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On Dec. 2, 2011, the U.S. Court of Appeals for the Federal Circuit issued its decision in In re Link_A_Media Devices, which granted a petition for a writ of mandamus directing the U.S. District Court for the District of Delaware to transfer a patent case.1 Although the Federal Circuit had granted similar mandamus petitions in 10 previous cases, all 10 of those successful petitions sought transfer from the Eastern District of Texas.2 Because it was the first time that the Federal Circuit overturned a venue decision from a jurisdiction other than the Eastern District of Texas, Link_A_Media prompted considerable speculation that the District of Delaware would become more amenable to transfer motions and a less desirable forum for patentees to file infringement actions.3

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