ROTHSCHILD STORAGE RETRIEVAL INNOVATIONS, LLC v. SONY MOBILE COMMUNICATIONS (USA) INC.
Filing
45
OPINION AND ORDER granting 30 Motion to Transfer. Signed by Judge Beth Bloom on 1/14/2015. (yha)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 14-CIV-22652-BLOOM/Valle
ROTHSCHILD STORAGE RETRIEVAL
INNOVATIONS, LLC,
a Florida limited liability company,
Plaintiff/Counter-Defendant,
v.
SONY MOBILE COMMUNICATIONS (USA) INC.,
a Delaware corporation,
Defendant/Counter-Plaintiff.
_______________________________________/
ORDER ON DEFENDANT’S MOTION TO TRANSFER
This cause is before the Court on Defendant Sony Mobile Communications (USA) Inc.’s
Motion to Transfer pursuant to 28 U.S.C. § 1404(a) (“Motion”), ECF No. [30], filed on
November 10, 2014, which seeks transfer of this matter to the United States District Court for the
Northern District of California. On December 5, 2014, Plaintiff Rothschild Storage Retrieval
Innovations, LLC (“Plaintiff”) filed its Response, ECF No. [42], and Defendant Sony Mobile
Communications (USA) Inc. (“Sony Mobile”) filed its Reply, ECF No. [44], on December 15,
2014. The Court has reviewed the Motion, all supporting and opposing filings, and the record in
this case, and is otherwise fully advised as to the premises. For the reasons that follow, the
Motion is granted.
I. BACKGROUND
On July 3, 2014, Plaintiff acquired U.S. Patent No. 8,437,797 (“the ’797 Patent”), titled
“Wireless Image Distribution System and Method.” See Patent Assignment, ECF No. [30-14].
On July 16, 2014, a mere two weeks after the patent’s acquisition, Plaintiff commenced this
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action alleging infringement of the ‘797 Patent by virtue of Sony Mobile’s continued “making,
using, selling, offering to sell, and/or importing into the United States products that embody or
practice the apparatus and/or method covered by one or more claims of the ‘797 Patent . . . .”
See Compl., ECF No. [1] at ¶¶ 11, 15. The allegedly infringing functionalities which are
contained within Android devices such as Sony’s Xperia Z1S and Xperia TL smartphones (the
“Accused Products”), include “sharing a group of photos based on their geographic location
within their ‘Locations’ album to another mobile device.” Id. at ¶ 15. Plaintiff is a Florida
limited liability company organized and existing under the laws of the State of Florida with its
principal place of business located in Bay Harbor Islands, Florida. See Compl., ECF No. [1] at
¶ 1. Sony Mobile is a Delaware corporation licensed to do business in the State of Florida with
its principal place of business in Atlanta, Georgia. Id. at ¶ 2. According to the Complaint, venue
is proper in the Southern District of Florida because Sony Mobile “has committed acts of
infringement in this District giving rise to this action and does business in this District, including
making sales and/or providing service and support for their respective customers in this District.”
Id. at ¶ 8.
Simultaneously with the filing of this action, Plaintiff filed six additional lawsuits in this
District against various technology companies operating in the mobile phone industry claiming
infringement of the ‘797 Patent through similar and/or related functionalities.1 Plaintiff has
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The seven related cases, including this action (listed first), are:
1. Rothschild Storage Retrieval Innovations, LLC v. Sony Mobile Communications
(USA) Inc., 1:14-cv-22652-BB (“Sony Case”);
2. Rothschild Storage Retrieval Innovations, LLC v. Samsung Electronics Co., Ltd., et
al., Case No. 1:14-cv-22653-CMA (“Samsung Case”);
3. Rothschild Storage Retrieval Innovations, LLC v. LG Electronics, Inc., et al., Case
No. 1:14-cv-22654-DPG (“LG Case”);
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sought consolidation of these actions for claim construction purposes, alleging that all involve
common questions of law and fact. See Mot. to Consolidate, ECF No. [28]. In the instant
Motion, Sony Mobile seeks to transfer this matter to the Northern District of California, asserting
that this alternative venue is “overwhelmingly [] more convenient,” and stating in support that
(1) Sony Mobile’s relevant witnesses are located in California, (2) numerous third-party
witnesses are also in California, and (3) Plaintiff’s ties to the forum are weak at best. See Mot.,
ECF No. [30]. In fact, similar motions have been filed in five of the six other actions in this
District seeking to transfer their respective actions to the Northern District of California.2
II. LEGAL STANDARD
The transfer statute, 28 U.S.C. § 1404(a), which embodies a codification and revision of
the forum non conveniens doctrine, see Piper Aircraft Co. v. Reyno, 454 U.S. 235, 253 (1981),
provides that “[f]or the convenience of parties and witnesses, in the interest of justice, a district
court may transfer any civil action to any other district or division where it might have been
brought.” “Section 1404(a) reflects an increased desire to have federal civil suits tried in the
federal system at the place called for in the particular case by considerations of convenience and
justice.” Van Dusen v. Barrack, 376 U.S. 612, 616 (1964). The statute grants broad discretion to
the district court. See Osgood v. Disc. Auto Parts, LLC, 981 F. Supp. 2d 1259, 1263 (S.D. Fla.
