Ang Jiang Liu et al v. Uber Technologies, Inc. et al Document 21: Answer

Filed May 1, 2014

BackBack to Ang Jiang Liu et al v. Uber Technologies, Inc. et al, Superior Court of California, County of San Francisco Case No. CGC-14-536979

Answer To Complaint Filed By Defendant Uber Technologies, Inc. Rasier Llc Rasier-ca Llc

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Page 1 SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
May-01-2014 3:39 pm

Case Number: CGC-14-536979
Filing Date: May-01-2014 3:27
Filed by: ANNA TORRES
Juke Box: 001 Image: 04468603
ANSWER



ANG JIANG LIU et al VS. UBER TECHNOLOGIES, INC. et al

Instructions:
Please place this sheet on top of the document to be scanned.
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QUINN EMANUEL URQUHART &
SULLIVAN, LLP
Diane M. Doolittle (Bar No. 142046)
Morgan W. Tovey (Bar No. 136242)
Nicole Y. Altman (Bar No. 279397) California Street, 22nd Floor
San Francisco, California 94111
Telephone: (415) 875-6600
Facsimile: (415) 875-6700
Attorneys for Defendants Uber Technologies,
Inc., Rasier LLC and Rasier-CA LLC
BRADLEY CURLEY ASIANO BARRABEE
ABEL & KOWASKI
Ann Asiano (Bar No. 94891)
Michael A. King (Bar No. 77014) Larkspur Landing Circle, Suite 200
Larkspur, CA 94939
Telephone: (415) 464-8888
Facsimile: (415) 464-8887
Attorneys for Defendants Uber Technologies,
Inc. and Rasier LLC
°o
San Francisco County Superior Court
MAY 01 2014
“tit a MONLY
BY:
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
ANG JIANG LIU, AS AN INDIVIDUAL
AND AS GUARDIAN AD LITEM FOR
ANTHONY LIU, AND SUCCESSOR IN
INTEREST ON BEHALF OF THE ESTATE
OF SOFIA LIU, HUAN HUA KUANG,
ANTHONY LIU,
Plaintiffs,
vs.
UBER TECHNOLOGIES, INC., RASIER
LLC, RASIER-CA. LLC, SYED ‘MUZAFFAR,
and DOES 1- 30, =
Defendants.


