Summary
The United States District Court for the Eastern District of Texas grants Darktrace, Inc.’s motion to transfer a patent-infringement action to the Northern District of California under 28 U.S.C. § 1404(a). The court concludes that the Northern District of California is clearly more convenient based on the location of witnesses, documents, customers, and alleged infringing activity, while no factor weighs against transfer.
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Practice areas
Questions Presented
- Whether the Northern District of California was a district in which the patent-infringement action could have been filed.
- Whether Darktrace established good cause for transfer under 28 U.S.C. § 1404(a) by showing that the Northern District of California was clearly more convenient than the Eastern District of Texas.
Holdings
- The Northern District of California was a district in which the patent-infringement action could have been filed because Darktrace’s principal office was located there and Gatekeeper did not dispute that some alleged infringing acts occurred there.
- Transfer to the Northern District of California was warranted because Darktrace clearly demonstrated that the Northern District of California was more convenient than the Eastern District of Texas.
Key quotations
“Because Darktrace has demonstrated that the Northern District of California is clearly a more convenient venue for this action, the motion will be granted.”
“The Court, having considered the facts and law, concludes that the Northern District of California is clearly the more convenient venue to resolve this action than the Eastern District of Texas.”
Factual background
Gatekeeper, a New York corporation, alleged that Darktrace’s email product infringed U.S. Patent No. 9,032,038. Darktrace is a Delaware corporation headquartered in San Francisco, and its former small office in Plano, Texas, had closed before the motion was decided. Darktrace’s likely witnesses and relevant product documents were located principally in the Northern District of California and Cambridge, United Kingdom, while approximately twenty-four accused-product customers were located in the Northern District of California and only one was located in the Eastern District of Texas.
Procedural history
Gatekeeper filed a patent-infringement action against Darktrace in the Eastern District of Texas. Darktrace moved to transfer venue to the Northern District of California, the motion was fully briefed, and the case had been stayed pending ex parte reexamination since April 2025. The court granted the motion and ordered transfer.