Rilley v. Moneymutual LLC

884 N.W.2d 321 (2006)

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Nature of the Case

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Facts

D operates a website that allows people to apply for short-term loans, commonly known as 'payday loans.' After an individual submits a loan application through D's website, D 'matches' the applicant with a payday lender in its network. For each matched applicant, D receives a 'lead' fee from the lender. Rilley (Ps) filed a class-action complaint, alleging that D matched Ps with payday lenders that were unlicensed in Minnesota; that the terms of the payday loans were illegal under Minnesota's statutes because, the APRs advertised by D-which ranged 'between 261% and 1304% for a 14 day loan'-exceeded the maximum allowable APRs under Minnesota law. D moved to dismiss the complaint for lack of personal jurisdiction. Ps alleged that D sent several emails to Minnesota residents in connection with generating business once D had 'matched' the applicant with a particular payday lender. These emails were sent after the application and had valid physical address information as part of the application process. D also sent emails to applicants who started but did not finish their online application. These emails urged the applicant to complete the application in order to be matched with a payday lender. D also sent emails to prior loan applicants inviting them to apply for additional loans. D sent over 1000 such emails. D also purchased television advertising with Montel Williams promoting the website. D also targets Minnesota customers through Google AdWords with specific search terms targeted at Minnesota residents. The court held against D, and the appeals court affirmed. The Supreme Court of Minnesota granted certiorari.