Judge: Michael Schneider
Holding: Motion to Transfer Venue DENIED
In this case, the defendant sought a transfer to the Northern District of Illinois. Judge Schneider concluded that one private factor only slightly favored transfer, while the remaining seven factors were neutral. “When viewed holistically,” the Court philosophized, as Judge Schneider is wont to do, “this is a very close case. The proposed venue is as convenient as—if not slightly more convenient than—the Eastern District of Texas. But slightly more convenient does not rise to the level required under section 1404(a). Groupon bears the burden to demonstrate that the Northern District of Illinois is clearly more convenient than the Eastern District of Texas. Groupon has not met that burden.”
Referring to the facts of the case, the Court made some further observations. “This case does not present a scenario where Blue Calypso filed a lawsuit in a venue devoid of any real connection to the case. Instead, Blue Calypso filed this lawsuit in its home venue, the Eastern District of Texas. Based on the balance of factors, it would not be “clearly more convenient” to transfer this case to the Northern District of Illinois.” Accordingly, the motion to transfer (and the attendant motion to stay pending ruling) was denied.
From Docket Navigator.