Judge Andrews recently dropped this intriguing paragraph modifying the balancing of the Jumara transfer factors in light of COVID-19:
Currently, the COVID-19 pandemic is ongoing. Hopefully, things will get better, but the pandemic has highlighted that there can be risks associated with travel. Some people who would not have been worried about travel before the pandemic are now reluctant to travel. I believe it is appropriate to give slightly greater weight to the possibility of less risk associated with less travel, which would favor the [transfer] venue.
The opinion is otherwise a bog-standard grant of transfer where both parties were incorporated in Delaware but had no other real connection. It's quite rare to see any change to the balancing of the transfer factors, though, so I would expect to see this passage cited widely in the coming months.
If you enjoyed this post, consider subscribing to receive free e-mail updates about new posts.
