In the months since the U.S. Supreme Court established the “nerve center” test as the definitive test for determining corporate citizenship, two federal judges in the U.S. District Court for Eastern District of Pennsylvania have issued conflicting rulings on whether pharmaceutical manufacturer GlaxoSmithKline is a corporate citizen of Pennsylvania or Delaware.

One judge ruled June 23 that two Brooklyn plaintiffs should not have their case removed from the Philadelphia Common Pleas Court because the judge concluded GSK conducts its business operations at its Philadelphia office. Another judge ruled that a Florida plaintiff should have her case removed from the Philadelphia Common Pleas Court because GSK’s significant decisions are made and ratified by its directors and officers in Delaware.

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