CASE NO. CGC-14-536979
ANSWER AND AFFIRMATIVE
DEFENSES OF DEFENDANTS UBER
TECHNOLOGIES, INC., RASIER LLC,
AND RASIER-CA LLC TO PLAINTIFFS’
COMPLAINT
Complaint Filed: January 27, 2014
Trial Date: None Set
Case No. CGC-14-536979
ANSWER AND AFFIRMATIVE DEFENSES
OF UBER. RASTER. AND RASIER-CA
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Defendants Uber Technologies, Inc. (“Uber”), Rasier LLC (“Rasier”), and Rasier-CA LLC
(“Rasier-CA”) (hereinafter collectively referred to as the “Companies”) hereby answer this
unverified complaint filed by Plaintiffs Ang Jiang Liu, as an individual and as guardian ad litem
for Anthony Liu, and successor in interest on behalf of the estate of Sofia Liu, Huan Hua Kuang,
and Anthony Liu.
This case arises out of a tragic automobile-pedestrians accident involving Plaintiffs and
Defendant Syed Muzaffar, a former licensee of Uber’s software application (the “Uber App”).
Uber and its affiliated companies sympathize with the Liu family and understand their desire for
redress for their loss and their injuries. However, the Companies did not cause this tragic
accident.
Uber and its affiliated companies are committed to the safety of users, transportation
providers, and the public. The Uber App is designed to be used in a safe manner that complies
with all applicable laws. At the time of the accident, Mr. Muzaffar was operating his own vehicle
and was not transporting a rider who requested transportation services through the Uber App, en
route to pick up a passenger who requested transportation services using the Uber App, or
receiving a request for transportation services through the Uber App. At the time of the accident,
there was no reason for Mr. Muzaffar to interact with the Uber App. Moreover, Mr. Muzaffar was
not — and has never been — an employee of any of the Companies.
Plaintiffs attempt to hold Uber and its affiliated companies liable using what Plaintiffs’
attorney asserted in a recently authored article to be “legal theories never before advanced.”
Christopher A. Dolan, “The Sharing Economy,” Plaintiff Magazine, March 2014. At the
appropriate time, the Companies will ask the Court to apply well-established law to resolve the
novel claims asserted. For now, the Companies provide this Answer to the Complaint.
GENERAL BACKGROUND, The Named Defendants
(a) Uber and Its Affiliated Companies
Uber is a San Francisco-based technology company that developed a software application
that enables users to request transportation services from independent, third-party transportation
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ANSWER AND AFFIRMATIVE DEFENSES
OF UBER. RASIER AND RASIER-CA
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providers (i.e., the Uber App). The easy-to-use Uber App is available in 100 cities around the
world — from Ann Arbor to Zurich.
With the Uber App, riders have greater access to transportation, rendering cities more
accessible for riders. The Uber App allows riders to connect with, and request transportation
services from, a range of independent transportation providers. Through the Uber App, riders may
select one of several classes of ride options depending on the type of vehicle, including limousine
and luxury sedans (“UberBLACK?”), taxis (“uberTAXI”) and hybrid and mid-range cars
(“uberX”), the last of which is the most economical option. Users pay the transportation provider
for transportation services.
The Uber App provides transportation providers with a tool to grow their businesses and
increase their livelihood. Drivers use the Uber App to receive lead generation service. In other
words, the Uber App allows transportation providers to grow their businesses by providing a
means for them to connect with potential customers.
Uber itself does not provide transportation services and is not a transportation carrier. It
does not own vehicles or employ drivers. Rather, Uber licenses the driver version of the Uber
App to licensed independent transportation companies such as “Charter-Party Carries of
Passengers” transportation companies (““TCPs”) for the TCPs’ drivers to use, and to licensed
independent taxi drivers.
Rasier, a wholly-owned subsidiary of Uber, also licenses the Uber App from Uber and
contracts with drivers who provide peer-to-peer (“P2P”) ridesharing services requested through
the Uber App’ in an independent contractor relationship. Like Uber, Rasier does not operate any
vehicles. Rather, ridesharing drivers provide their own vehicles to provide their services, which
can be requested through the uberX car type option in the Uber App. Rasier provides drivers with
a smartphone device that is preloaded with the Uber App (the “Device”). Drivers who have

