In November and December 2025, Fleet Connect Solutions LLC and OBD Sensor Solutions LLC, both Texas entities, filed three related patent infringement suits in the Eastern District of Virginia against Xirgo Technologies, LLC and Xirgo Holdings, Inc., headquartered in Illinois (Order 2). The petitions arise from Nos. 2:25-cv-00712, 2:25-cv-00713, and 2:25-cv-00837, each assigned to Judge Jamar K. Walker (Order 1-2).
Transfer of all three cases
Xirgo moved under 28 U.S.C. 1404(a) to transfer the November actions to the Northern District of Illinois. The district court denied those motions because Xirgo had not moved to transfer the December action, reasoning that this created a risk of inconsistent judgments and potential waste of judicial economy. A footnote states that, at the time, Xirgo had a pending motion to dismiss the December action based on 35 U.S.C. 101. After Xirgo moved to transfer the December action and sought reconsideration, the district court granted transfer for all three cases (Order 2 and n.1).
The petitions are denied
Fleet and OBD petitioned for writs of mandamus. Circuit Judge Linn wrote the order for a panel that also included Circuit Judges Chen and Cunningham, in In re Fleet Connect Solutions LLC, Nos. 2026-155 and 2026-159, and In re OBD Sensor Solutions LLC, No. 2026-158 (Fed. Cir. Oct. 22, 2026) (nonprecedential) (Order 1-2). Applying Fourth Circuit law, the court reviewed the reconsideration ruling under Federal Rule of Civil Procedure 54(b) and the transfer ruling under section 1404(a) for abuse of discretion. It said that on mandamus, Fleet and OBD must also show, among other things, a "clear and indisputable" right to relief and that the writ is "appropriate under the circumstances," and it held that the petitioners had not met "that demanding standard" (Order 2-3).
The November petitions, Nos. 2026-155 and 2026-158, turned on reconsideration. The court said the petitioners' claim to relief hinges on their argument that the district court "committed legal error by granting reconsideration under Rule 54(b)" and gave weight to the "movant's own voluntary, post-ruling litigation" actions (Order 3). The court noted that the petitioners "do not directly challenge the sufficiency of the district court's revised findings on the relevant transfer factors" (Order 3). Quoting Fourth Circuit precedent, the court said that, generally, a "district court possesses broad discretion to revisit a prior ruling." It said the petitioners cite no authority showing the district court exceeded its discretion, and that because the district court considered and rejected the petitioners' arguments under the Fourth Circuit decisions they relied on, the court was "not prepared to reach a different conclusion on limited mandamus review" (Order 4).
The court said Fleet's petition on the December action, No. 2026-159, rises or falls with the district court's reconsideration decision that "the interests of justice dictate that the same forum should resolve these disputes" (Order 4). Citing the district court's discretion and the Federal Circuit's own conclusions on reconsideration, the court concluded Fleet had not shown entitlement to relief, and it ordered that the petitions are denied (Order 4-5).