Greenberg v. Johnson Controls Inc, 2:25-cv-01004

Plaintiffs, long-term HVAC Account Executives for Johnson Controls, Inc. (“JCI”), sued in the Eastern District of Pennsylvania, alleging breach of contract for unpaid commissions under JCI’s 2023 incentive plan.
Plaintiffs claimed that after JCI implemented a new 2024 commission plan, it refused to pay out earned commissions from jobs booked under the previous plan, contrary to expectations set by the 2023 plan.
This Pennsylvania lawsuit is one of several similar actions nationwide, with the earliest-filed (the "Novin" class action) and multiple related cases consolidated or transferred to the Eastern District of Wisconsin, JCI’s principal place of business.
JCI moved to transfer this case to the Eastern District of Wisconsin for convenience and judicial efficiency, and Plaintiffs moved to compel the deposition of a key JCI executive and for sanctions.
The court considered both the traditional Section 1404(a) transfer analysis (using Jumara factors) and the "first-filed rule" due to parallel overlapping cases in other federal districts.

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Should venue be transferred to Wisconsin?	Plaintiff’s choice of forum; claims relate to PA branch.	Efficiency, judicial economy, locus of contract breach in Wisconsin, first-filed rule.	Court transferred to Wisconsin; both Section 1404(a) and first-filed rule support transfer.
Has JCI waived right to seek transfer?	Did not raise improper venue in original pleadings.	Section 1404(a) transfer may be raised at any time, improper venue not at issue.	No waiver under Section 1404(a); transfer motion is timely and proper.
Should discovery sanctions be imposed for refusing deposition?	JCI refused deposition unreasonably after scheduling.	With transfer in play, postponing was reasonable litigation strategy.	Denied; court found JCI’s conduct justified under circumstances.
Does interest of justice favor transfer?	Local PA interest in case; inconvenience to plaintiffs.	National scope of dispute; centralized litigation in Wisconsin more efficient.	Public interest and judicial efficiency outweigh local forum preference.

Jumara v. State Farm Ins. Co., 55 F.3d 873 (3d Cir. 1995) (outlines factors for venue transfer under § 1404(a))
Stewart Organization, Inc. v. Ricoh Corp., 487 U.S. 22 (1988) (district courts have discretion in venue transfer analysis)
E.E.O.C. v. Univ. of Pennsylvania, 850 F.2d 969 (3d Cir. 1988) (explains and applies the first-filed rule in overlapping federal litigation)