As described in more detail below, the California Public Utilities Commission (“CPUC”)
regulates these services as “Transportation Network Company (‘TNC’)” services. The CPUC also
regulates TCPs.
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ANSWER AND AFFIRMATIVE DEFENSES
OF UBER. RASIER AND RASIER-CA
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contracted with Rasier, like all drivers who use the Uber App, have the option to accept or reject
each request for transportation.
Rasier-CA is a wholly-owned subsidiary of Rasier formed to do business in California and
to hold any necessary regulatory license within the states of California. Because states in which
Rasier operates may have different regulatory requirements, Rasier has formed subsidiaries to hold
the necessary licenses and meet the regulatory requirements in each jurisdiction in which it
operates. At all times relevant to the allegations of the Complaint, Rasier-CA was not engaged in
any business. Subsequent to the Accident, Rasier-CA obtained a license from the CPUC to
operate as a TNC. Rasier-CA will perform the functions previously performed by Rasier with
respect to all California-based P2P ridesharing drivers using the Uber App — namely, entering
into an independent contractor relationship with, and licensing the Uber App to, the drivers.
(b) Mr. Muzaffar
From approximately December 5, 2013, to December 31, 2013, through two separate
contracts, Mr. Muzaffar had a license to receive ride requests through the Uber App.
Mr. Muzaffar initially used the Uber App as a driver for — and using the vehicles of —a
licensed TCP that had separately contracted with Uber. Prior to being granted access to use the
Uber App, Uber requested a background check on Mr. Muzaffar, including a criminal history and
driver’s record check, which came back clear. On or about December 5, 2013,
Mr. Muzaffar agreed to be bound by the Software License and Online Services Agreement
between Uber and the TCP. Under his Driver Addendum to that agreement, entered into directly
between him and Uber, Mr. Muzaffar acknowledged that he was an independent, for-hire
transportation provider who was maintaining a contractual relationship with a TCP to perform
passenger carrier services for the TCP’s customers. He was never an employee, agent, joint
venture or partner of Uber. From on or about December 5, 2013, to on or about December 15,, he used the Uber App to receive ride requests as a TCP driver.
On or about December 19, 2013, Mr. Muzaffar contracted with Rasier and began providing
P2P ridesharing services. Like Uber, Rasier also received a clear background check on Mr.
Muzaffar prior to contracting with him. Under the Transportation Services Provider Agreement
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ANSWER AND AFFIRMATIVE DEFENSES
OF UBER. RASIER AND RASIER-CA
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between Rasier and Mr. Muzaffar, Rasier agreed to provide user requests for transportation
services made through the uberX request option in the Uber App. The contract also provided him
with a license to use the driver-side Uber App installed on the Device. Under that Transportation
Services Provider Agreement, he acknowledged that he was not an employee, agent, joint venturer
or partner of Rasier for any purpose; rather, he was an independent contractor of Rasier engaged in
the independent business of providing transportation services with his own vehicle. As an
independent contractor, Mr. Muzaffar had complete discretion concerning whether and when to
make himself available to receive ride requests through the Uber App. He also had the option to
use any other lead generation software application service. Pursuant to the Transportation
Services Provider Agreement, in exchange for Rasier providing him its lead generation services,
including the use of the driver-side Uber App, Mr. Muzaffar paid to Rasier a service fee for each
ride request he accepted through the Uber App.
Mr. Muzaffar’s access to the Uber App to receive transportation requests was disabled
when the Companies learned of the tragic accident that occurred on December 31, 2013.
. The Regulatory Environment
In September 2013, the CPUC promulgated a comprehensive set of rules and regulations
governing ridesharing services that utilize an online-enabled application to connect passengers
with drivers using their personal vehicles, defined by the CPUC as TNCs. TNC services may be
requested through the uberX option in the Uber App.
The CPUC rules are designed to protect the public safety while “encouraging innovation
and utilization of technology to better the lives of Californians.” In promulgating these
comprehensive regulations governing TNCs (such as Rasier and Rasier-CA) the CPUC occupies
the field.
The CPUC’s September 2013 decision required TNCs to apply for a license to operate.
Rasier-CA timely applied for such a license and, on April 7, 2014, the CPUC issued a TNC
license to Rasier-CA. Prior to issuance of the TNC license, the CPUC authorized TNC services to
be requested through the Uber App through an agreement with Uber.
-5- Case No. CGC-14-536979
ANSWER AND AFFIRMATIVE DEFENSES
OF UBER. RASIER AND RASIER-CA
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. The Uber App and Device
The Uber App is a software application that allows drivers and riders to connect with each
other. The Uber App is designed to be, and should always be, used in a safe manner that complies
with all applicable laws. For example, the Uber App is designed so that a driver waiting to receive
a ride request need not monitor or otherwise interact with either the Uber App or the Device.
Using the Device, a driver can log into the Uber App to indicate that he is available for receiving
ride requests at any time. Once a driver is logged in and available to receive a ride request, the
Uber App displays a map showing the driver’s location. The drivers-side Uber App never shows
drivers the location of other drivers. The drivers-side Uber App never shows drivers the location
of individual potential riders.
The Device can only be used to run the Uber App. Drivers cannot call potential riders
through the Uber App or the Device. They cannot send text messages to potential riders through
the Uber App or the Device. They cannot send instant messages to potential riders through the
Uber App or the Device. They also cannot receive calls, text messages, or instant messages from
potential riders through the Uber App or the Device. If necessary, they can call or text passengers
using only the drivers’ own mobile phone, in a manner that complies with all applicable laws.
For these reasons, the Companies deny that the Uber App and/or Device is designed or
manufactured in a way to lead to distracted, inattentive or otherwise unlawful driving.
, The December 31, 2013 Accident
On December 31, 2013, while driving his own vehicle, Mr. Muzaffar was involved in a
tragic automobile-pedestrians accident involving Plaintiffs. The accident took place at the
