LightMed Corporation v. Ellex Medical Pty. Ltd., 3:13-cv-03933

LightMed Corp. and LightMed USA sue Ellex Medical in the Northern District of California over allegedly misleading cease-and-desist letters to its distributors.
Ellex is an Australian company with a Minnesota US subsidiary; LightMed’s distributors include Barron Medical in Chino Hills, CA, and another distributor in Florida/Illinois.
LightMed alleges the letters misrepresented Ellex’s patent rights and were sent to disrupt LightMed’s business relationships and to unfairly compete.
LightMed requests dismissal for improper venue or, in the alternative, transfer to the Central District of California for inconvenient venue.
The court grants transfer under 28 U.S.C. § 1404(a) after weighing convenience and connections to each district.
The Northern District makes a general jurisdiction finding against a lack of forum connection, while finding substantial connections to the Central District justify transfer.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper venue in ND Cal or transfer warranted	LightMed contends ND Cal has general jurisdiction over Ellex	Ellex argues venue is proper here but transferring serves convenience	Transfer granted; ND Cal venue recognized but transfer appropriate
Appropriateness of transfer under 1404(a) given convenience factors	LightMed emphasizes minimal connection to ND Cal and central witnesses	Ellex highlights Central District as proper with closer connections and witnesses	Transfer to Central District granted; factors favor centralization, despite some neutral considerations

Williams v. Bowman, 157 F. Supp. 2d 1103 (N.D. Cal. 2001) (plaintiff’s forum weight reduced when no forum residence or significant connection)
Jones v. GNC Franchising, Inc., 211 F.3d 495 (9th Cir. 2000) (transfer discretionary; individualized analysis of factors)
Texas Gulf Sulphur Co. v. Ritter, 371 F.2d 145 (10th Cir. 1967) (no connection to forum may favor transfer when appropriate)