Cogmedia LLC v. Meta Platforms, Inc. d/b/a Facebook, Inc. (D. Mass. 25-cv-12127).

In July 2025, Cogmedia accused Meta of patent infringement, and while not disputing that venue was proper in Massachusetts, Meta moved to transfer the case to the Northern District of California.

Cogmedia asserts three patents listing Dr. Paul Keel, a former MIT PhD student and Cambridge, MA resident and Cogmedia’s sole managing member.

Judge Murphy denied the motion to transfer.  He noted that, while venue is a matter for the Court’s discretion, there is a presumption in favor of the plaintiff’s choice of forum.  He noted that litigating in California would no doubt be more convenient for Meta, the presumption in favor of the plaintiff’s chosen forum renders transfer solely for the purpose of shifting inconvenience from one party to the other inappropriate.  Similarly, the inconvenience to Meta’s party witnesses is entitled to less weight than any inconvenience to third party witnesses, and the ability to transfer documents electronically entitles any inconvenience associated with the location of documents minimal.  Judge Murphy felt that the California had a greater interest in the outcome of the litigation than Massachusetts, given that the accused infringing products and services were created and implemented in that District, but he felt that this weighed only slightly in Meta’s favor.  Because it is a patent case, the same law would be applied regardless of the venue, rendering this factor irrelevant.  Finally, the judicial economy factor weighed slightly in Cogmedia’s favor, given the Massachusetts’ Court’s familiarity with the case as a result of adjudicating Meta’s motion to dismiss.