Michael L. v. Anthem Blue Cross & Blue Shield (U.S. Dist. Ct. for the Dist. of UT, case no. 4:21-cv-32-DN-PK, Oct. 29, 2021). In this proceeding, Judge David Nuffer denied Defendants’ motion to dismiss for lack of personal jurisdiction and improper venue and also denied Defendants’ motion to dismiss but did grant Defendants’ motion to transfer venue to the Southern District of Indiana. Plaintiffs filed both an ERISA Recovery of Benefits 1132(a)(1)(B) claim and a Parity Act 1132(a)(3) claim for the denial of MH/SUD RTC treatment for son, Michael L. Anthem’s denial was upheld during the internal and external appeals process. Judge Nuffer explained in detail the court’s rational which included the following. In terms of the personal jurisdiction question: “A defendant has the burden to show a forum is not fair and reasonable by establishing ‘constitutionally significant’ inconvenience such that his or her liberty interests have been violated.” Weighing all of the factors, Defendants did not meet this burden. However, Defendants request to transfer the case to the Southern District of Indiana was granted by the Court. Among other factors, “The convenience of witnesses is typically the most important factor in deciding a (transfer) motion” and in this case, the Judge noted that “Any discovery would focus on the terms of the plan and the rationale behind Defendants’ decision to deny coverage, which would necessarily be produced by the Defendants in Indiana.”