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December 15, 2010
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sued VistaPrint and OfficeMax for patent infringement in the Eastern District of
Texas. Defendants wanted a transfer to Massachusetts. Denied. Petition to the
CAFC for a writ of mandamus, to overturn, failed. "In sum, there are cases where
to hold a trial court to a meaningful application of the § 1404(a) factors
presents only one correct outcome. In those cases, mandamus may be appropriate.
A case such as this, however, shows that a meaningful application of the factors
often creates a reasonable range of choice. Under such circumstances, it is
entirely within the district court's discretion to conclude that in a given case
the § 1404(a) factors of public interest or judicial economy can be of
"paramount consideration," Volkswagen II, 566 F.3d at 1351, and as long
as there is plausible support of record for that conclusion we will not second
guess such a determination, even if the convenience factors call for a different
result." This, with an approving nod to EDT Judge Davis from his
upstairs brethren: "the trial court performed a detailed analysis explaining
that it is very familiar with the only asserted patent and the related
technology, and where there is a co-pending litigation before the trial court
involving the same patent-in-suit..." (CAFC
2010-m954o) precedential
Posted by Patent Hawk at December 15, 2010 11:37 AM | Case Law