Mario Del Valle, et al. v. Trivago GMBH, et al., No. 20-12407 (11th Cir. 2022)Annotate this Case
The Trump administration announced that it would not suspend the Cuban Liberty and Democratic Solidarity Act (known as the “Helms-Burton Act”) for the first time since its enactment in 1996. Shortly after this announcement, the cause of action created by Title III of the Helms-Burton Act became fully effective in U.S. courts. Plaintiffs in this case Title III against several entities that own and operate travel websites, including Booking.com BV and Booking Holdings, Inc. (the Booking Entities), and Expedia Group, Inc., Hotels.com L.P., Hotels.com GP, and Orbitz, LLC (the Expedia Entities). Plaintiffs alleged that they are U.S. nationals and living heirs to separate beach-front properties nationalized by the Cuban government after the 1959 revolution According to the complaint, the Booking Entities and Expedia Entities trafficked in those properties on their travel booking websites.
The district court dismissed Plaintiffs’ Title III claims without leave to amend, ruling that it lacked personal jurisdiction over the defendants under the relevant provisions of Florida’s longarm statute. The Eleventh Circuit reversed and remanded. The court explained that based on the uncontroverted allegations in the complaint, the district court has specific personal jurisdiction over the Booking Entities and Expedia Entities pursuant to Fla. Stat. Section 48.193(1)(a)(2), and the exercise of such jurisdiction does not violate the Due Process Clause of the Fourteenth Amendment. Plaintiffs also have plausibly alleged Article III standing.