Bath & Body Works Direct, Inc. v. Radial, Inc., 2:25-cv-02282

Bath & Body Works Direct, Inc. and Bath & Body Works GC, LLC (collectively, Bath & Body Works) entered into an e-commerce and logistics agreement with Radial, Inc.
Bath & Body Works claimed Radial breached multiple provisions of the agreement and attempted to terminate parts of the agreement, effective March 7, 2025.
Radial disputed the termination and claimed compliance, leading to contentious settlement negotiations.
Radial filed a lawsuit first in the Eastern District of Pennsylvania, seeking declaratory and related relief; two weeks later, Bath & Body Works filed a separate lawsuit in the Northern District of Georgia.
Radial moved to stay or transfer the Georgia action, invoking the first-to-file rule based on its earlier Pennsylvania action.
The current decision addresses only the issue of whether the Georgia case should be stayed or transferred.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Application of first-to-file rule	Issues in both actions are not overlapping	Cases substantially overlap in parties & issues	Rule applies; cases overlap
Exception for anticipatory litigation	Radial filed anticipatorily, in bad faith	Bath had not threatened litigation	No evidence of anticipatory lawsuit
Transfer vs. stay of proceedings	N/A	Transfer is warranted	Transfer to Pennsylvania granted

Manuel v. Convergys Corp., 430 F.3d 1132 (11th Cir. 2005) (explains the first-to-file rule and when exceptions may apply)
Collegiate License Co. v. American Casualty Co. of Reading, 713 F.3d 71 (11th Cir. 2013) (discusses first-to-file doctrine and anticipatory suit exception)