In re Fleet Connect Solutions LLC, No. 26-155 (Fed. Cir. Oct. 22, 2026)

LINN, Circuit Judge.

O R D E R

In November and December 2025, Fleet Connect Solutions LLC and OBD Sensor Solutions LLC—both Texas entities—filed three related patent infringement suits against Xirgo Technologies, LLC and Xirgo Holdings, Inc. (collectively, “Xirgo”)—headquartered in Illinois—in the United States District Court for the Eastern District of Virginia. Pursuant to 28 U.S.C. § 1404(a), Xirgo moved to transfer the November actions to the United States District Court for the Northern District of Illinois. The district court denied the motions because Xirgo had not moved to transfer the December action,¹ creating a risk of inconsistent judgments and potential waste of judicial economy. After Xirgo moved to transfer the December action and sought reconsideration, the district court granted transfer for all three cases. Fleet and OBD now petition for writs of mandamus. We are asked to decide whether the court abused its discretion in granting reconsideration and transferring under the circumstances presented.

Our review of transfer rulings is governed by the law of the regional circuit, here, the United States Court of3 Appeals for the Fourth Circuit. See In re TS Tech USA Corp., 551 F.3d 1315, 1319 (Fed. Cir. 2008). Under Fourth Circuit law, we review a district court’s decisions on whether to grant reconsideration under Rule 54(b) of the Federal Rules of Civil Procedure and whether to grant transfer under § 1404(a) only for an abuse of discretion. See Nadendla v. WakeMed, 24 F.4th 299, 303–04 (4th Cir. 2022); Brock v. Entre Computer Centers, Inc., 933 F.2d 1253, 1257 (4th Cir. 1991) (citations omitted). On mandamus, Fleet and OBD must also show, inter alia, a “clear and indisputable” right to relief and the writ is “appropriate under the circumstances.” Cheney v. U.S. Dist. Ct. for D.C., 542 U.S. 367, 380–81 (2004) (cleaned up). Petitioners have not met that demanding standard here.

Fleet’s and OBD’s petitions from the transfer of the two November actions turn on whether the district court abused its discretion in reconsidering its initial transfer decisions after Xirgo moved to transfer the December action. Notably, they do not directly challenge the sufficiency of the district court’s revised findings on the relevant transfer factors. Rather, Fleet’s and OBD’s right to relief in the November actions hinges on their argument that the district court “committed legal error by granting reconsideration under Rule 54(b)” and by giving weight to “movant’s own voluntary, post-ruling litigation” actions. See Appeal Nos. 2026-155 and 158, ECF Nos. 2-1 at 9 and 24 (“Strip out the improper reconsideration and the court’s own original, correct finding controls[.]”).

Their argument against reconsideration depends on two premises. First, citing Phoenix v. Amonette, 95 F.4th 852, 857 (4th Cir. 2024), and Carlson v. Boston Sci. Corp., 856 F.3d 320, 325 (4th Cir. 2017), petitioners argue that a district court may revisit an interlocutory ruling only in three circumstances that authorize departing from the law of the case: (1) when new material evidence is discovered during the litigation; (2) when there has been a change in applicable law; and (3) when there has been clear error4 causing manifest injustice. Second, petitioners contend that Xirgo’s motion to transfer the December action does not fall into any of those categories.

Generally, a “district court possesses broad discretion to revisit a prior ruling,” Nadendla, 24 F.4th at 303, and the law of the case does not “limit the power of a court to reconsider an earlier ruling,” as the “ultimate responsibility of the federal courts, at all levels, is to reach the correct judgment under law,” Am. Canoe Ass’n v. Murphy Farms, Inc., 326 F.3d 505, 515 (4th Cir. 2003). Petitioners cite no authority that shows the district court exceeded its discretion here. Phoenix and Carlson support a district court’s decision to deny reconsideration when the district court concludes that the movant is improperly attempting to get a second bite at the apple or the evidence presented in support is insufficient to warrant reconsideration. 95 F.4th at 857; 856 F.3d at 325–26. But the district court considered and rejected petitioners’ arguments based on those principles here, and we are not prepared to reach a different conclusion on limited mandamus review.

Fleet’s petition challenging transfer of the December action also rises or falls with the district court’s decision on reconsideration that “the interests of justice dictate that the same forum should resolve these disputes,” Appeal No. 2026-159, Appx011, as they assert that transfer “became possible only after the District Court treated a voluntary procedural act as a changed circumstance and then used that changed circumstance to recast the balance.” Appeal No. 2026-159, Pet. at 14. Given the district court’s discretion in deciding these issues, see In re Vistaprint Ltd., 628 F.3d 1342, 1347 (Fed. Cir. 2010), and our conclusions regarding reconsideration, we conclude Fleet has not shown entitlement to relief.

Accordingly,

5IT IS ORDERED THAT:

The petitions are denied.

FOR THE COURT

October 22, 2026

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