Thursday, July 08, 2021

CAFC grants mandamus in Uber case from WD Texas

the conclusion:

In this case, we see no basis for a disposition different from the ones reached in Samsung. The district court here [WD Texas] relied on the same improper grounds as in Samsung to diminish the clear convenience of the Northern District of California. The reasons for not finding judicial economy considerations to override the clear convenience of the transferee venue also apply with even more force here. Though the district court in this case relied on the co-pending case against Lyft, Inc. as well as Bumble, both of those litigations involve entirely different underlying functionality and the Samsung Electronics Co., Ltd. et al. and LG Electronics Inc. et al. litigations have now been directed to be transferred to Northern California. In addition, the district court clearly erred in negating the transferee venue’s strong local interest by relying merely on the fact that plaintiffs alleged infringement in the Western District of Texas.

The petition for a writ of mandamus is granted. The district court’s May 26, 2021 order denying transfer is vacated, and the district court is directed to grant Uber’s motion to the extent that the case is transferred to the United States District Court for the Northern District of California under 28 U.S.C. § 1404(a).


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