4. Rothschild Storage Retrieval Innovations, LLC v. HTC Corporation, et al., Case No.
1:14-cv-22655-KMW (“HTC Case”);
5. Rothschild Storage Retrieval Innovations, LLC v. Nokia Corporation, Case No. 1:14cv-22657-DPG (“Nokia Case”);
6. Rothschild Storage Retrieval Innovations, LLC v. Apple Inc., Case No. 1:14-cv22658-MGC (“Apple Case”); and
7. Rothschild Storage Retrieval Innovations, LLC v. Motorola Mobility LLC, Case No.
1:14-cv-22659-RNS (“Motorola Case”).
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Motions to transfer have been filed in the Samsung Case, ECF No. [43], LG Case, ECF No.
[39], HTC Case, ECF No. [20], Apple Case, ECF No. [16], and Motorola Case. ECF No. [35].
Thus, only the Nokia Case defendants have not sought transfer.
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2013) (stating that the “standard for transfer under 28 U.S.C. § 1404(a) leaves much to the broad
discretion of the trial court”) (citation omitted); see also Piper Aircraft, 454 U.S. at 253 (noting
that “[d]istrict courts were given more discretion to transfer under § 1404(a) than they had to
dismiss on grounds of forum non conveniens”) (citation omitted); Motorola Mobility, Inc. v.
Microsoft Corp., 804 F. Supp. 2d 1271, 1275 (S.D. Fla. 2011) (“The Court has broad discretion
in determining whether these factors suggest that transfer is appropriate.”). The party seeking
transfer bears the burden of demonstrating entitlement. In re Ricoh Corp., 870 F.2d 570, 573
(11th Cir. 1989) (“[I]n the usual motion for transfer under section 1404(a), the burden is on the
movant to establish that the suggested forum is more convenient.”).
In determining the appropriateness of transfer, courts employ a two-step process. See
Osgood, 981 F. Supp. 2d at 1263 (citing Abbate v. Wells Fargo Bank, Nat. Ass’n, 09–62047–Civ,
2010 WL 3446878, at *4 (S.D. Fla. Aug. 31, 2010)); Precision Fitness Equip., Inc. v. Nautilus,
Inc., No. 07-61298-CIV-COOKE, 2008 WL 2262052, at *1 (S.D. Fla. May 30, 2008) (citing
Thermal Techs., Inc. v. Dade Serv. Corp., 282 F. Supp. 2d 1373, 1376 (S.D. Fla. 2003);
Jewelmasters, Inc. v. May Dep’t Stores, 840 F. Supp. 893, 894-95 (S.D. Fla. 1993) (citing Cont’l
Grain Co. v. The Barge FBL-585, 364 U.S. 19 (1960))). First, the district court is tasked with
determining whether the action could have been pursued in the venue to which transfer is sought.
See Osgood, 981 F. Supp. 2d at 1263 (citing Abbate, 2010 WL 3446878, at *4). Second, “courts
assess whether convenience and the interest of justice require transfer to the requested forum.”
Id. (citation omitted). In analyzing this second prong, the Court applies several factors:
(1) the convenience of the witnesses; (2) the location of relevant
documents and the relative ease of access to sources of proof; (3)
the convenience of the parties; (4) the locus of operative facts; (5)
the availability of process to compel the attendance of unwilling
witnesses; (6) the relative means of the parties; (7) a forum’s
familiarity with the governing law; (8) the weight accorded a
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plaintiff’s choice of forum; and (9) trial efficiency and the interests
of justice, based on the totality of the circumstances.
