Wimble v. Parx Casino & Greenwood Gaming & Entertainment, Inc., 40 A.3d 174

Wimble filed suit against Greenwood Gaming for a Bucks County incident on April 16, 2010.
Greenwood Gaming filed preliminary objections (venue) on November 16, 2010.
Wimble amended the complaint on December 2, 2010; Greenwood objected again on December 29, 2010.
Wimble filed a second amended complaint on January 14, 2011; objections followed.
Judge Moss sustained the objections and transferred venue to Bucks County on March 7, 2011.
Wimble appeals asserting improper standard, lack of record development, and misassessment of Philadelphia regular business activity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether venue was improper in Philadelphia County	Wimble: Greenwood regularly conducts business in Philly.	Greenwood: venue improper; primary operations in Bucks; sister entities not imputable.	No abuse; venue transferred to Bucks County.
Proper legal standard for venue determination	Court applied incorrect standard; improper Philadelphia venue.	Court correctly applied §2179 quality/quantity test.	Standard applied properly; no error.
Attribution of sister corporations to Greenwood Gaming	Bensalem/Keystone regulars conduct Philly business for Greenwood.	Bensalem/Keystone are sister entities, not subsidiaries; not imputable.	Philadelphia activities of sister entities not imputable to Greenwood.
Whether the court needed further factual record prior to ruling	Rule 1028 requires development of factual record.	Record lacked genuine factual disputes; no discovery needed.	No abuse of discretion; court based on pleadings record.

Purcell v. Bryn Mawr Hospital, 525 Pa. 237 (1990) (quality/quantity test for regular conduct in venue)
Schultz v. MMI Products, Inc., 30 A.3d 1224 (Pa.Super.2011) (requires case-specific facts; supports direct vs. incidental acts)
Hamre v. Resnick, 337 Pa. Super. 119 (1984) (permissible to decide prelim objections on pleadings when no factual issues)