Research Automation Inc. v. Schrader-Bridgeport International, Inc.

Dist. Ct. did not err in granting defendant's motion to transfer instant breach of contract action under 28 USC section 1404(a) where instant action was mirror image of defendant's subsequently-filed breach of contract action filed in Virginia Dist. Ct., and where factors of convenience and public interest, such as material events regarding formation and enforcement of contract, as well as location of sources of proof favored litigating lawsuit in Virginia. Ct. rejected plaintiff's contention that Dist. Ct. was required to follow first-to-file rule so as to defeat defendant's transfer motion under instant circumstances.