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Challenge to a district court's decision to transfer a case in parties' mirror-image lawsuits filed in two different district courts
Research Automation, Inc. v. Schrader-Bridgeport Int'l, Inc., 09-2232, concerned a challenge to an Illinois district judge's finding that a transfer to Virginia district court under 28 U.S.C. section 1402(a) was the most appropriate resolution of the parties' competing motions, in parties' mirror-image lawsuits filed in two different district courts involving a dispute between the seller and a buyer of an industrial cleaning machine.
In affirming, the court held that the district court's decision to deny the injunction and to transfer the Illinois action to the Western District of Virginia was correct as, where a district court gives thoughtful consideration to the factors applicable to a transfer analysis under section 1404(a), its decision is given substantial deference, and that deference applies regardless of whether there is only one lawsuit between the parties or whether there is a second case pending in the other forum.