Federal Circuit disposition — 26-141

N OTE: This order is nonprecedential.
United States Court of Appeals
for the Federal Circuit
______________________
In re ZOHO CORP. PVT., LTD.,
Petitioner
______________________
2026-141
______________________
On Petition for Writ of Mandamus to the United States
District Court for the Eastern District of Texas in No. 2:25-
cv-00414-JRG-RSP, Judge J. Rodney Gilstrap.
______________________
ON PETITION
______________________
Before P ROST , MAYER , and CUNNINGHAM , Circuit Judges.
CUNNINGHAM , Circuit Judge.
O R D E R
Zoho Corp. Pvt., Ltd. petitions for a writ of mandamus
directing the United States District Court for the Eastern
District of Texas (EDTX) to vacate its order denying trans-
fer and to transfer the case to the United States District
Court for the Western District of Texas (WDTX). Knossos
Global Systems LLC opposes. We deny the petition.
In April 2025, Knossos brought this suit in EDTX
against Zoho, an Indian company, alleging its email soft-
ware solution, Zoho Mail, infringes Knossos’s patents. It is
undisputed that India is where Zoho Mail was developed
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IN RE ZOHO CORP . PVT., LTD. 2
and where the source code and relevant technical docu-
ments are stored electronically.
In August 2025, Zoho moved to transfer the case to
WDTX under 28 U.S.C. § 1404(a), noting both Knossos and
Zoho’s non-party U.S. affiliates (collectively, “Zoho U.S.”)
maintain offices in WDTX and arguing that EDTX is where
“marketing, sales, and financial operations related to Zoho
Mail in the United States” took place. App’x 111. In March
2026, the magistrate judge denied the motion, concluding
no private- or public-interest factor favored transfer and
that the practical problems factor slightly disfavored trans-
fer.1 In particular, the magistrate judge determined that
the bulk of the relevant evidence and the willing witnesses
are located in India, which is “equally inconvenient” to
WDTX and EDTX and “little relevant evidence stems” from
Zoho U.S.’s documents in WDTX. App’x 5–6. Zoho did not
object to the magistrate judge’s decision, and this petition
followed.
Applying regional circuit law, we review a § 1404(a) de-
cision on mandamus only for a “‘clear’ abuse of discretion
such that refusing transfer produced a ‘patently erroneous
1 As the Fifth Circuit explained in In re Volkswagen
AG, the private factors include: “(1) the relative ease of ac-
cess to sources of proof; (2) the availability of compulsory
process to secure the attendance of witnesses; (3) the cost
of attendance for willing witnesses; and (4) all other prac-
tical problems that make trial of a case easy, expeditious
and inexpensive.” 371 F.3d 201, 203 (5th Cir. 2004) (cita-
tion omitted). The public factors include: “(1) the adminis-
trative difficulties flowing from court congestion; (2) the
local interest in having localized interests decided at home;
(3) the familiarity of the forum with the law that will gov-
ern the case; and (4) the avoidance of unnecessary prob-
lems of conflict of laws of the application of foreign law.”
Id.
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IN RE ZOHO CORP . PVT., LTD. 3
result.’” In re TS Tech USA Corp., 551 F.3d 1315, 1319
(Fed. Cir. 2008) (noting that this court applies “the laws of
the regional circuit in which the district court sits” when
reviewing a petition for a writ of mandamus of a transfer
decision); see In re Volkswagen of Am., Inc., 545 F.3d 304,
310 (5th Cir. 2008) (in reviewing a petition for a writ of
mandamus of a transfer decision, “we only will grant man-
damus relief when . . . errors produce a patently erroneous
result”). We cannot say such a result occurred here. The
magistrate judge found that judicial economy considera-
tions slightly favored EDTX given overlap with co-pending
litigation in the same district involving the same asserted
patent. App’x 6. To be sure, such considerations here could
not override a clear imbalance on the other transfer factors;
however, the inventors, party witnesses, and bulk of the
evidence concerning the development of the accused prod-
uct are all located outside WDTX.2
Zoho’s arguments, premised largely on Zoho U.S.’s
presence in WDTX, have not established entitlement to
mandamus relief. Zoho’s contention that the magistrate
judge erred in weighing the compulsory process factor as
neutral is undermined by its own transfer motion which
urged the same conclusion. See App’x 6, 112. Zoho also
argues the magistrate judge’s transfer analysis overlooked
two potential witnesses residing in WDTX.3 But Zoho first
identified these individuals in its reply in support of its
2 While Knossos has an office in WDTX, its identified
employee witnesses reside outside both districts. Moreo-
ver, the evidence and one potential Zoho U.S. employee wit-
ness identified in the transfer motion in WDTX appear to
relate only to sales and marketing information.
3 These witnesses include a Zoho U.S. employee
“with knowledge of the design, development, operation,
[and] U.S. financials . . . for the [accused] product,” ECF
No. 2-1 at 25, and a third-party prior art witness.
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IN RE ZOHO CORP . PVT., LTD. 4
transfer motion. App’x 281–82. Under such circum-
stances, we cannot say the magistrate judge clearly erred.
See Magnolia Island Plantation, L.L.C. v. Whittington, 29
F.4th 246, 251–52 (5th Cir. 2022) (noting that a district
court is not required to address an issue raised first in a
reply). Finally, we are not prepared to say that the local
interest in having localized interests decided at home fac-
tor is entitled to significant weight here, given neither dis-
trict has any meaningful connection to the events giving
rise to the invention or the design or development of the
accused product.
Accordingly,
I T I S O RDERED T HAT :
The petition is denied.
July 15, 2026
Date
F OR THE COURT
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