 2012)).

According to the Fourth Circuit Court of Appeals, arbitration should be compelled under 

the FAA where the movant can demonstrate (1) the existence of a dispute between the parties, 

(2) a written agreement that includes an arbitration provision which purports to cover the dispute, 

(3) the relationship of the transaction, which is evidenced by the agreement, to interstate or 

foreign commerce, and (4) the failure, neglect or refusal of a party to arbitrate the dispute. 

Whiteside v. Teltech Corp., 940 F.2d 99, 102 (4th Cir. 1991). Each of these four elements is met 

in this case.

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1. A dispute exists between the parties.

There is clearly a dispute between the parties. Plaintiff has filed a Class Action 

Complaint against the Defendants alleging, inter alia, violations of the FDCPA based on the 

Proofs of Claim filed by AIS as an agent for Spotloan. Compl. ¶¶ 47-62. AIS denies that 

Plaintiff is entitled to the relief requested in the Complaint and denies any allegations of 

wrongdoing. Thus, there is a dispute between Plaintiff and AIS that could be efficiently resolved 

through arbitration.

2. The disputes between Plaintiff and AIS are subject to an enforceable, binding 

arbitration agreement. 

The claims alleged by Plaintiff in the Complaint are subject to a written arbitration 

agreement. Namely, the Loan Agreement signed by Plaintiff included, within its terms, a 

binding Arbitration Clause, which provides that, by accepting this Clause, Plaintiff agrees to 

arbitrate, and waives the right to litigate, disputes. Compl. Ex. 2, p. 9, ECF No. 1-2. The term 

“disputes” has “the broadest possible meaning,” including “all claims even indirectly related to 

your ... agreements with us.” Id. at p. 10. The Arbitration Clause applies not just to Plaintiff 

and Spotloan, but also to “their successors and assigns, along with any third parties related to any 

Dispute.” Id. at p. 9. Plaintiff’s claims are plainly related to the Loan Agreement and AIS is a 

named Defendant in the instant action that arises from the Loan Agreement. 

Therefore, the second element is satisfied. Despite this undeniable conclusion, Plaintiff 

asserts in the Complaint that the arbitration agreement is invalid under the Fourth Circuit Court 

of Appeals’ recent decision in Dillon, 856 F.3d 330. Compl. ¶¶ 40-41. Plaintiff is wrong.

 

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a. The Arbitration Clause is enforceable as written.

Plaintiffs’ reliance on Dillon is misplaced because the terms of an arbitration agreement 

in Dillon are materially different from the Arbitration Clause that does not seek to disclaim 

application of any federal laws.

In Dillon, the Fourth Circuit applied a “prospective waiver doctrine” to determine 

whether the arbitration agreement was enforceable. Id. at 332 (citing Mitsubishi Motors Corp. v. 

Soler Chrysler-Plymouth, Inc., 473 U.S. 614, 637 n.19 (1985); Am. Express Co. v. Italian Colors 

Rest., 133 S. Ct. 2304, 2310 (2013)). As the court in Dillon accurately stated, pursuant to the 

prospective waiver doctrine “courts will not enforce an arbitration agreement if doing so would 

prevent a litigant from vindicating federal substantive statutory rights. 856 F.3d at 332

(emphasis added) (citing Am. Express Co., 133 S. Ct. at 2310; 14 Penn Plaza LLC v. Pyett, 556 

U.S. 247, 273-74 (2009); Gilmer v. Interstate/Johnson Lane Corp., 500 U.S. 20, 28 (1991)). The 

prospective waiver doctrine is meant to preclude attempts to “convert a choice of law clause into 

a choice of no law clause” and to prevent such attempts “to renounce the authority of the federal 

statutes.” Hayes, 811 F.3d at 675 (emphasis added, citations omitted); see also 14 Penn Plaza 

LLC, 556 U.S. at 273-74 (stating that “a substantive waiver of federally protected civil rights

will not be upheld”). 

Prospective waiver plainly does not apply to waivers of state laws and the undersigned is 

not aware of any case law to the contrary. See AT&T Mobility LLC v. Concepcion, 563 U.S. 333, 

344 (2011) (holding that FAA preempts state laws hostile to arbitration). This is especially true 

here where Plaintiff is not alleging any claims under state law but instead is seeking to enforce 

her rights under a federal consumer protection statute, the FDCPA. Therefore, the Arbitration 

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Clause does not “prevent [Plaintiff] from vindicating [her] federal substantive statutory rights” in 

any way. Dillon, 856 F.3d at 332 (double emphasis added).

