Lewis

I. BACKGROUND

The currently operative complaint is Plaintiff’s Second Amended Complaint (ECF No. 19), which incorporates exhibits filed with Plaintiff’s original complaint (ECF No. 1). The Second Amended Complaint makes numerous attacks on YouTube’s Terms of Service. (See, e.g., ECF No. 19 ¶¶ 81–84, 89, 116, 201.) Exhibit S to the original complaint is a PDF rendering of those Terms of Service. (ECF No. 1-19.) The Terms of Service state, among other things, that “[a]ny claim or dispute between you and YouTube that arises in whole or in part from the Service shall be decided exclusively by

a court of competent jurisdiction located in Santa Clara County, California.” (Id. § 14.) The Court will refer to this as the “Forum Selection Clause.”

II. LEGAL STANDARD

“For the convenience of parties and witnesses, in the interest of justice, a district court may transfer any civil action to any other district or division where it might have been brought.” 28 U.S.C. § 1404(a). Normally, the party moving to transfer a case pursuant to § 1404(a) bears the burden of establishing that the existing forum is inconvenient. See Chrysler Credit Corp. v. Cnty. Chrysler, Inc., 928 F.2d…