Daniel v. American Board of Emergency Medicine

holding that the Sherman Act “can properly confer personal jurisdiction over a defendant” only where the action is brought in “the district where ,.. venue lies.” | holding that § 1406(a) “permits courts to transfer in the interest of justice whenever either personal jurisdiction or venue are improper’ | concluding that Section 12 of the Clayton Act “can properly confer personal jurisdiction over a defendant only . . . where Section 12 venue lies” | concluding that physician-plaintiffs seeking to join cartel were not efficient enforcers of antitrust laws | holding that Section 1391(b)(2) contemplates that venue can be appropriate in more than one district so long as a substantial part of the relevant events took place in each of those districts | holding that a defendant “resides” only in its place of domicile for venue purposes | explaining that anticompetitive effects of defendant‟s behavior “are classic „rule of reason‟ questions, distinct from the antitrust standing question” | noting that “some courts and commentators have suggested assuming the existence of [an antitrust] violation in addressing the issue of standing” | noting that, even where plaintiff has properly asserted antitrust injury, he may not be efficient enforcer of antitrust laws | concluding alleged "contacts ... with the State of New York as a whole, not specifically the Western District of New York" were irrelevant to venue under Section 12 | explaining that a court’s decision to transfer or dismiss a case over which it lacks jurisdiction includes a power of limited review of the merits | holding personal jurisdiction under Clayton Act is only proper when venue provision has been satisfied | explaining that courts “will not waste judicial resources by transferring a case that is clearly doomed” (citation omitted) | noting that the narrow scope of plaintiffs’ requested injunctive relief would not address the alleged violation and concluding that this indicated that they had not suffered an antitrust injury | noting that “Section 1391(b)(2) does not restrict venue to the district in which the ‘most substantial’ events or omissions giving rise to a claim occurred” and concluding that “§ 1391(b)(2 | noting that “Section 1391(b)(2) does not restrict venue to the district in which the ‘most substantial’ events or omissions giving rise to a claim occurred” and concluding that “§ 1391(b)(2 | noting that “‘[s]ubstantiality’ for venue purposes is more a qualitative than a quantitative inquiry.” | explaining that “[i]n most instances, the purpose of statutorily defined venue is to protect the defendant against the risk that a plaintiff will select an unfair or inconvenient place of trial.” | explaining that appropriate venue can exist in multiple districts, and “Section 1391(b)(2) does not restrict venue to the district in which the ‘most substantial’ events or omissions giving rise to a claim occurred” | stating that antitrust injury “would not necessarily establish [plaintiffs’] standing to sue” because other considerations “may sometimes indicate that a party who states an antitrust injury is nevertheless not a proper antitrust plaintiff’ | noting that a court must decide whether to “simply affirm dismissal on these [improper venue] grounds or, in the interest of justice, order transfer of the action to another district where jurisdiction and venue properly obtain” | explaining that substantiality is “determined by assessing the overall nature of the plaintiff’s claims and the nature of the specific events or omissions in the forum, and not by simply adding up the number of contacts” | noting that a court must decide whether to “simply affirm dismissal on these [improper venue] grounds or, in the interest of justice, order transfer of the action to another district where jurisdiction and venue properly obtain” | noting that a court must decide whether to “simply affirm dismissal on these [improper venue] grounds or, in the interest of justice, order transfer of t