Flynn v. Informatica, LLC

Background

Joseph Flynn filed a collective action against Informatica, LLC, alleging failure to pay overtime compensation in violation of the Fair Labor Standards Act (FLSA). Flynn worked for Informatica at its Austin, Texas location. The proposed collective included inside sales employees who worked or had worked for Informatica during the period beginning three years before the complaint was filed and continuing through the present. At the time of the motion, Alison Blakely and Thomas Chard had opted into the case; Blakely worked in Austin, and Chard worked in Redwood City, California.

Informatica was described as a Delaware limited liability company headquartered in Redwood City. It moved under 28 U.S.C. § 1404(a) to transfer the case to the Western District of Texas. Flynn did not oppose the motion.

Transfer analysis

Section 1404(a) permits a federal district court to transfer a civil action to another district where it could have been brought when transfer would serve the convenience of the parties and witnesses and the interests of justice. The moving party must show that the proposed district is the more appropriate forum.

Informatica argued that the Western District of Texas had federal-question jurisdiction because the complaint alleged an FLSA violation, and that the case could have been brought there because Informatica conducted business and maintained offices in Texas and employed Flynn, Blakely, and most other potential collective members there. Informatica also argued that Texas was the location of the material events: the inside-sales efforts were primarily run from Austin, supervisors were located in Texas, compensation and classification decisions were made there, and important employee witnesses lived in or near Austin. It further argued that Texas had a substantial interest because decisions concerning the alleged pay and classification violations were made there.

Disposition

The court found that transfer was warranted. It granted Informatica’s unopposed motion to transfer and transferred the action to the United States District Court for the Western District of Texas. The court directed the clerk to transfer the case and close the file. It also terminated as moot the parties’ stipulation to cancel the case-management conference.

This order addressed venue and did not decide whether Informatica violated the FLSA or whether Flynn or the proposed collective was entitled to overtime compensation.