In both Dillon and Hayes, the Fourth Circuit found the particular arbitration agreements 

unenforceable not because of a waiver of any state laws, but because of a prospective waiver of 

substantive federal rights. In Dillon, both an underlying loan agreement and arbitration 

agreement required application of tribal law and disclaimed application of state and federal law. 

Id. at 331. The arbitration agreement further provided that “any dispute . . . will be resolved by 

arbitration in accordance with the [tribal law]” and that the arbitrator must apply the tribal law, to 

the exclusion of any other law. Id. Further, even if a borrower wanted to opt out of arbitration, 

the arbitration provision in Dillon stated that “‘any disputes . . . shall nonetheless be governed 

under the laws of the Otoe-Missouria Tribe of Indians and must be brought within the court 

system thereof.’” Id. (quoting the arbitration agreement.) 

In determining whether the arbitration clause was enforceable, the Fourth Circuit referred 

back to its own decision in Hayes, in which the court applied the prospective waiver doctrine to 

another arbitration agreement. Id. at 333. In Hayes, the court “observed that the language 

disclaiming any law other than the tribal law ‘almost surreptitiously waive[d] a potential 

claimant’s federal rights through the guise of a choice of law clause’ and ‘flatly and 

categorically renounce[d] the authority of the federal statutes.’” Dillon, 856 F.3d at 332 

(emphasis added) (quoting Hayes, 811 F.3d at 675). Because such language took the “‘plainly 

forbidden’ step of prospectively waiving federal substantive rights,” the court concluded that the 

challenged choice of law provision was unenforceable as a matter of law. Hayes, 811 F.3d at 

675. The language at issue in Dillon was “not distinguishable in substance from the related 

provisions” in Hayes, and the court predictably reached the same result on the grounds that “the 

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arbitration agreement functions as a prospective waiver of federal statutory rights and, therefore, 

is unenforceable as a matter of law.” 856 F.3d at 333 (citing Hayes, 811 F.3d at 676.). 

In dictum, Hayes noted a “brazen” disclaimer of both federal and state laws, but at no 

time did the court hold in either case that a limited waiver of state laws only would render an 

arbitration agreement unenforceable. 811 F.3d at 676; see also Dillon, 856 F.3d at 334 (waiver 

of state laws, in addition to federal laws, lent further support to the court’s holding). Such 

question was not before the court and, even if it was, the result would be the same because the 

prospective waiver doctrine does not apply to waivers of state law. As the Fourth Circuit

emphasized in both Dillon and Hayes, its main concern was with the obvious “animating 

purposes of the arbitration agreements” at issue in those cases “to ensure that [the lender] could 

engage in lending and collection practices free from the strictures of any federal law.” Dillon, 

856 F.3d at 334 (emphasis added) (citing Hayes, 811 F.3d at 676).

Here, the Arbitration Clause differs from the arbitration agreements in Dillon and Hayes

in a critical respect, that is: the Arbitration Clause does not waive federal law in general or 

Plaintiff’s substantive federal rights in particular. On the contrary, the waiver provision in the 

Loan Agreement here is expressly limited to the “United States state law,” Compl. Ex. 2, at p. 9

(emphasis added), and the Arbitration Clause here states that arbitration is to be governed by the 

FAA and, only if the FAA is found inapplicable by a court, then Plaintiff’s state law 

governs. Id. at p. 10. Clearly, prospective waiver is not implicated here because the Loan 

Agreement does not “waive [Plaintiff’s] federal rights”—which are the only rights that Plaintiff 

seeks to vindicate through his claims for violations of the FDCPA—and does not “renounce the 

authority of the federal statutes.’” Hayes, 811 F.3d at 675; see Jarry v. Allied Cash Advance Va., 

L.L.C., 175 F. Supp. 3d 622, 626 (W.D. Va. 2016) (distinguishing Hayes because the arbitration 

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clause applied to “any claim arising under ... a federal or state statute” and thus did “not reject 

the wholesale application of federal and state law”).

A holding that the Arbitration Clause which does not waive federal substantive rights and 

requires application of the FAA is unenforceable would directly contradict the controlling 

precedent by both the United States Supreme Court and the Fourth Circuit Court of Appeals that 

limit application of the prospective waiver doctrine to renunciation of federal substantive rights, 

not state laws. Accordingly, the second factor is satisfied.

b. In the alternative, the choice of law provision in the Arbitration Clause is 

severable.

