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45(c)( 1 )(A). The fourth factorlocus of operative factsalso weighs against transfer, as the central facts happened in Alabama. Ms. Clackum negotiated with Goldco while residing in Alabama, the very first in a chain of events that eventually generated this case. Mr. Wilson supposedly impersonated an Alabama local, utilized a phone number with an Alabama area code, and claimed to have called the Alabama Attorney general of the United States's Office.

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Wilson's actions caused the biggest reputational injury in Alabama since Mr. Wilson particularly implicated Goldco of breaching Alabama law to defraud an elderly Alabama homeowner. Finally, the 8th factorplaintiff's option of venueweighs against transfer due to the fact that Goldco picked the Northern District of Alabama by submitting its claim here. Even after finding out the expected identity of "Bruce Clackum" to be a citizen of California, Goldco preserves that the Northern District of Alabama is its favored location.

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While elements two and threelocation of relevant files and convenience of partiesweigh in favor of transfer, other courts have actually discounted the value of these factors. For example, the Southern District of Florida has held that "producing documents and other apply for litigation. is not typically a challenging experience due to technological advancements, such as electronic document-imaging and retrieval." Video Game Controller Tech., LLC v.

Supp. 2d 1268, 1274 (S.D.  goldco ) (internal quote marks and modifications left out). And the Middle District of Alabama has noted that the "convenience of non-party witnesses receives significantly more weight than the convenience of celebrations or party-witnesses." ASD Specialized Healthcare, Inc. v. Letzer, No. 2:10-CV-388-WKW, 2010 WL 2952573, at * 4 (M.D.