intersection of Polk Street and Ellis Street. This intersection has been identified by the City of San
Francisco as a “high injury corridor.”
At the time of the accident, Mr. Muzaffar was not providing transportation services
requested through the Uber App. He was not transporting a rider who requested transportation
services through the Uber App. He was not en route to pick up a rider who requested
transportation services through the Uber App. He was not receiving a request for transportation
services through the Uber App.
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ANSWER AND AFFIRMATIVE DEFENSES
OF UBER. RASIER AND RASTER-CA
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Moreover, at the time of the accident, there was no reason for Mr. Muzaffar to interact
with the Device. The only information displayed on the screen was a GPS-generated map with his
location — akin to the information displayed by a smartphone map application, a GPS-dedicated
device, or an automobile navigation system. In sum, at the time of the accident, neither Uber nor
Rasier had provided any passenger leads for Mr. Muzaffar to accept, and none of the Companies
caused Mr. Muzaffar to act in an allegedly negligent manner.
Upon learning about the tragic accident on December 31, 2013, Uber and Rasier
immediately disabled Mr. Muzaffar’s driver accounts. Uber and Rasier have fully cooperated with
the CPUC’s investigation of the accident.
GENERAL DENIAL
Pursuant to California Code of Civil Procedure § 431.30(d), the Companies generally deny
each and every material allegation of the Complaint and further deny that Plaintiffs are entitled to
any of the relief sought.
AFFIRMATIVE DEFENSES
The Companies allege and assert the following separate and additional defenses in
response to the allegations, undertaking the burden of proof only as to those defenses deemed
affirmative defenses by law, regardless of how such defenses are denominated herein. In addition
to the affirmative defenses described below, the Companies specifically reserve all rights to allege
additional affirmative defenses that become known through the course of discovery.
FIRST DEFENSE
The Complaint fails to allege facts sufficient to state a claim upon which relief can be
granted.
SECOND DEFENSE
The Complaint is barred in whole or part because the Companies are not liable for the acts
of others over whom it is not responsible.
THIRD DEFENSE
The Complaint is barred in whole or part because the Companies are not liable for the
misuse, if any, of the Uber App or the Device.
-7- Case No. CGC-14-536979
ANSWER AND AFFIRMATIVE DEFENSES
OF UBER. RASIER AND RASIER-CA
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FOURTH DEFENSE
The Complaint is barred because Plaintiffs’ damages, if any, were not caused by the
Companies.
FIFTH DEFENSE
The Companies specifically deny all allegations of duty, breach, negligence, defect,
causation, and all forms of damages and demands strict proof thereof.
SIXTH DEFENSE
Plaintiffs’ products liability claim is barred because neither the Uber App nor the Device is
defectively designed.
SEVENTH DEFENSE
Plaintiffs’ products liability claim is barred because neither the Uber App nor the Device is
defectively manufactured.
EIGHTH DEFENSE
Plaintiffs’ products liability claim is barred because the Uber App and the Device
conformed to the state-of-the art for such items at that time and were fit for their normal use. To
the extent the Uber App or Device caused Plaintiffs’ injuries, it was due to abnormal or improper
use of the items.
NINTH DEFENSE
Plaintiffs’ products liability claim is barred because the Companies primarily provide
services, not products.
TENTH DEFENSE
Plaintiffs’ products liability claim is barred because the Uber App and the Device are not
“products” subject to strict liability.
ELEVENTH DEFENSE
Plaintiffs’ claims based on Vehicle Code 23123 are barred by People v. Spriggs (2014) 224
Cal. App. 4th 150.
-8- Case No. CGC-14-536979
ANSWER AND AFFIRMATIVE DEFENSES
OF UBER. RASIER AND RASIER-CA
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TWELFTH DEFENSE
Plaintiffs’ claims are barred, in whole or in part, because the Companies are
comprehensively regulated by the CPUC and, accordingly, Plaintiffs’ claims are preempted.
THIRTEENTH DEFENSE
Plaintiffs’ claims may be barred because Plaintiffs’ injuries may have been actually or
proximately caused, in whole or in part, by the intervening or superseding conduct of Plaintiffs,
independent third parties, or events that were extraordinary under the circumstances, or not
foreseeable in the normal course of events.
FOURTEENTH DEFENSE
Plaintiffs’ claims may be barred, in whole or in part, because Plaintiffs’ injuries were
caused, in whole or in part, by negligence, fault, or wrongful conduct of Plaintiffs or by third
parties, and Plaintiffs’ claims may be barred or limited by the doctrines of comparative fault or
contributory negligence.
FIFTEENTH DEFENSE
The damages requested in the Complaint may be barred in part as speculative, uncertain or
otherwise not cognizable.
SIXTEENTH DEFENSE
The liability of the Companies, if any, for Plaintiffs’ non-economic loss must be
apportioned in accordance with the provisions of California Civil Code § 1431.2 (Proposition 51).
SEVENTEENTH DEFENSE
The Complaint, and each cause of action purportedly alleged therein, may be barred, in
whole or in part, by Plaintiffs’ failure to mitigate damages.
EIGHTEENTH DEFENSE
Plaintiffs’ damages may be barred, limited or offset in the amount of any reimbursement
received by Plaintiffs as a result of any insurance or other health benefits plan, or any amounts
paid by any insurance or other health benefits plan.
-9- Case No. CGC-14-536979
ANSWER AND AFFIRMATIVE DEFENSES
OF UBER. RASIER AND RASIER-CA
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NINETEENTH DEFENSE
Plaintiff fails to state facts sufficient to support an award of punitive damages. Moreover,
any award of punitive damages in this case would violate due process, equal protection and the
excessive fines provision of the California and United States Constitutions.
TWENTIETH DEFENSE
Without admitting that the Complaint states a claim, any remedies are limited to the extent
that Plaintiff seeks an overlapping or duplicative recovery pursuant to the claims against
Defendants for any alleged wrongdoing.
TWENTY FIRST DEFENSE
The Companies are entitled to, and claim the benefit of, all defenses and presumptions set
forth in or arising from any rule of law or statue of the State of California or any other applicable
law.
TWENTY SECOND DEFENSE
The Companies may discover additional affirmative defenses and reserve the right to assert
additional affirmative defenses if discovery such defenses appropriate.
PRAYER FOR RELIEF
The Companies pray that the Court:. Dismiss the Complaint against the Companies in its entirety with prejudice and
order that Plaintiffs take nothing from the Companies;
. Enter judgment in favor of Defendants; and. Order such other and further relief that the Court may deem proper.
-10- Case No. CGC-14-536979

