Sonic Indus., LLC v. iRobot Corp., No. 13 C 9251, Slip Op. (N.D. Ill. Jan. 17, 2014) (Shadur, Sen. J.).
Judge Shadur sua sponte ordered the parties to explain their positions as to whether venue for this patent case was proper in the N.D. Illinois. Based upon the complaint, plaintiff Sonic was a Delaware company and iRobot was a Massachusetts company. The Court saw no connection to the Northern District except, perhaps Sonic’s interest in the Court’s Local Patent Rules.
Universal Beauty Prods., Inc. v. Morning Glory Prods., Inc., No. 10 C 3212, Slip Op. (N.D. Ill. Oct. 18, 2012) (Grady, J.).
Judge Grady denied defendant Morning Glory’s motion to transfer venue to the E.D. North Carolina in this competition–based false patent marking case. The parties agreed that venue was proper in each district. The Court, therefore, only considered the convenience factor and the public interest.
Unlike many prior false marking cases, plaintiff UBP’s choice of forum was given weight as defendant MGP’s competitor who was allegedly harmed by the false marking in this jurisdiction.
The alleged false marking decisions were made in North Carolina, but UBP’s harm allegedly occurred in this district. So, the situs of facts and access to judges were both neutral. Convenience of witnesses weighed slightly in MGP’s favor. Only MGP identified local third party witnesses. But the input of those witnesses was unclear. Convenience of the parties also weighed slightly in MGP’s favor, but the Court balanced that by requiring depositions of MGP personnel to occur where they are located.
Public Interest Factor
The public interest factors were neutral. Both districts had an interest in keeping cases related to their resident corporations. And both districts were well-versed in the law.
Addition & Detoxification Institute, LLC v. Rapid Drug Detox Center, No. 11 C 7992, Slip Op. (N.D. Ill. Oct. 11, 2012) (Coleman, J.).
Judge Coleman granted in part plaintiff ADI’s motion to compel limited jurisdictional discovery in this patent case. ADI’s requests were overly broad and the Court accepted defendant’s declarations, but the Court ordered that defendant respond to limited additional interrogatories:
- Identify customers by race and whether they reside in this district.
- Provide a general statement of defendant’s worth to demonstrate its ability or lack thereof to litigate in this district.