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Chicago IP Litigation Tracking Northern District of Illinois IP Cases

Illinois Witnesses Not Sufficient to Retain Case Where Michigan Witnesses Provide Same Proof

Posted in Federal Rules, Jurisdiction

Addiction & Detoxification Institute, LLC v. Rapid Drug Detox Center, No. 11 C 7992, Slip Op. (N.D. Ill. Mar. 11, 2013) (Coleman, J.).

Judge Coleman granted defendant Rapid Detox’s 28 U.S.C. § 1404(a) motion to transfer this patent infringement case to the Eastern District of Michigan.  While Rapid Detox had a website and had patients from Illinois, the website did not specifically target Illinois residents and Rapid Detox’s treatments all occurred in Michigan.  Furthermore, to the extent that patients became necessary witnesses, there was no reason plaintiff could not use Michigan patients instead of the Illinois patients that it identified in the motion papers.