ANSWER AND AFFIRMATIVE DEFENSES
OF UBER. RASIER AND RASIER-CA
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DATED: May 1, 2014


°o
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
By Diane Wh. Deol alle
Diane M. Doolittle Af
Morgan W. Tovey
Attorneys for Defendants Uber Technologies,
Inc., Rasier LLC, and Rasier-CA LLC
-U1- Case No. CGC-14-536979
ANSWER AND AFFIRMATIVE DEFENSES
OF UBER. RASIER AND RASIER-CA
Page 13 1) ORIGINAL
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N vm meme pe
BNRRR RBBRRB FERRE BAEBHEKLRS
©
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
Diane M. Doolittle (Bar No. 142046)
Morgan W. Tovey (Bar No. 136242)
Nicole Y. Altman (Bar No. 279397) California Street, 22nd Floor
San Francisco, California 94111
Telephone: (415) 875-6600
Facsimile: (415) 875-6700
Attorneys for Defendants Uber Technologies,
Inc., Rasier LLC and Rasier-CA LLC
BRADLEY CURLEY ASIANO BARRABEE
ABEL & KOWASKI
Ann Asiano (Bar No. 94891)
Michael A. King (Bar No. 77014) Larkspur Landing Circle, Suite 200
Larkspur, CA 94939
Telephone: (415) 464-8888
Facsimile: (415) 464-8887
Attorneys for Defendants Uber Technologies,
Inc. and Rasier LLC
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
ANG JIANG LIU, AS AN INDIVIDUAL
AND AS GUARDIAN AD LITEM FOR
ANTHONY LIU, AND SUCCESSOR IN
INTEREST ON BEHALF OF THE ESTATE
OF SOFIA LIU, HUAN HUA KUANG,
ANTHONY LIU,
Plaintiffs,
vs.
UBER TECHNOLOGIES, INC., RASIER
LLC, RASIER-CA LLC, SYED MUZAFFAR,
and DOES 1-30,
Defendants.
CASE NO. CGC-14-536979
PROOF OF SERVICE
Complaint Filed:
Trial Date:
January 27, 2014
None Set


