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Mitchell Ellis Products, Inc. v. AgriNomix LLC
Citations: 242 F. Supp. 3d 320; 2017 U.S. Dist. LEXIS 37743; 2017 WL 1030211Docket: Civ. No. 16-367-SLR
Court: District Court, D. Delaware; March 16, 2017; Federal District Court
Defendant AgriNomix, LLC's motion to transfer venue is granted. Plaintiff Mitchell Ellis Products, Inc. (MEP), an Alabama corporation, claims infringement of its U.S. Patent No. 8,590,583, titled "Potting Apparatus," by AgriNomix, which manufactures and sells the accused devices, "Agrinomix KV-XL Filler with Drill" and "Nursery Potter with Drill." AgriNomix, a Delaware LLC with its principal place of business in Ohio, asserts it has minimal connections to Delaware, having sold only fifteen units in the U.S. and three in Canada, generating approximately $17,000 in profits, and has never operated or sold products in Delaware. The court notes that while plaintiffs have the privilege to choose their litigation forum, the interests of justice may necessitate a transfer under 28 U.S.C. § 1404(a). The judge references established case law that supports a defendant's place of incorporation as a suitable venue and emphasizes the necessity of balancing factors outlined in Jumara v. State Farm Ins. Co. The court finds that administrative difficulties due to court congestion are neutral, suggesting litigators often prefer to prolong disputes. Overall, the analysis leads to the conclusion that transferring the case serves the interests of justice. Motions to transfer cases are typically denied if two conditions are met: the defendant is a Delaware corporation or LLC and conducts business nationally, including in Delaware. However, in this case, there is no evidence that AgriNomix has sold or advertised the accused devices in Delaware, making transfer to the United States District Court for the Northern District of Ohio appropriate. Depositions are usually conducted where the deponents live, and records are often in digital format, minimizing travel burdens for plaintiffs. Trials are time-sensitive events, and the majority of patent suits settle before trial, reflecting broader civil litigation trends. The defendant's motion to stay proceedings pending the transfer ruling is denied as moot, while the motion to stay pending reexamination and inter partes review will be decided by the judge in Ohio. The plaintiff's motion for leave to file a sur-reply has been considered and denied.