In The Wake of TS Tech: Decisions from the Western District of Wisconsin Indicate Continued Challenges for Transfer Motions
By Michael Bednarek & Aslan Baghdadi
Two recent decisions from the Western District of Wisconsin suggest that the Federal Circuits decision in TS Tech (see earlier alert) may not have repercussions in patent friendly forums outside the Fifth Circuit. The decisions in Wacoh Co. v. Chrysler LLC et al., (Wacoh) and Ledalite Architectural products v. Pinnacle Architectural Lighting, Inc., 2009 WL 54239 (W.D. Wis. Jan. 7, 2009) (Ledalite), both by Chief Judge Barbara Crabb, show that even in the wake of the Federal Circuits TS Tech decision, the Western District of Wisconsin is not yet ready to grant an increased number of motions to transfer venue.