WMW, Inc. v. American Honda Motor Co., 291 Ga. 683

WMW, a corporate Honda dealer in Roswell, operates a new-car dealership since 1976 and a separate Alpharetta service-only location since 2000 under a Honda franchise.
In 2010 Honda planned to authorize Sobh to open a new Honda dealership in Cumming, within eight miles of Alpharetta but beyond WMW's Roswell sales area.
WMW sued Honda and Sobh under OCGA § 10-1-664, seeking to enjoin the new dealership within the Act’s anti-encroachment provision.
The trial court dismissed for lack of standing; the Court of Appeals affirmed, rejecting Alpharetta as a relevant market area for WMW.
This Court granted certiorari to resolve how to define a corporate dealership’s standing under the Act, and to address mootness issues raised by Honda after the briefing.
Honda subsequently argued the case was moot due to a voluntary cessation of the challenged conduct, which this Court denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
What is the proper eight-mile relevant market area for a corporate dealership?	WMW contends Alpharetta location should count toward its market area because the corporation exists at multiple locations.	Honda argues the relevant market area is tied to the dealership’s selling location, not every corporate location or service facility.	The relevant market area is the eight miles around where the dealer sells new cars (Roswell), not all corporate locations.
Does WMW qualify as a dealership beyond selling new cars at multiple locations?	WMW is a dealership because it sells and services Honda vehicles at its facilities.	The Act distinguishes dealers based on selling versus exclusively repairing; service facilities do not expand standing for a car-selling dealer.	WMW is a car-selling dealer, not exclusively repairing; standing rests on its selling location(s).
Should the case be dismissed as moot due to Honda's voluntary cessation?	Mootness should not defeat appellate review given the public importance of the issue.	Voluntary cessation can render an appeal moot unless recurrence is likely.	Mootness denied; the case proceeds to the merits to resolve standing.

U.S. Bank Nat. Assn. v. Gordon, 289 Ga. 12 (Ga. 2011) (integrated statutory construction; statutes construed as a whole)
Bunn v. State, 291 Ga. 183 (Ga. 2012) (certiorari review; right-for-any-reason affirmance doctrine)
United States v. Concentrated Phosphate Export Assn., 393 U.S. 199 (U.S. 1968) (voluntary cessation and mootness principles)
United States v. W.T. Grant Co., 345 U.S. 629 (U.S. 1953) (public interest and mootness considerations in standing)
City of Mesquite v. Aladdin's Castle, Inc., 455 U.S. 283 (U.S. 1982) (mootness and ongoing legality of practices)