Motorola Mobility, 804 F. Supp. 2d at 1275-76 (quoting Meterlogic, Inc. v. Copier Solutions,
Inc., 185 F. Supp. 2d 1292, 1299 (S.D. Fla. 2002) and citing Manuel v. Convergys Corp., 430
F.3d 1132, 1135 n.1 (11th Cir. 2005)). Traditionally, a plaintiff’s choice of forum is accorded
considerable deference, In re Ricoh, 870 F. 2d at 573 (citing Gulf Oil Corp. v. Gilbert, 330 U.S.
501, 508 (1947)), and, “[u]ltimately, transfer can only be granted where the balance of
convenience of the parties strongly favors the defendant.” Steifel Labs., Inc. v. Galderma Labs.,
Inc., 588 F. Supp. 2d 1336, 1339 (S.D. Fla. 2008) (citing Robinson v. Giarmarco & Bill, P.C., 74
F.3d 253, 260 (11th Cir. 1996)). With regard to the first prong, an action “might have been
brought” in any court that has subject-matter jurisdiction, where venue is proper, and where the
defendant is amenable to process issuing out of the transferee court.
Windmere Corp. v.
Remington Prods., Inc., 617 F. Supp. 8, 10 (S.D. Fla. 1985) (citing 15 C. Wright, A. Miller and
E. Cooper, Federal Practice and Procedure § 3845 (1976)).
III. DISCUSSION
The parties do not dispute that this matter “might have been brought” in the Northern
District of California and the Court concurs. See Mot., ECF No. [30] at 9; Resp., ECF No. [42]
at 6. Accordingly, the Court’s examination focuses on the second inquiry: whether convenience
and the interest of justice support transfer. As noted, in determining this, the Court weighs
several factors. See Motorola Mobility, 804 F. Supp. 2d at 1275-76 (citation omitted).
A.
Convenience of the Parties, Witnesses, and Availability of Process
Sony Mobile first contends that the convenience of the parties and witnesses weighs
heavily in favor of transfer. Although Sony Mobile is headquartered in Atlanta, Georgia, a
venue significantly closer to this District than the Northern District of California, see Lazzardi
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Decl., ECF No. [30-1] at ¶ 4, its additional facilities in San Diego and San Mateo, California, are
primarily responsible for its mobile operations and related software development.
See id;
Hilding Decl., ECF No. [30-2] at ¶ 4. Indeed, the Atlanta headquarters serves only as an
administrative facility, merely providing marketing and other administrative functions necessary
to the operation of the company. See Lazardi Decl., ECF No. [30-1] at ¶ 4. Details surrounding
the integration of the camera and photo album functionality in the Accused Products is created
and developed through Sony Mobile’s Applications and Service Development group, which is
comprised of a fourteen-member team located solely in San Mateo, California. See Hilding
Decl., ECF No. [30-2] at ¶¶ 5-7. Other key witnesses are also located in the Northern District of
California.
Sony Mobile’s Head of Platform Software, Stephen Lee, an individual with
knowledge of how the Accused Products operate within networks, including the nature of photo
sharing across devices, is located in San Mateo. See Hilding Decl., ECF No. [30-2] at ¶ 9.
On the other hand, besides the corporate Plaintiff itself and the inventor of the ‘797
Patent, very few witnesses are located in this District, and those referenced by Plaintiff do not
appear to be directly related to the ultimate issue of infringement. Plaintiff stresses that it will be
incredibly inconvenient for its two corporate executives to testify in California due to personal
issues that need not be discussed here. While the Court is sympathetic to the circumstances
creating this inconvenience, the Court is not persuaded that the convenience of these two
witnesses weighs in favor of denying transfer. Plaintiff points to two corporate executives,
including the inventor, who will be offered to testify to the value of the ‘797 Patent and damages,
as well as testifying to Plaintiff’s “business dealings and other licensing issues.” See ECF No.
[42] at 20. These witnesses, while arguably relevant to the certain issues in the case, do not
appear to be relevant to the accusations contained in the Complaint. See Microspherix LLC v.
