govinfo:USCOURTS-njd-2_25-cv-06316-0

Not for Publication 
UNITED STATES DISTRICT COURT 
DISTRICT OF NEW JERSEY 
 
JANE DOE (C.M.B.), 
 
                              Plaintiff, 
 
                              v. 
 
WYNDHAM HOTELS & RESORTS, INC., et 
al., 
 
                              Defendants. 
 
 
Civil Action No.: 25-06316 (ES) (SDA) 
 
OPINION 
SALAS, DISTRICT JUDGE 
Before the Court are two motions to dismiss Plaintiff Jane Doe (C.M .B.)’s (“Plaintiff”) 
Complaint, (D.E. No. 1 (“Compl. ”)): (i) defendants  Super 8 Worldwide,  Inc., Wyndham Hotel 
Group, LLC, and Wyndham Hotels & Resorts, Inc. ’s (collectively, the “Wyndham Defendants”) 
motion to dismiss, (D.E. No. 21 (“Wyndham Motion”)); and (ii) defendant Independent Lodging 
Company’s motion to dismiss.  (D.E. No. 8).  Defendant Shri Hari Investments LLC did not move 
to dismiss and instead filed an answer to the Co mplaint.  (D.E. No. 28).  The Court refers to 
Defendants Independence Lodging Company (“Independent Lodging”) and Shri Hari Investments 
LLC collectively as the “Franchisees”.  
The Court has carefully considered the parties’ submissi ons in connectio n with the two 
motions, as well as the balance of the record, and decides the matters without oral argument.  See 
Fed. R. Civ. P. 78(b); L. Civ. R.  78.1(b).  For the re asons stated herein, Independent Lodging’s 
motion to dismiss, (D.E. No. 8), is GRANTED IN PART and DENIED IN PART.  This Court 
transfers the instant matter to the United States District Court for the Western District of Missouri. 
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I. BACKGROUND 
A. Factual Background 
Congress enacted the Trafficking Victims Pr otection Reauthorization Act (“TVPRA”) to 
combat human trafficking and provi de both criminal penalties and civil remedies for victims of 
the same.  18 U.S.C. §§ 1581–97.  Among its pr ovisions, 18 U.S.C. § 1591 (“Section 1591”) 
establishes criminal liability for sex trafficking, while 18 U.S.C. § 1595 (“Section 1595”) provides 
a private right of action for victims.  In particular, Section 1595 provides that an individual who is 
a victim of a TVPRA violation may bring a civil action against the perpet rator or against any 
person who knowingly benefits, financially or by receiving anything of value, from participation 
in a venture that the person knew or should have known engaged in trafficking in violation of the 
statute.  See Section 1595(a).   
This case is one of several filed in this Di strict seeking similar redress under the TVPRA 
for alleged sex trafficking in hotels located in various cities.  Plaintiff alleges that between June 
2015 through December 21, 2015, she was sex traffick ed at a Travelodge hotel and a Super 8 
hotel—both located in Missouri.  (Compl. ¶¶ 30–32 &34).  Plaintiff alleges that, when her abusers 
trafficked her at these locations, there were obvious signs that she was being trafficked such that 
the Defendants “knew or through the exercise of reasonable diligence should have known, that 
they were benefitting from a ventur e causing her sexual exploitation.”  ( Id. ¶ 38).  Those signs 
included prepaid room payments, daily extensions of the stay, constant “do not disturb” signs, and 
repeated short visits by multiple non-guest men.  ( Id. ¶ 39).  Additionally, Plaintiff had few 
personal belongings, and her traffickers failed to provide identification to the hotel staff and 
loitered on-site.  (Id.).   
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According to the Complaint, Shri Hari owned, operated and managed the Travelodge hotel 
at issue through the Wyndham Defendants’ franchising system.  (Id. ¶ 42).  Plaintiff further alleges 
that Independence Lodging owned, operated and ma naged the relevant Super 8 hotel through the 
