In re TS Tech USA Corp.

Lear Corporation sued TS Tech US Corporation, TS Tech North America, Inc., and TS Tech Canada, Inc. (collectively, TS Tech) (plaintiff) for patent infringement in the United States District Court for the Eastern District of Texas. Lear claimed that headrest assemblies sold by TS Tech to a car company infringed on a Lear patent, and that cars with the headrests were then sold across the United States. TS Tech filed a motion requesting transfer of venue to the Southern District of Ohio, arguing that the requested venue was more convenient. Lear objected. The district court denied the motion, finding that the citizens of the Eastern District of Texas had a substantial interest in a local trial because cars built with the headrest assemblies were sold in the district. The district court also found that TS Tech had failed to show that the inconvenience outweighed the deference owed to Lear’s choice of venue. The district court gave little weight to the potential travel and cost burdens on witnesses, even though key witnesses would have to travel 900 more miles to attend trial in Texas than in Ohio. The fact that most of the physical evidence was in Ohio, Michigan, and Canada was not weighed at all. TS Tech petitioned for a writ of mandamus, arguing that the district court clearly had abused its discretion by denying the motion to transfer.