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Biocompatibles, Inc., No. 9:11-CV-80813-KMM, 2012 WL 243764, at *3 (S.D. Fla. Jan. 25,
2012) (noting that the Court does not simply tally the number of witnesses on each side, but
rather, “the witnesses’ actual knowledge relative to the instant dispute, and the location and
convenience of the witnesses are [the] important considerations when evaluating whether
transfer is justified”) (citations omitted). Thus, their presence in the current forum is accorded
little weight. Moreover, the fact that additional Sony Mobile witnesses may be located in
Atlanta or, alternatively, Raleigh-Durham, North Carolina, provides little support for the denial
of transfer.
The individuals responsible for the development and creation of the Accused
Products, and, therefore, those with the most knowledge of the allegedly infringing
functionalities, reside in Northern California.
Additionally, potential third-party witnesses can be found in the transferee district, yet
another fact supporting transfer. The Accused Products are based on Google, Inc.’s Android
operating system, and, therefore, the allegedly infringing functionalities rely on the Android
software for many features. See Hilding Decl., ECF No. [30-2] at ¶ 8. Google, Inc. and its
related witnesses are located in Mountain View, California, in the Northern District of
California. See id. This Court has noted that “[t]he convenience of non-party witnesses is an
important, if not the most important, factor in determining whether a motion for transfer should
be granted.” Cellularvision Tech. & Telecommunications, L.P. v. Cellco P’ship, No. 06-60666CIV, 2006 WL 2871858, at *3 (S.D. Fla. Sept. 12, 2006) (citing Meterlogic, Inc. v. Copier
Solutions, Inc., 185 F. Supp. 2d 1292, 1301 (S.D. Fla. 2002)). Moreover, potentially helpful
academics and other individuals with knowledge pertaining to the prior art reside in Northern
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California.3 The issuance of subpoenas and power to enforce these witnesses’ attendance at trial
is vested in the Northern District of California. This District lacks that authority.
In a case very analogous to the one at bar, the Honorable Judge Donald M. Middlebrooks
recently found that a related plaintiff’s limited number of in-forum witnesses would not preclude
transfer where a substantial portion of defendant’s witnesses were located in the Northern
District of California.
See Rothschild Digital Media Innovations, LLC v. Sony Computer
Entertainment America LLC, No. 14-cv-22134-MIDDLEBROOKS, ECF No. [22] (S.D. Fla.
Aug. 28, 2014).4 Similarly, here, this factor weighs heavily in favor of transfer.
B.
Access to Sources of Proof, Locus of Operative Facts, and Plaintiff’s Choice
Undoubtedly, and contrary to Plaintiff’s assertions, the bulk of evidence regarding the
Accused Products exists in Northern California, where the products were created. However,
given the ease with which documents may be transmitted in the 21st Century, courts regularly
3
Plaintiff cites to Wi-Lan USA, Inc. v. Alcatel-Lucent USA Inc., No. 12-23568-CIV, 2013 WL
358385, at *4 (S.D. Fla. Jan. 29, 2013) for the blanket proposition that this Court has held that
“[t]he most important third-party witnesses are the inventors and the attorneys.” Ostensibly,
Plaintiff’s citation in this regard is intended to assign great significance to the presence of the
original prosecuting attorneys in Southern Florida. Yet, as presented, Plaintiff’s quotation is
disingenuous. The Court in Wi-Lan did not hold that inventors and attorneys are always the most
important third party witnesses, but rather, under the factual circumstances presented therein, and
because the defendant had failed to present any witnesses who would be assisted by transfer, the
convenience factor did not favor transfer. See id. Absent additional authority supporting this
proposition, the Court respectfully declines to accord the residence of the original prosecuting
attorneys the weight Plaintiff desires. Furthermore, Plaintiff has failed to identify how the
prosecuting attorneys will be of extraordinary significance in this matter.
4
In an attempt to discount Judge Middlebrooks’ findings in Rothschild Digital Media
Innovations, Plaintiff contends that the “roles are reversed,” as Plaintiff has identified several
key witnesses and Sony Mobile has “sparingly identified any witnesses with knowledge of
infringement and damages located in the Northern District of California.” See Resp., ECF No.
[42] at 7-8. The Court disagrees. As noted, Sony Mobile has identified numerous witnesses in
the Northern District of California that directly relate to the issue of infringement, whereas
Plaintiff has only identified a few individuals, namely, the inventor and original prosecuting
attorneys, whose relation to the question of infringement remains unclear.
