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For many years, it has been routine for a patent plaintiff, particularly a non-practicing entity (NPE), to file one infringement suit against multiple defendants, in a jurisdiction he or she felt was more favorable. These types of suits typically asserted infringement of one or more patents by a diverse group of defendants who were using different apparatuses, systems, or processes. Occasionally, some of the defendants would seek to sever the action and transfer the severed cases to other venues. These approaches met with limited success.

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