Summary
The United States District Court for the Middle District of Florida granted in part and denied without prejudice in part Defendant APP Academy’s renewed motion concerning arbitration and venue. The court held that the parties’ forum-selection clause required the action to be brought in the Northern District of California and ordered the case transferred to that district. The court did not decide whether the dispute was subject to arbitration, leaving that issue for the appropriate forum.
Topics
Practice areas
Questions Presented
- Whether the Enrollment Agreement's forum-selection clause applied to Plaintiffs' RICO claims.
- Whether the forum-selection clause was valid and enforceable under the circumstances.
- Whether the action should be transferred from the Middle District of Florida to the Northern District of California.
- Whether the court should compel arbitration or stay the action.
Holdings
- The broad forum-selection clause applied to Plaintiffs' claims because the claims arose directly from their enrollment in and participation in the educational program covered by the Enrollment Agreement.
- The forum-selection clause was presumptively valid, enforceable, and applicable, and the action had to be transferred to the Northern District of California.
- The court did not decide whether the dispute was subject to mandatory arbitration; the arbitration request was denied without prejudice to seeking relief in the appropriate forum.
Key quotations
“Because the forum selection clause is enforceable and applicable to the claims brought by Plaintiffs, the clause must be enforced, and the case must be transferred to the Northern District of California.”
Factual background
Plaintiffs enrolled in an online software-engineering coding bootcamp operated by Hash Map Labs, Inc., doing business as APP Academy. They alleged that the defendants falsely represented that the program guaranteed job placement and later made substantial changes to the program, including reducing resources, staffing, and support. Plaintiffs asserted RICO claims arising from their enrollment agreements, which contained California governing-law and forum-selection provisions requiring actions to be brought in California, including the Northern District of California.
Procedural history
Plaintiffs filed suit on March 15, 2025, and amended their complaint on September 24, 2025. Defendant moved to compel arbitration or transfer venue and separately moved to dismiss for failure to state a claim. The court had previously dismissed claims against Kush Patel without prejudice for lack of service. The court granted transfer to the Northern District of California based on the forum-selection clause and did not reach the arbitration issue.
Remand instructions
The Clerk was directed to transfer the case to the San Francisco Division of the Northern District of California for all further proceedings. After transfer, the Clerk was directed to terminate pending motions and deadlines and close the case. The arbitration request was denied without prejudice to seeking to compel arbitration in the appropriate forum.