Judge Albright Reverses Transfer Decision In Open Text Corp.

Less than a month after denying Alfresco Software, Ltd.'s motion for transfer of venue under 28 U.S.C. 1404(a) in Open Text Corp. v. Alfresco Software, Ltd., Judge Albright reversed his own order in light of In re Juniper Networks, Inc., 14 F.4th 1313 (Fed. Cir. 2021). The case has now been transferred to the Central District of California (CDCA).

As previously discussed, the case concerns nine patents Open Text owns. Open Text is an enterprise information management software company with offices in both the Northern District of California and the Western District of Texas (WDTX). While Open Text accuses all four defendants of collectively infringing all nine patents, only two defendants have a connection to the WDTX. The defendants sought to have the case transferred to the CDCA.