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determine the location of relevant documents to be of little weight. See, e.g., Microspherix LLC,
2012 WL 243764, at *3 (“In a world with fax machines, copy machines, email, overnight
shipping, and mobile phones that can scan and send documents, the physical location of
documents is irrelevant.”). Therefore, this factor remains neutral.
Typically, “[t]he plaintiff’s choice of forum should not be disturbed unless it is clearly
outweighed by other considerations.” Robinson, 74 F.3d at 260 (citation omitted).
However,
“‘where the operative facts underlying the cause of action did not occur within the forum chosen
by the Plaintiff, the choice of forum is entitled to less consideration.’” Wi-LAN USA, Inc. v.
Apple Inc., No. 12-CV-24318-KMM, 2013 WL 1343535, at *4 (S.D. Fla. Apr. 2, 2013) (quoting
Motorola Mobility, 804 F. Supp. 2d at 1276). “In patent infringement cases, the bulk of the
relevant evidence usually comes from the accused infringer. Consequently, the place where the
defendant’s documents are kept weighs in favor of transfer to that location.” In re Genentech,
Inc., 566 F.3d 1338, 1345 (Fed. Cir. 2009) (quoting Neil Bros. v. World Wide Lines, Inc., 425 F.
Supp. 2d 325, 330 (E.D.N.Y. 2006)). Further, various district courts have determined that the
“center of gravity” for a patent infringement case is “where the accused product was designed
and developed.” See, e.g., Motorola Mobility, Inc., 804 F. Supp. 2d at 1276 (citing Trace-Wilco,
Inc. v. Symantec Corp., No. 08–80877, 2009 WL 455432, at *2-3 (S.D. Fla. Feb. 23, 2009)
(collecting cases)).
Interestingly, Plaintiff does not address Sony Mobile’s “center of gravity” argument, but
rather merely tries to distinguish the cited cases on factual bases. Any distinguishing elements of
the cited cases do not obviate the indisputable fact that no aspect of the design or development of
the Accused Products occurred in the Southern District of Florida. As the Accused Products
were developed in California, the operative facts of this litigation and this matter’s “center of
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gravity” is located there, and, accordingly, Plaintiff’s choice of forum is entitled to less
deference. As noted by Judge Middlebrooks, “where the inventor of the patent-in-suit resides in
Florida, the recent creation of Plaintiff as an entity solely to license the patent and enforce the
patent in litigation here does not carry weight.” See Rothschild Digital Media Innovations, No.
14-cv-22134-MIDDLEBROOKS, ECF No. [22], at *7 (citing In re Microsoft Corp., 630 F.3d
1361, 1365 (Fed. Cir. 2011)). Therefore, Plaintiff’s choice of forum is not entitled to substantial
deference. Based upon these facts, the Court finds that these factors heavily favor transfer to the
Northern District of California, despite Plaintiff’s initial choice of forum.
C.
The Relative Means of the Parties
At first blush, the relative means of the parties’ factor appears to weigh in favor of
retaining the action as Sony Mobile is a large corporate entity and Plaintiff is not. However,
Plaintiff and related entities owned and operated by the ‘797 Patent’s inventor have filed over
twenty separate lawsuits in districts other than this one, demonstrating a willingness to litigate
patents elsewhere. See Wynne Decl., ECF No. [30-3] at ¶¶ 15-17. Thus, this factor only
marginally supports a denial of transfer.
D.
Public Interest Factors and the Interests of Justice
The final pertinent factor requires the Court to examine, based on the totality of the
circumstances, trial efficiency and the interests of justice, as well as several other public interest
factors including,
the administrative difficulties flowing from court congestion; the
local interest in having localized controversies decided at home;
the interest in having the trial of a diversity case in a forum that is
at home with the law that must govern the action; the avoidance of
unnecessary problems in conflict of laws, or in the application of
foreign law; and the unfairness in burdening citizens in an
unrelated forum with jury duty.
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Trace-Wilco, 2009 WL 455432, at *2 (quoting Piper Aircraft, 102 S. Ct. at 241 n.6). An
examination of these interests does not substantially favor either position and, therefore, these
factors remain neutral in the Court’s analysis.
