MindbaseHQ LLC v. Google LLC

I. BACKGROUND

Plaintiff initiated this patent infringement action on November 17, 2020. ECF No. [1]. On January 11, 2021, Plaintiff filed a First Amended Complaint dismissing the originally named defendant and asserting its patent infringement claims against Defendant Google LLC. ECF No. [22] (“Amended Complaint”). The Amended Complaint asserts two separate counts of patent infringement for two different patents Plaintiff owns, see generally id., alleging as follows: 18. Google has directly infringed claims of the Patents-in-Suit under 35 U.S.C. § 271(a) by making, using, offering for sale, selling, and/or importing the below accused database goods and/or services in this District and elsewhere in the United States that include the apparatus and methods claimed in the Patents-in-Suit. 19. Infringing Google products include the Google internet search and Google Ads (collectively, “the [] Accused Services”). Id. ¶¶ 18-19. Defendant now files the instant Motion1 seeking to transfer this action to the United States District Court for the Northern District of California, arguing that the material facts in this case weigh strongly in favor of transfer because this action presents no…