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Federal Circuit: Case Belongs In the Northern District of California, Not Western District of Texas
On Sept. 24, 2021, a Federal Circuit panel of Judge Lourie, Judge Bryson, and Judge Taranto issued a decision in In re Juniper Networks, Inc., No. 2021-160 (Fed. Cir. 2021). In a unanimous decision, the Federal Circuit vacated the district court's denial of a motion to transfer and directed that the case be transferred under 28 U.S.C. §1404(a).
In September 2020, WSOU Investments LLC d/b/a Brazos Licensing and Development (Brazos) sued Defendant Juniper Networks, Inc. (Juniper) for patent infringement in the Western District of Texas. Juniper sought to transfer the case to the Northern District of California, arguing that "whatever ties Brazos has to this District appear to have been created for the purpose of its patent litigation activities in this District." Slip op. at 2. Juniper argued that Brazos' only business in the district is filing patent lawsuits, and that Brazos' offices and officers are primarily in California. Id. at 3. Juniper argued that the Northern District of California was a more convenient forum, as "the accused products were primarily designed, developed, marketed, and sold from Juniper's Sunnyvale headquarters within the Northern District of California." Id. Brazos argued that venue is proper in the Western District of Texas, as both parties maintain offices in the district. Id.
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