Bodum USA, Inc. v. Williams-Sonoma, Inc., No. 16 C 981, Slip Op. (N.D. Ill. Jun. 3, 2016) (Kendall, J.).
Judge Der-Yeghiayan granted defendant Williams-Sonoma’s 28 U.S.C. § 1404(a) motion to transfer the Lanham Act case to the Northern District of California.
The Court held as follows:
- Both the Northern District of California and the Northern District of Illinois were proper venues for the suit.
- The Court afforded Bodum’s choice of forum deference, but it was not a controlling factor. And it was given less weight because Bodum had no discernable connection to the Northern District of Illinois.
- Williams-Sonoma showed that a significant portion of the alleged conduct occurred in California. Additionally, Williams-Sonoma’s witnesses and documents were in California.
- Both courts can handle the Lanham Act claims. The only reason to proceed in Illinois would be for the benefit of Bodum’s counsel.