The Fourth Circuit Court of Appeals has held that, if a district court finds a provision in 

an arbitration agreement to be unenforceable, the court then must decide “whether severance of 

[such] provision[], rather than invalidation of the arbitration agreements, would be the 

appropriate remedy.” Atl. Textiles v. Avondale Inc., 505 F.3d 274, 292 (4th Cir. 2007) (citations 

omitted); see also Rent-A-Ctr., W., Inc. v. Jackson, 561 U.S. 63, 71 (2010) (stating that “a party’s

challenge to another provision of the contract, or to the contract as a whole, does not prevent a 

court from enforcing a specific agreement to arbitrate”). 

Federal appellate courts nationwide have reached the same conclusion. See, e.g.,

Terminix Int’l Co. v. Palmer Ranch Ltd. P’ship, 432 F.3d 1327, 1331 (11th Cir. 2005) (“If all the 

provisions of the arbitration clause are enforceable, then the court must compel arbitration 

according to the terms of the agreement. If, however, some or all of its provisions are not 

enforceable, then the court must determine whether the unenforceable provisions are 

severable.”); see also Kristian v. Comcast Corp., 446 F.3d 25, 64 (1st Cir. 2006) (severing 

provisions that precluded plaintiff from pursuing his statutory remedies and compelling 

arbitration); Hadnot v. Bay, Ltd., 344 F.3d 474, 478 (5th Cir. 2003) (severing an unenforceable 

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ban on punitive damages and compelling arbitration); Spinetti v. Service Corp. Int'l, 324 F.3d 

212, 219-23 (3d Cir. 2003) (severing invalid provisions regarding attorney’s fees and requiring 

the parties to arbitrate); Gannon v. Circuit City Stores, Inc., 262 F.3d 677, 683 (8th Cir. 2001) 

(severing unenforceable ban on punitive damages and compelling arbitration).

As the Southern District of Florida explained, “two policy interests at issue ... must be 

respected, if possible. The first is the powerful [policy] in favor of arbitration. The second is the 

policy ... to protect a party’s right to pursue statutory remedies.” Krstic v. Princess Cruise 

Lines, Ltd., 706 F. Supp. 2d 1271, 1280 (S.D. Fla. 2010) (severing the choice of law provision 

and compelling arbitration). “[S]everance of the unenforceable choice-of-law provision is the 

appropriate remedy, as it promotes both policies at issue without having to unnecessarily elevate 

one over the other.” Id.; see also Galen v. Redfin Corp., No. 14-cv-05229, 2015 U.S. Dist. 

LEXIS 161111, at *30 (N.D. Cal. Dec. 1, 2015) (severing feeshifting, forum selection, and 

choice of law clauses and delegating the question of arbitrability to the arbitrator). 

In Dillon and Hayes, the Fourth Circuit Court of Appeals refused to sever the invalid 

choice of law provision on the grounds that the provision required application of the tribal law to 

the exclusion of all state and federal laws and, thus, such provision went to the “essence” and 

“animating purpose” of the contract to engage in consumer lending without federal regulation. 

Hayes, 811 F.3d at 676; Dillon, 856 F.3d at 335. The Court in Dillon found further support for 

declining to sever based on the adhesive language in the contract that was “a calculated attempt 

to avoid the application of state and federal law.” Id.

Unlike Dillon and Hayes, the Loan Agreement and the Binding Arbitration Clause do not 

attempt to avoid application of the federal consumer laws, as explained in more detail above; 

thus the choice of law provision does not go to the core of the contract, i.e., to extend loans to 

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consumers, subject to federal consumer protection statutes. The choice of law provision is 

“merely collateral to the main purpose of the arbitration agreement,” Vargas v. Delivery 

Outsourcing, LLC, No. 15-cv-03408-JST, 2016 U.S. Dist. LEXIS 32634, at *34 (N.D. Cal. Mar. 

14, 2016), and if found to be unenforceable, should be severed. 

In addition, the Arbitration Clause was not adhesive because it expressly provided 

Plaintiff with a choice of opting out of the Arbitration Clause within 60 days of signing the Loan 

Agreement. Compl. Ex. 2, p. 7, ECF 1-2.1 As the Supreme Court observed in AT&T Mobility, 

LLC, although “[s]tates remain free to take steps addressing the concerns that attend contracts of 

adhesion, ... [s]uch steps cannot ... conflict with the FAA or frustrate its purpose to ensure that 

private arbitration agreements are enforced according to their terms.” 563 U.S. at 347 n.6.

