Federal Circuit disposition — 24-139

N OTE: This order is nonprecedential.
United States Court of Appeals
for the Federal Circuit
______________________
In Re ANONYMOUS MEDIA RESEARCH
HOLDINGS, LLC,
Petitioner
______________________
2024-139
______________________
On Petition for Writ of Mandamus to the United States
District Court for the Western District of Texas in No. 1:23-
cv-01143-RP, Judge Robert L. Pitman.
______________________
ON PETITION
______________________
Before L OURIE, H UGHES , and STARK, Circuit Judges.
L OURIE, Circuit Judge.
O R D E R
On July 10, 2024, the United States District Court for
the Western District of Texas (“WDTX”) issued an order
transferring Anonymous Media Research Holdings, LLC
(“AMR”)’s patent infringement action against Roku, Inc. to
the United States District Court for the Northern District
of California (“NDCA”). AMR now petitions this court for
a writ of mandamus directing the district court to reverse
or vacate that order. We deny the petition.
Case: 24-139 Document: 10 Page: 1 Filed: 09/11/2024

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IN RE ANONYMOUS MEDIA RESEARCH HOLDINGS, LLC 2
In its July 10th order, the district court recognized that
“when the transferee venue is ‘not clearly more convenient
than the venue chosen by the plaintiff, the plaintiff’s choice
should be respected,’” Appx0003 (quoting In re Volkswagen
of Am., Inc., 545 F.3d 304, 315 (5th Cir. 2008) (en banc)),
but found Roku had shown good cause to transfer. The
court reasoned that NDCA had a stronger local interest be-
cause “Roku is headquartered there,” “the technologies at
issue were developed in part in the NDCA,” “a number of
likely witnesses are located in the NDCA,” and AMR did
not have any meaningful connection to WDTX. Appx0013.
The district court also determined that the cost of at-
tendance of willing witnesses factor strongly favored trans-
fer, finding “many relevant witnesses are located within
the NDCA . . . while few, if any, likely witnesses are located
in this district.” Appx0011. Although AMR identified
three current and two former Roku employees in WDTX as
potential witnesses, the court found that “[t]here is no rea-
son to think that the Roku [employees] in this district that
AMR identified will provide any relevant testimony,” and,
as to the former employees, “Roku has disputed their rele-
vance and provided seven potential witnesses located in
NDCA who would have more information than the two that
AMR presented.” Appx0009–0010.
The court added that NDCA could compel the testi-
mony of more potential third-party witnesses, Appx0009,
and that it would be easier to access sources of proof in that
forum if the action was transferred because Roku’s source
code, documents, and team that handled those materials
are in NDCA, and, at best, “Roku may have one specific
piece of evidence in” the WDTX, Appx008. Having con-
cluded that several of the relevant “factors weigh over-
whelmingly in favor of transfer” and “[n]o factor weighs in
favor of keeping venue in the Western District of Texas,”
Appx0013–014, the court concluded that NDCA was clearly
more convenient than WDTX, and therefore granted
Case: 24-139 Document: 10 Page: 2 Filed: 09/11/2024

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IN RE ANONYMOUS MEDIA RESEARCH HOLDINGS, LLC 3
transfer. AMR then filed this petition. We have jurisdic-
tion pursuant to 28 U.S.C. §§ 1295(a)(1) and 1651.
Mandamus is “reserved for extraordinary situations.”
Gulfstream Aerospace Corp. v. Mayacamas Corp., 485 U.S.
271, 289 (1988) (citation omitted). A petitioner must show
that: (1) it has a clear and indisputable right to relief; (2) it
does not have any other adequate method of obtaining re-
lief; and (3) the “writ is appropriate under the circum-
stances.” Cheney v. U.S. Dist. Ct. for D.C., 542 U.S. 367,
380–81 (2004) (citation omitted). In the context of transfer
rulings under § 1404(a) arising out of the Fifth Circuit, we
must deny mandamus unless it is clear “that the facts and
circumstances are without any basis for a judgment of dis-
cretion.” Volkswagen, 545 F.3d at 317 n.7. We cannot say
that AMR has satisfied that demanding standard.
As to the local interest factor, AMR has not made a
compelling showing that the district court impermissibly
focused only on the parties as opposed to the events giving
rise to this case. The court also considered and rejected
AMR’s arguments about the relevance of current and for-
mer Roku employees in WDTX and potential third-party
prior art witnesses in NDCA, and we are not prepared to
say that the court’s conclusions on those issues are plainly
incorrect. In addition, while AMR contends that the dis-
trict court should have given more weight in its analysis to
the fact that potential witnesses in the United Kingdom,
New York, and Boston would have to travel less of a dis-
tance to WDTX than to NDCA, we cannot say that it was
unreasonable for the district court here to conclude that, on
balance, it would be more convenient to allow many wit-
nesses to testify close to home than to require all potential
witnesses to travel a significant distance to appear at trial.
We have considered AMR’s remaining arguments on the
other factors and find them unpersuasive to warrant grant-
ing its request for this extraordinary relief.
Accordingly,
Case: 24-139 Document: 10 Page: 3 Filed: 09/11/2024

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IN RE ANONYMOUS MEDIA RESEARCH HOLDINGS, LLC 4
I T I S O RDERED T HAT :
The petition is denied.
September 11, 2024
Date
F OR THE COURT
Case: 24-139 Document: 10 Page: 4 Filed: 09/11/2024

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