In re Samsung Electronics Co.


Issue(s) Presented

1. “Whether the district court erred by holding that Plaintiffs’ pre-filing assignment of geographically limited patent rights to a newly minted related entity precluded transfer regardless of the convenience of parties and witnesses.”

2. “Whether the district court clearly abused its discretion by denying Petitioners’ motion to transfer where the most important factors—sources of proof, the availability of compulsory process, and the convenience of witnesses—clearly favor the NDCA, and the only record-supported reasons weighing against transfer are speculation about court congestion and the fact that Plaintiffs filed similar suits against other defendants in the WDTX.”


1. “On the face of the complaint, the Northern District of California could not be a proper venue for Ikorongo Texas’s claims because no act of infringement of Ikorongo Texas’s rights took place there. But in ascertaining proper venue, we are not bound by a plaintiff’s efforts to manipulate venue.”

2. “In general, we give substantial deference to how a district court balances conveniences and fairness factors that favor transfer against practical and public concerns if the cases were transferred. However, we have explained that ‘a clear abuse of discretion in balancing convenience against judicial economy under § 1404 is not outside the scope of correctible error on mandamus review.’ . . . Here, we find that the court’s conclusions were such an abuse.”


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