As such, the Qualcomm employees with knowledge of the accused functionality, and the majority of Qualcomm’s relevant documents—including the source code implementing the allegedly-infringing LTE functionality—are located in or near its San Diego headquarters.
Further, the LG engineers involved in integrating Qualcomm’s SoCs into LG’s cellular- capable products worked in the Qualcomm Joint Lab, located in LGEUS’s office at 10225 Willow Creek, San Diego, CA 92131.
Even in cases involving intimate parent- subsidiary corporate relationships, a plaintiff seeking to impute one corporation’s property to another for venue purposes carries a “heavy burden” to show “a sufficient degree of control” to establish alter ego status.
Similarly, the former LGEUS employees and now third-party engineers involved in integrating Qualcomm’s SoCs into LG’s accused products are likely relevant to this case, and to the best of LG’s knowledge, are still located in SDCA following the recent closure of LG’s mobile division.
And while LG is unaware of the location of any relevant Neo witnesses, the convenience of traveling from Neo’s principal place of business in Wayne, Pennsylvania to SDCA and WDTX is neutral.