Narrative Opinion Summary
The case involves a dispute between Caldera Pharmaceuticals, Inc., the Regents of the University of California, Los Alamos National Security LLC (LANS), and Uchicago Argonne LLC, centered on a patent licensing agreement. Caldera alleges that LANS breached the exclusivity provision by conspiring to transfer licensed technology to competitors. LANS sought to dismiss or transfer the venue, citing Federal Rule of Civil Procedure 12(b)(3) and 28 U.S.C. §§ 1404(a) and 1406(a). The court found the venue proper for claims related to the breach but improper for fraudulent inducement and concealment claims, as significant events did not occur in Illinois. The court determined that Argonne was subject to personal jurisdiction in New Mexico due to conspiracy allegations with LANS, which allowed for jurisdiction under New Mexico's long-arm statute. The court resolved to transfer the case to New Mexico, considering the convenience of the parties and witnesses, the majority of whom reside there, and the interest of justice. The decision was influenced by the lack of substantial connections between the case and Illinois, Caldera's operational ambiguity in Illinois, and the suitability of New Mexico as the venue for resolving disputes between local entities. Ultimately, LANS's motion to transfer the case to New Mexico was granted.
Legal Issues Addressed
Interest of Justice under 28 U.S.C. § 1406(a)subscribe to see similar legal issues
Application: The court exercised its discretion to transfer the case to a proper venue in New Mexico in the interest of justice, given the connections to New Mexico.
Reasoning: Under 28 U.S.C. § 1406(a), the court has the discretion to transfer a case to a proper venue in the interest of justice, as affirmed by precedents.
Personal Jurisdiction under New Mexico Long-Arm Statutesubscribe to see similar legal issues
Application: The court found that Argonne is subject to personal jurisdiction in New Mexico as its actions, in conspiracy with LANS, were directed toward a New Mexico corporation.
Reasoning: Caldera alleges that Argonne conspired with LANS to defraud it, which constitutes sufficient grounds for asserting personal jurisdiction since the injury occurred in New Mexico.
Transfer of Venue under 28 U.S.C. § 1404subscribe to see similar legal issues
Application: The court ruled that transferring the case to New Mexico is appropriate due to the convenience of the parties and witnesses, as well as the majority of related events occurring there.
Reasoning: Regarding the convenience of parties and witnesses, the case favors transfer to New Mexico. Although the plaintiff's choice of forum typically carries weight, this is diminished since it is not the plaintiff's home state.
Venue under 28 U.S.C. § 1391(b)(2)subscribe to see similar legal issues
Application: The court determined that a substantial part of the events giving rise to Caldera's claims occurred in the current judicial district due to Argonne's alleged collusion with LANS.
Reasoning: The court assessed venue propriety under 28 U.S.C. § 1391(b)(2), concluding that a substantial part of the events giving rise to Caldera's claims occurred in the current judicial district, particularly due to Argonne's alleged collusion with LANS to breach the licensing agreement.