Par Pharmaceutical, Inc. v. Alkem Laboratories Ltd.

CourtDistrict Court, E.D. Texas
DecidedSeptember 11, 2024
Docket2:23-cv-00400
StatusUnknown

This text of Par Pharmaceutical, Inc. v. Alkem Laboratories Ltd. (Par Pharmaceutical, Inc. v. Alkem Laboratories Ltd.) is published on Counsel Stack Legal Research, covering District Court, E.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Par Pharmaceutical, Inc. v. Alkem Laboratories Ltd., (E.D. Tex. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

PAR PHARMACEUTICAL, INC., and § ENDO PAR INNOVATION COMPANY, § LLC, § § Plaintiff, § CIVIL ACTION NO. 2:23-CV-00400-JRG-RSP v. § § ALKEM LABORATORIES LTD., §

Defendant. MEMORANDUM ORDER

Before the Court is Defendant’s Motion to Quash Service and Dismiss the Complaint1 or in the Alternative Transfer Venue (Dkt. No. 75). After consideration, the Court concludes that Alkem has not met its burden of showing that the District of Delaware would be a clearly more convenient venue than this forum. Accordingly, the Court DENIES Alkem’s Motion to Transfer. I. APPLICABLE LAW A federal district court may transfer a case “for the convenience of parties and witnesses” to “any other district or division where it might have been brought.” 28 U.S.C. § 1404(a). Section 1404(a)’s threshold inquiry is whether the case could initially have been brought in the proposed transferee forum. In re Volkswagen AG, 371 F.3d 201, 202-03 (5th Cir. 2004) (“Volkswagen I”). The question of whether a suit “might have been brought” in the transferee forum encompasses subject matter jurisdiction, personal jurisdiction, and propriety of venue. Id. at 203. Only if this statutory requirement is met should the Court determine whether convenience warrants a transfer of the case. See id.; In re Volkswagen of Am., Inc., 545 F.3d 304, 312 (5th Cir. 2008) (“Volkswagen

1 The Parties have resolved service, see Dkt. Nos. 23, 26 at n1, as such the Court only addresses the transfer issue. II”). Once the moving party has established that the instant case could have been brought in the transferee forum, the Court moves on to consider the private and public factors provided in Volkswagen I. The private interest factors are “(1) the relative ease of access to sources of proof; (2) the

availability of compulsory process to secure the attendance of witnesses; (3) the cost of attendance for willing witnesses; and (4) all other practical problems that make trial of a case easy, expeditious and inexpensive.” Volkswagen II, 545 F.3d at 315 (quoting Volkswagen I, 371 F.3d at 203). The public interest factors are “(1) the administrative difficulties flowing from court congestion; (2) the local interest in having localized interests decided at home; (3) the familiarity of the forum with the law that will govern the case; and (4) the avoidance of unnecessary problems of conflict of laws [or in] the application of foreign law.” Id. (quoting Volkswagen I, 371 F.3d at 203) (alterations in original). The factors are neither exclusive nor exhaustive, and no one factor is dispositive. Id. The burden to prove that a case should be transferred for convenience falls squarely on the

moving party. Id. Although the plaintiff's choice of forum is not a separate factor, respect for the plaintiff's choice of forum is encompassed in the movant's elevated burden to “clearly demonstrate” that the proposed transferee forum is “clearly more convenient” than the forum in which the case was filed. Id. at 314-15; In re Apple Inc., 979 F.3d 1332, 1338 (Fed. Cir. 2020) (applying Fifth Circuit law). While “clearly more convenient” is not necessarily equivalent to “clear and convincing,” the moving party “must show materially more than a mere preponderance of convenience, lest the standard have no real or practical meaning.” Quest NetTech Corp. v. Apple, Inc., No. 2:19-cv-118, 2019 WL 6344267, at *7 (E.D. Tex. Nov. 27, 2019). In considering a transfer under § 1404(a), the Court may consider undisputed facts outside of the pleadings but must draw all reasonable inferences and resolve factual disputes in favor of the non-movant. See Vocalife LLC v. Amazon.com, Inc., No. 2:19-cv-00123, 2019 U.S. Dist. LEXIS 205696, 2019 WL 6345191, at *2 (E.D. Tex. Nov. 27, 2019); cf. Trois v. Apple Tree Auction Cent. Inc., 882 F.3d 485, 492-93 (5th Cir. 2018) (reviewing a transfer under § 1406); Ambraco, Inc. v. Bossclip B.V.,

570 F.3d 233, 238 (5th Cir. 2009) (reviewing enforcement of a forum-selection clause). II. ANALYSIS

a. Private Interest Factors Alkem largely contends this district has no connection with the underlying infringement at issue. Alkem argues it is an Indian corporation that produces the pharmaceuticals at issue in India but it is not licensed to distribute those pharmaceuticals in the U.S. Instead, it is Alkem’s subsidiary Ascend Laboratories, LLC a Delaware corporation with principal place of business in New Jersey, that distributes Alkem’s products in the U.S. As such, Alkem broadly contends all sources of proof are likely in New Jersey and India where Delaware will offer greater ease of access. Alkem further contends, again broadly, that compulsory process may be needed against Ascend which is amenable to compulsory process in Delaware but not Texas. For willing witnesses, Alkem contends its personnel routinely travel to New Jersey and as such Delaware would be more convenient for them. Alkem further contends the District of Delaware already has at least one case concerning the patent Par asserts here. As such, Alkem contends this weighs in favor of transfer. Par responds that it is asserting infringement of manufacturing claims and as such the relevant evidence will be with Alkem rather than Ascend. Thus, Par contends Alkem’s identification of New Jersey is largely irrelevant. For ease of access, Par contends India will hold the majority of relevant evidence not New Jersey and thus there is little gained through transfer to Delaware. Par also contends Alkem’s failure to specifically identify any documents or other evidence render’s Alkem’s showing deficient. As to compulsory process, Par contends Alkem has not shown any third-party witnesses are likely to reside within the subpoena power of the Delaware court. Par contends that without specifying any witness, this factor is neutral. As to willing witnesses, Par again points to India contending that is where manufacturing takes place and where relevant witnesses will be located. Par contends this district is just as convenient for those witnesses as Delaware. Last, Par contends there are two pending actions covering the asserted patent in this district while there is only one in Delaware, rendering the last private factor neutral. The Court expects greater specificity in defendant’s showing of convenience than the generalized allegation that evidence will be found in one location over another. Such broad allegations as those put forth by Alkem are unlikely to meet its burden to show its preferred forum is clearly more convenient. Here, Alkem has identified no witnesses or evidence with specificity. While the Court agrees the majority of relevant evidence is likely with Alkem, Alkem has not shown how or why Delaware might provide greater ease of access to such information. Without identifying a custodian or physical evidence or some other relevant factor, the Court finds most evidence is likely in India, but that Delaware will not provide greater ease of access. This factor is neutral. As to the witness factors, no party has identified any witness. As such, the Court is only left with the assumption that the relevant witnesses will reside near the principal place of business of the identified parties.

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Related

Ambraco, Inc. v. Bossclip B.V.
570 F.3d 233 (Fifth Circuit, 2009)
In Re Volkswagen Ag Volkswagen of America, Inc.
371 F.3d 201 (Fifth Circuit, 2004)
In Re: Radmax, Limited
720 F.3d 285 (Fifth Circuit, 2013)
Charles Trois v. Apple Tree Auction Center, Inc, e
882 F.3d 485 (Fifth Circuit, 2018)
In re Volkswagen of America, Inc.
545 F.3d 304 (Fifth Circuit, 2008)

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