Force MOS Technology Company Limited v. ASUSTeK Computer Incorporated, 2:24-mc-00013

Force MOS Technology Co., Ltd. (Force MOS) sued ASUSTek Computer, Inc. (ASUS) for patent infringement in the Eastern District of Texas.
ASUS stated its supplier, Panjit International, Inc. (Panjit), a Taiwanese company, is indemnifying ASUS and is central to the alleged infringement.
Force MOS issued subpoenas to Panjit for deposition and document production.
Panjit moved to quash or modify the subpoena in the District of Arizona, where compliance was required.
Force MOS moved to transfer the motion to quash to the Eastern District of Texas, arguing that court is better suited due to its existing familiarity with the case.
The Texas case had been ongoing since 2022, with discovery largely overseen by the Texas court and a Markman hearing already conducted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Transfer motion to quash to Texas court under Rule 45(f)	Texas court is more familiar, better position to decide	No exceptional circumstances to justify transfer	Transfer warranted due to exceptional circumstances
Relevance and complexity of discovery dispute	Patent case technicalities favor Texas court's expertise	Local court should resolve nonparty subpoena motions	Texas court's expertise justifies transfer
Panjit's nonparty status and burden	Discovery central to underlying action and indemnification	Panjit should not be burdened by transfer	Interests of justice favor transfer over burden
Local resolution vs case management efficiency	Texas court's case management requires centralization	Arizona local interests favored	Judicial economy & case management favor transfer

Truswal Sys. Corp. v. Hydro-Air Eng’g, Inc., 813 F.2d 1207 (Fed. Cir. 1987) (district court supervising only discovery in ancillary action should avoid ruling on relevance where original forum is better situated)
Markman v. Westview Instruments, Inc., 517 U.S. 370 (1996) (claim construction in patent cases is exclusively within the court's purview)