In Re FLEET CONNECT SOLUTIONS LLC
CourtCourt of Appeals for the Federal Circuit
Date FiledOctober 22, 2026
Docket26-155
StatusUnpublished
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Full Opinion
Case: 26-155 Document: 15 Page: 1 Filed: 10/22/2026
NOTE: This order is nonprecedential.
United States Court of Appeals
for the Federal Circuit
______________________
In Re FLEET CONNECT SOLUTIONS LLC,
Petitioner
______________________
2026-155
______________________
On Petition for Writ of Mandamus to the United States
District Court for the Eastern District of Virginia in No.
2:25-cv-00712-JKW-RJK, Judge Jamar K. Walker.
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In Re OBD SENSOR SOLUTIONS LLC,
Petitioner
______________________
2026-158
______________________
On Petition for Writ of Mandamus to the United States
District Court for the Eastern District of Virginia in No.
2:25-cv-00713-JKW-RJK, Judge Jamar K. Walker.
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In Re FLEET CONNECT SOLUTIONS LLC,
Petitioner
______________________
2026-159
______________________
Case: 26-155 Document: 15 Page: 2 Filed: 10/22/2026
2 IN RE FLEET CONNECT SOLUTIONS LLC
On Petition for Writ of Mandamus to the United States
District Court for the Eastern District of Virginia in No.
2:25-cv-00837-JKW-RJK, Judge Jamar K. Walker.
______________________
ON PETITION
______________________
Before CHEN, LINN, and CUNNINGHAM, Circuit Judges.
LINN, Circuit Judge.
ORDER
In November and December 2025, Fleet Connect Solu-
tions LLC and OBD Sensor Solutions LLC—both Texas en-
tities—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 Vir-
ginia. 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 incon-
sistent 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 of
1 At the time, Xirgo had a pending motion to dismiss
the December action based on 35 U.S.C. § 101.
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IN RE FLEET CONNECT SOLUTIONS LLC 3
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 manda-
mus, Fleet and OBD must also show, inter alia, a “clear
and indisputable” right to relief and the writ is “appropri-
ate 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 de-
cisions 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 No-
vember 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, cor-
rect 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 error
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4 IN RE FLEET CONNECT SOLUTIONS LLC
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 responsibil-
ity 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 discre-
tion 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 sup-
port 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 princi-
ples here, and we are not prepared to reach a different con-
clusion 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 discre-
tion in deciding these issues, see In re Vistaprint Ltd., 628
F.3d 1342, 1347 (Fed. Cir. 2010), and our conclusions re-
garding reconsideration, we conclude Fleet has not shown
entitlement to relief.
Accordingly,
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IN RE FLEET CONNECT SOLUTIONS LLC 5
IT IS ORDERED THAT:
The petitions are denied.
FOR THE COURT
October 22, 2026
Date