Transfer to forum of previous litigation is denied
Quantum Loyalty Systems, Inc. and Quantum Corporation of New York, Inc., v. TPG Rewards, Inc., Civ. No. 09-022-SLR, April 2, 2009.
Robinson, J. Defendant’s motion to transfer to the Southern District of New York is denied.
The court will transfer matters to other districts only (1) there is no bona fide relationship between Delaware and the defendant; (2) there is a related first-filed case in another district; or (3) the defendant is truly a regional enterprise. None of these situations is present in this case. Defendant is a Delaware corporation. The New York litigation was resolved within months and did not involve the same substantive claims. Delaware’s close proximity to New York makes the argument that the defendant is a regional enterprise not compelling. Although defendant’s arguments of inconvenience are unpersuasive, depositions are to take place in the city where the witnesses work.