Plaintiff implores the Court to impart great significance to maintaining this action here, in
Plaintiff’s home forum. However, as previously discussed, other than Plaintiff’s incorporation in
the State of Florida and very recent acquisition of the patent at issue, this matter does not present
a case where Florida has a substantial interest. The burden imposed upon the Northern District
of California’s citizens is light, given that the California district has a substantial interest in
adjudicating controversies involving a corporation employing hundreds of California residents.
Further, the issue is governed by federal law and jurisdiction of the federal courts is not based on
diversity. Thus, no problems related to the governing law are raised by the transfer of this matter
to the Northern District of California. Ultimately, the public interest factors and the interests of
justice favor transfer. The center of the alleged infringement, related parties, and the community
with the most interest in the matter is not the Southern District of Florida. See Trace-Wilco,
2009 WL 455432, at *4 (finding that transfer would serve the interests of justice where the
center of the accused activity occurred in the transferee district); see generally ShadeFX
Canopies, Inc. v. Country Lane Gazebos, LLC, No. 13-80239-CIV, 2013 WL 9827411, at *3
(S.D. Fla. June 14, 2013) (citing 15 Wright, Miller & Cooper, Federal Practice and Procedure:
Jurisdiction and Related Matters § 3854 at 246-47 (3d ed. 2007) (“a number of federal courts
have considered this factor decisive—outweighing the other statutory factors”)).
E.
Other Considerations
Lastly, Plaintiff asserts that the pendency of the seven related actions in this District
creates practical problems with transfer, rendering a possible scenario where two different courts
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adjudicate the matter. The Federal Circuit has stated that “the existence of multiple lawsuits
involving the same issues ‘is a paramount consideration when determining whether a transfer is
in the interest of justice.’” In re Vicor Corp., 493 F. App’x 59, 61 (Fed. Cir. 2012) (quoting In re
Volkswagen of Am., Inc., 566 F.3d 1349, 1351 (Fed. Cir. 2009)). However, this consideration is
not nearly as prominent given the fact that defendants in all but one of the cases pending before
this Court have moved for transfer on similar grounds.
See supra, at 3 n.2.
Moreover,
“multidistrict litigation procedures exist to mitigate inefficiencies in this type of situation.” In re
Apple, Inc., 581 F. App’x 886, 889 (Fed. Cir. 2014) (citing In re EMC Corp., 677 F.3d 1351,
1360 (Fed. Cir. 2012) (“Common pretrial issues of claim construction and patent invalidity may
also be adjudicated together through the multidistrict litigation procedures of 28 U.S.C. §
1407.”)). For these reasons, the Court also finds that post-claim-construction transfer will not
increase judicial efficiency.5
IV. CONCLUSION
Balancing the aforementioned elements, the Court finds that transfer to the Northern
District of California is warranted. The alternative forum is not only an appropriate forum, but
significantly more appropriate given the fact that the core of activity surrounding the design,
development, and production of the Accused Products occurred there. Plaintiff’s ties to this
forum are tenuous; it does not conduct business in the forum, but was merely formed in order to
license and litigate the patent at issue, which was acquired a mere two weeks prior to
commencing this action. On the other hand, the Northern District of California has significant
5
Additionally, the claim construction process may be conducted on a rolling basis, that is, a
presiding court may “revisit[] and alter[] its interpretation of the claim terms as its understanding
of the technology evolves.” Pressure Products Med. Supplies, Inc. v. Greatbatch Ltd., 599 F.3d
1308, 1316 (Fed. Cir. 2010) (quoting Pfizer, Inc. v. Teva Pharm., USA, Inc., 429 F.3d 1364,
1377 (Fed. Cir. 2005)). Therefore, construction of the claims is best resolved by a single court.
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ties to the Accused Products and can otherwise be deemed the “center of gravity” for this patent
infringement action.
Accordingly, Defendant Sony Mobile Communications (USA) Inc.’s Motion to Transfer
Pursuant to 28 U.S.C. § 1404(a), ECF No. [30], is GRANTED. The Clerk is directed to
TRANSFER this case to the United States District Court for the Northern District of California.
Upon transfer, the Clerk shall CLOSE this case.
DONE AND ORDERED in Fort Lauderdale, Florida, this 14th day of January, 2015.
____________________________________
BETH BLOOM
UNITED STATES DISTRICT JUDGE
Copies to:
Counsel of Record
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