On balance, severance of the choice of law provision and enforcement of the arbitration 

clause will accomplish both of the important policies—presumption in favor of arbitration and 

avoidance of prospective waiver of federal substantive rights to the extent it is implicated here 

(and it is not)—without elevating one over the other. Accordingly, if the Court deems the choice 

of law provision unenforceable, the Court should sever this provision and compel arbitration. 

3. The loan transaction involves interstate commerce.

Interstate commerce is implicated in a transaction, so long as “in the aggregate the 

economic activity in question would represent a general practice ... subject to federal control.” 

Citizens Bank v. Alafabco, Inc., 539 U.S. 52, 56-57, 123 S.Ct. 2037, 156 L.Ed.2d 46 (2003) 

(internal quotation and citation omitted). “No elaborate explanation is needed to make evident 

 

1

The arbitration agreement in Hayes did not include any opt-out clause whatsoever, Hayes, 811 

F.3d at 669-70, and, although an “opt-out” clause was ostensibly present in the arbitration 

agreement in Dillon, it had no force or effect because it still limited plaintiff to resolution of 

disputes under the tribal law within the tribal court system, 856 F.3d at 331. By contrast, the optout clause here provides Plaintiff with a choice of opting out of the Arbitration Clause.

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the broad impact of commercial lending on the national economy or Congress’s power to 

regulate that activity pursuant to the Commerce Clause.” Id. It is also beyond dispute that

consumer loans, like the one entered into by Plaintiff, are subject to federal laws and regulations 

because they affect interstate commerce. See, e.g., 15 U.S.C. § 1602 (broadly defining “credit” 

for application of the federal Truth in Lending Act); National Home Equity Mortg. Ass'n v. Face, 

64 F. Supp. 2d 584, 592 (E.D. Va. 1999) (recognizing that “the borrowing and lending of money 

is commerce that falls within Congress’ broad commerce power.”). Plaintiff is a citizen of 

Virginia while both Spotloan and AIS are located out of state. Thus, this loan transaction 

implicates interstate commerce and easily satisfies the third prong in support of compelling 

arbitration.

4. Plaintiff refuses to arbitrate.

The fourth prong—a refusal or failure to arbitrate—is also satisfied. Prior to filing this 

Motion, Defendant’s counsel contacted Plaintiff’s Counsel to inquire whether Plaintiff would 

consent to arbitration pursuant to the Arbitration Clause in the Loan Agreement signed by

Plaintiff. Plaintiff’s counsel responded that he did not consent to arbitration. Thus, the fourth 

prong—a refusal to arbitrate—has been met and arbitration is warranted.

2

CONCLUSION

For the reasons set forth above, Defendant American Infosource L.P. respectfully 

requests that the Court grant this Motion to Compel Arbitration and that the Court dismiss or stay

this Action and grant AIS’ attorney’s fees and costs incurred in bringing this motion.

 

2

Spotloan responded that it reserves the right to join AIS’ Motion to Compel Arbitration.

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Dated this 31 day of July, 2017. Respectfully Submitted,

AMERICAN INFOSOURCE LP

By: /s/ Jason E. Manning

Of Counsel

Jason E. Manning (VSB No. 74306)

Maryia Y. Jones (VSB No. 78645)

TROUTMAN SANDERS LLP

222 Central Park Avenue, Suite 2000

Virginia Beach, Virginia 23462

Telephone: (757) 687-7564

Facsimile: (757) 687-1524

E-mail: jason.manning@troutmansanders.com

E-mail: maryia.jones@troutmansanders.com

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CERTIFICATE OF SERVICE

I hereby certify that on this 31st day of July, 2017, I electronically filed the foregoing 

Memorandum in Support of Motion to Compel Arbitration with the Clerk of the Court using the 

CM/ECF system, which will send notification of such filing to all CM/ECF participants

/s/ Jason E. Manning

Jason E. Manning (VSB No. 74306)

Maryia Y. Jones (VSB No. 78645)

TROUTMAN SANDERS LLP

222 Central Park Avenue, Suite 2000

Virginia Beach, Virginia 23462

Telephone: (757) 687-7564

Facsimile: (757) 687-1524

E-mail: jason.manning@troutmansanders.com

E-mail: maryia.jones@troutmansanders.com

Counsel for American Infosource LP

32040724

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