1. Whether, “[f]or the ‘clearly materialize’ burden of proof, the Google Decision is inconsistent with the Fifth Circuit and failed to properly impose the burden on Google, leaving open the ability to transfer cases based on hypothetical convenience that is unlikely to materialize.”
2. Whether, “[f]or the local interest factor, the Panel Decision erred by ignoring the Fifth Circuit’s rule that this public interest factor cannot be based on the private activities of the parties.”
