Nine Energy Service Inc.'s motion to transfer venue, in NCS Multistage Inc.'s action against Nine Energy for patent infringement, was denied by a federal district court in Texas. In examining the private Volkswagen factors, the court found that (1) “the relative ease of access to sources of proof” and “all other practical problems” factors weigh against transferring the case; (2) the “compulsory process” factor weighs in favor of transfer; and (3) the “cost of attendance” factor is neutral. In examining the public Volkswagen factors, the court found that (1) the “administrative difficulties flowing from court congestion” factor weighs against transfer ...
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