## Facts

- Brazos Licensing and Development (a patent assertion entity) filed seven patent-infringement suits against Juniper in the Waco Division of the Western District of Texas; one was dismissed, leaving six cases.
- Juniper moved under 28 U.S.C. § 1404(a) to transfer the six remaining actions to the Northern District of California, where Juniper is headquartered.
- Juniper submitted a sworn declaration that the accused products were primarily designed, developed, marketed, and sold from its Sunnyvale, California headquarters, and identified relevant technical, marketing, and sales witnesses located in the Northern District of California.
- Juniper stated it had identified no relevant employees in Texas and that its small Austin office did not maintain relevant records.
- Brazos opened a Waco office shortly before filing suit; corporate materials and a patent-assignment agreement listed a California address for Brazos, and key officers (including its CEO and president) resided in California.
- The district court denied transfer; Juniper petitioned the Federal Circuit for a writ of mandamus directing transfer.

## Issues

1. Whether the district court’s denial of Juniper’s § 1404(a) transfer motion reflected legal error and a clear abuse of discretion warranting mandamus relief.
2. Whether, under the applicable private and public interest factors, the Northern District of California was clearly more convenient than the Western District of Texas.

## Decision

- The Federal Circuit granted Juniper’s petition for a writ of mandamus.
- The court vacated the order denying transfer and directed that the six actions be transferred to the Northern District of California under § 1404(a).
- The court held that the district court committed legal errors in its transfer-factor analysis, amounting to a clear abuse of discretion.

## Legal Principles

- Mandamus may issue to correct a clear abuse of discretion in § 1404(a) rulings, including misapplication of the governing transfer factors.
- A § 1404(a) transfer is warranted when the transferee forum is clearly more convenient based on the relevant private and public interest factors.
- In evaluating convenience, courts must give substantial weight to the location of key witnesses (including non-party witnesses) and the location of relevant evidence tied to the accused products and operative events.
- A forum’s local-interest factor should reflect where the operative facts occurred; minimal or litigation-driven contacts by a plaintiff are weak grounds to retain venue when the accused conduct and core witnesses are concentrated elsewhere.

## Conclusion

The Federal Circuit ordered transfer to the Northern District of California because the district court’s § 1404(a) analysis improperly discounted the California-centered witnesses and evidence and overstated a recently created Texas connection, resulting in a clear abuse of discretion correctable by mandamus.


In re Juniper Networks, Inc., 14 F.4th 1313 (Fed. Cir. 2021)