Hester v. j2Global Comm., Inc., No. 13 C 6143, Slip Op. (N.D. Ill. Sep. 19, 2014) (Lefkow, J.).

Judge Lefkow held that venue was improper in this patent inventorship dispute, but instead of dismissing, transferred the case to the N.D. Georgia.  The Court lacked venue because:

  • At least one defendant did not reside in Illinois; and
  • The events giving rise to the claim did not happen in Illinois.  Furthermore, the location of the patent was not relevant, and even if it were, there was no evidence that the patent resided in Illinois.

Because the Northern District was not a proper venue and because the parties agreed that N.D. Georgia was a proper venue, the Court transferred the case to the N.D. Georgia.