In re Juniper Networks, Inc.

Brazos Licensing and Development (Brazos) (defendant) helped inventors enforce their patents. Shortly after opening an office in Waco, Texas, Brazos filed suit in the United States District Court for the Western District of Texas against Juniper Networks, Inc. (Juniper) (plaintiff). Brazos alleged that Juniper had infringed multiple patents that had been assigned to Brazos. Juniper, which was headquartered in Sunnydale, California, moved to transfer venue to the Northern District of California. Juniper argued that the transfer was proper because Juniper’s allegedly infringing products were designed, developed, and sold from its Sunnydale headquarters and its potential witnesses, most of whom were Juniper employees, lived in California. Although Juniper maintained some business records in other locations, no relevant records were stored in its small Austin, Texas, office, which was its only office in the Western District of Texas. Additionally, Juniper argued that Brazos’s ties with the Western District of Texas were weak because Brazos only recently opened its Waco office and seemingly did so specifically to pursue litigation in the district. Brazos’s only business from its Waco office was patent litigation, and Brazos identified only one potential witness in Texas. Further, only one Brazos officer lived in Waco, while both its CEO and its president resided in California. After the district court denied Juniper’s motion to transfer, Juniper filed a petition in the Federal Circuit, seeking a writ of mandamus ordering the district court to transfer the case.