Astro-Med, Inc. v. Nihon Kohden America, Inc.
United States Court of Appeals for the First Circuit
591 F.3d 1 (1st Cir. 2009)
Relevant factsFree
Astro-Med (plaintiff), headquartered in Rhode Island, hired and negotiated an employment contract with Plant (defendant) there, gave him access to confidential information, then relocated him to Florida; competitor Nihon (defendant) later hired Plant away knowing of his agreement, and Astro-Med sued in Rhode Island for trade-secret misappropriation and tortious interference, though Plant now resided in Florida and Nihon resided in Rhode Island only for venue purposes.
IssueFree
Whether, in federal court, venue is proper in any judicial district in which a substantial part of the events giving rise to the cause of action occurred.