Wyndham Defendants’ system.  ( Id.).  Plaintiff seeks damages fo r the harms stemming from the 
alleged TVPRA violations.  ( Id. ¶¶ 151–53).  She alleges that the relationship between sex 
trafficking and the hote l industry is “widely known and pervasive,” ( id. ¶ 45–47), and that 
“Wyndham’s public statements confirm that it knew sex trafficking was a problem at its hotels[.]”  
(Id. ¶ 61).  Moreover, Plaintiff claims that each of “the Wyndham Defendants monitored criminal 
activity occurring at their brande d hotels and were aware of ac tivity indicating commercial sex 
trafficking or related crimes occurring at those branded hotels, including the [specific property 
where Plaintiff was trafficked.]”  (Id. ¶¶ 66 & 70). 
B. Procedural History 
On May 30, 2025, Plaintiff initiated this lawsuit against the Defendants, alleging violations 
of Sections 1591 and 1595 of the TVPRA.  ( See generally id. ).  In Count I of the Complaint, 
Plaintiff alleges that the Franchisees are liable as perpetrators under Section 1595(a).  (Id. ¶¶ 131–
33).  In Count II, Plaintiff asserts that all Defe ndants are liable as beneficiaries under Section 
1595(a) for the financial benefits derived from their part icipation in a ventur e violative of the 
TVPRA.  (Id. ¶¶ 134–38).  Finally, in Count III Plaintiff contends that the Wyndham Defendants 
are vicariously liable for the acts of their franchisees and those of the franchisees’ subagents.  (Id. 
¶¶ 139–44).   
Following Plaintiff’s commencement of this action, Defendant s filed the present motions 
to dismiss.  (See D.E. Nos. 8 & 21).  Specifically, on June 27, 2025, Independence Lodging moved 
to dismiss the Complaint under Federal Rules of Civil Procedure 12(b)(2) and (3) for lack of 
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personal jurisdiction and improper venue.  (D.E. N o. 8).  Plaintiff opposed the motion, (D.E. No. 
11), and Independence Lodging filed a reply, (D .E. No. 17).  On August 1, 2025, the Wyndham 
Defendants moved to dismiss the Complaint for failure to state a claim under Rule 12(b)(6).  (See 
generally Wyndham Motion).  Plaintif f opposed the motion, (D.E. No. 31), and the Wyndham 
Defendants filed a reply, (D.E. No. 33).  On August 25, 2025, Defenda nt Shri Hari submitted an 
answer to the Complaint without making a motion.  (D.E. No. 28).1    
The motions are therefore now ripe for adjudication. 
II. Legal Standard2 
Under Rule 12(b)(2), the Court may dismiss a complaint for lack of personal jurisdiction.  
When reviewing a motion to dismiss under Rule 12(b)(2), courts “must accept all of the plaintiff's 
allegations as true and construe disputed facts in favor of the plaintiff.”  Carteret Sav. Bank, FA v. 
Shushan, 954 F.2d 141, 142 n.1 (3d Cir. 1992).  The plaintiff bears the burden of establishing the 
court’s jurisdiction over the defendant.  Miller Yacht Sales, Inc. v. Smith, 384 F.3d 93, 97 (3d Cir. 
2004).  Although the plaintiff must ultimately prove personal juri sdiction by a preponderance of 
the evidence, such a showi ng is unnecessary at the early  stages of litigation.  Mellon Bank (E.) 
PSFS, Nat. Ass’n v. Farino , 960 F.2d 1217, 1223 (3d Cir. 1992).  Rather, the plaintiff need only 
present “a prima facie case for the exercise of personal jurisdiction by ‘establishing with reasonable 
particularity sufficient contacts between the defendant and the forum state.’”  Id. at 1223 (quoting 
Provident Nat’l Bank v. Cal. Fed. Sav. & Loan Ass’n , 819 F.2d 434, 437 (3d Cir. 1987)).  Once 
the plaintiff meets this burden, the burden shifts to the defendant to establish the presence of other 
 
1  As Defendant Shri Hari did not move to dismiss the Complaint, the Court does not address any claims against 
Shri Hari in this Opinion. 
 