.00003/5903481.1


PROOF OF SERVICE
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PROOF OF SERVICE
I, Mercedes Hereford, declare under penalty of perjury under the laws of the State of
California that the following is true and correct:
I am employed in the City of San Francisco, County of San Francisco, State of California,
in the office of a member of the bar of this court, at whose direction the service was made. I ama
resident of the United States, over the age of eighteen (18) years, and not a party to or interested
in the within-entitled action. My business address is Quinn Emanuel Urquhart & Sullivan, LLP,
at 50 California Street, 22nd Floor, San Francisco, CA 94111.
I caused to be served the following document(s):
ANSWER AND AFFIRMATIVE DEFENSES OF DEFENDANTS UBER
TECHNOLOGIES, INC., RASIER LLC, AND RASIER-CA LLC TO
PLAINTIFFS’ COMPLAINT
APPLICATION FOR APPROVAL OF COMPLEX LITIGATION DESIGNATION
BY DEFENDANTS UBER TECHNOLOGIES, INC., RASIER LLC, AND RASIER-
CA LLC
[PROPOSED] ORDER GRANTING APPLICATION FOR APPROVAL OF
COMPLEX LITIGATION DESIGNATION
I caused the above documents to be served on each person on the attached list by the
following means:
[X]_ On May 01, 2014, I deposited such document(s) in a box or other facility regularly
maintained by FedEx, or delivered such document(s) to a courier or driver authorized by
FedEx to receive documents, in sealed envelope(s) or package(s) designated by FedEx
with delivery fees paid or provided for, addressed to the person(s) being served.
(Indicated on the attached address list by an [FD] next to the address.)
I am readily familiar with my firm’s practice for collection and processing of
correspondence for delivery in the manner indicated above, to wit, that correspondence will be
deposited for collection in the above-described manner this same day in the ordinary course of
business.
Executed on May 01, 2014, at San Francisco, California.
OV RuW/®>
Mercedes Hereford
,00003/5903481.1 -2-


PROOF OF SERVICE
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SERVICE LIST

Key: [E] Delivery by E-Mail [FD] Delivery by Federal Express [M] Delivery by Mail


oOo me NY DH F&F WD WN
Nu NY N WD Pm meme meme mee ek

Emile Davis
Dolan Law Firm
Market Street
San Francisco, CA 94102
Tel. 415.421.2800
chris@cbdlaw.com
emile.davis@cbdlaw.com
Attorneys for Plaintiffs Ang Jiang Liu,
as an individual and as guardian ad
litem for Anthony Liu, and successor
in interest on behalf of the estate of
Sofia Liu, Huan Hua Kuang, and
Anthony Liu
[H] Delivery by Hand [E/FD] Delivery by E-Mail and [E/M] Delivery by E-Mail
Service Federal Express and Mail
[FD] Chris Dolan [FD] Jennifer Kung-Gelini
Carbone, Smoke, Smith, Bent &
Leonard
14" Street. Suite 600
Oakland, CA 94612
Tel. 510.267.7200
jennifer.gelini@csaa.com
Attorneys for Defendant Syed Muzaffar

[FD]

Graham Archer
Washington Street
Oakland, CA 94607
Tel. 415- 632-2310
graham@garcher.com
Attorneys for Defendant Syed
Muzaffar

[FD]
Ann Asiano
Michael King
Bradley Curley Asiano Barrabee Abel
& Kowaski
Larkspur Landing Circle, Suite
Larkspur, CA 94939
Tel: 949-464-8888
AAsiano@professionals-law.com
mking@professionals-law.com
Attorneys for Uber Technologies Inc.
and Rasier LLC

.00003/5903481.1


PROOF OF SERVICE
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