Judge Lynn’s Transfer Decision in iLife Technologies

Judge Lynn issued a transfer decision (available here) in three iLife Technologies cases. Two of the defendants moved to transfer to the Northern District of California, while the third defendant sought transfer to the Western District of Pennsylvania. Of particular interest is Judge Lynn’s discussion of judicial economy:

iLife argues that the gains in judicial economy to be delivered by this Court adjudicating each action concerning the Patents-in-Suit suggests that this factor weighs against transfer, while BodyMedia maintains that, if the Court finds that transfer to its preferred venue is unwarranted, it would consent to transfer of its case to the Northern District of California to vindicate such efficiency interests. First, if BodyMedia had not clearly shown the more convenient forum for suit against it would be the Western District of Pennsylvania, where BodyMedia is headquartered and where its executives and the developers of its accused products are purportedly located, then the Court would be unlikely to find that the Northern District of California, for which BodyMedia has shown, at best, a minimal local interest or quantity of evidence or witnesses, and which is located on the opposite coast of its headquarters, would be clearly more convenient than this forum. Second, the America Invents Act mandates that Courts adjudicate patent suits against separate defendants separately, 35 U.S.C. § 299 (2011), so the parties’ arguments concerning efficiency are unavailing. See GeoTag, Inc. v. Starbucks Corp., 2:10-CV-572, 2013 WL 890484, at *6 (E.D. Tex. Jan. 14, 2013) (holding that under the America Invents Act, related patent cases were not relevant to the transfer analysis, even where such cases were in their infancy). Accordingly, the Court finds that this factor is neutral.

Having found that defendants met their transfer burden, the cases were transferred to the Northern District of California and the Western District of Pennsylvania.

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