MasterCard International v. Visa International Service Association
United States Court of Appeals for the Second Circuit
471 F.3d 377 (2d Cir. 2006)
MasterCard International (MasterCard) (plaintiff), a Delaware corporation, sued the Federation Internationale de Football Association (FIFA) (defendant) for breach of contract in the United States District Court for the Southern District of New York under diversity jurisdiction. MasterCard alleged that FIFA breached its right of first refusal of World Cup sponsorship rights when it granted exclusive rights to Visa International Service Association (Visa), also a Delaware corporation. MasterCard requested an injunction and specific performance. FIFA sought to dismiss for lack of personal jurisdiction and compel arbitration, but both motions were denied. MasterCard requested a preliminary injunction. Visa claimed it was a necessary and indispensable party and that joinder would defeat diversity jurisdiction. The district court held that Visa was not a necessary or an indispensable party under and denied Visa’s motion. The district court concluded that Visa’s presence in the litigation was not necessary to adjudicate the contractual rights of MasterCard and FIFA and that Visa could always vindicate its rights by suing FIFA later. Visa appealed to the United States Court of Appeals for the Second Circuit.
Rule of Law
Holding and Reasoning (Pooler, J.)
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