2  Because this Court does not r each the merits of the Wyndham Defe ndants’ motion, it omits the Rule 
12(b)(6) standard from this section. 
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considerations that would render the exercise of personal jurisdiction unreasonable.  Carteret Sav. 
Bank, 954 F.2d at 150. 
III. Discussion3 
Independence Lodging contends that the Court should dismiss Plaintiff’s claims against it 
for lack of personal jurisdiction.  (See D.E. No. 8-1 (“Mov. Br.”) at 13).  A federal court engages 
in a two-step inquiry to determine whether it may exercise personal jurisdiction over a defendant.  
First, the court must determine whether the relevant state long-arm statute permits the exercise of 
jurisdiction; second, the court must  then satisfy itself th at the exercise of jurisdiction comports 
with due process.  See IMO Indus., Inc. v. Kiekert AG, 155 F.3d 254, 258–59 (3d Cir. 1998).  “New 
Jersey’s long-arm statute provides for jurisdiction coextensive with the due process requirements 
of the United States Constitution.”  Miller Yacht Sales, 384 F.3d at 96 (citing N.J. Ct. R. 4:4–4(c)).  
Under the Constitution, personal jurisdiction can be established either through general or specific 
jurisdiction.  See Bristol-Myers Squibb v. Superior Ct. of Cal. , 582 U.S. 255, 262 (2017).  
Independence Lodging asserts that th e Court has neither general nor specific jurisdiction over it.  
(Mov. Br. at 13).  The Court will address each argument in turn.4 
 
3  The Court notes that, in a related case decided co ntemporaneously, it addressed materially identical 
arguments involving overlapping franchisor defendants. See Doe (A.A.M.) v. Wyndham Hotels & Resorts, Inc. , No. 
24-11502, slip op. (D.N.J. Apr. 27, 2026). The analysis here  tracks that decision closely, although the cases involve 
different franchisee defendants and factual settings. 
 
4  If the court does not hold an evidentiary hearing, a plaintiff need only present “a prima facie case for the 
exercise of personal jurisdiction by ‘establishing with reasonable particul arity sufficient contacts between the 
defendant and the forum state.’”  Mellon Bank, 960 F.2d at 1223 (quoting Provident Nat’l Bank, 819 F.2d at 437).  
The governing standard, then, is similar to that on an ordina ry Rule 12(b)(6) motion to dismiss, which is directed to 
the face of the pleadings plus documents of which the court may properly taken notice.  See Schmidt v. Skolas, 770 
F.3d 241, 249 (3d Cir. 2014) (“To decide a motion to dismiss, courts generally consider only the allegations contained 
in the complaint, exhibits attached to the complaint a nd matters of public record”).  Here, Independence Lodging 
attached two exhibits and declarations to its motion to dismiss, both in support of its argument that this Court may not 
properly exercise personal jurisdiction over it.  (See D.E. Nos. 8-2 & 8-3).  Because the Court holds that Plaintiff has 
not met her burden to present a prima facie case for the exercise of personal jurisdiction, as explained herein, the Court 
does not reach the question of whether it can—or should—p roperly consider Independence Lodging’s declarations 
and exhibits at this stage. 
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A. General Jurisdiction  
Independence Lodging first argues that Plaintiff fails to estab lish that it is  “at home” in 
New Jersey for purposes of general personal jurisdiction.  ( See Mov. Br. at 14).  A district court 
may exercise general jurisdiction when a defend ant’s contacts with the forum state “are so 
‘continuous and systematic’ as to rend er [it] essentially at home.”  BNSF Ry. Co. v. Tyrrell , 581 
U.S. 402, 413 (2017) (quoting Daimler AG v. Bauman, 571 U.S. 117, 127 (2014)).   The Supreme 
Court has observed that “[w]ith respect to a co rporation, the place of incorporation and principal 
place of business are ‘paradig[m] ... bases for general jurisdiction.’”  Daimler, 571 U.S. at 137 
(citation omitted).  Likewise, the United States  Court of Appeals for the Third Circuit has 
recognized that “it is ‘incredibly difficult to establish general ju risdiction over a corporation in a 
forum other than the place of incorporation or principal place of business.’”  Malik v. Cabot Oil & 
Gas Corp., 710 F. App’x 561, 564 (3d Cir. 2017) (quoting Chavez v. Dole Food Co. , 836 F.3d 
205, 223 (3d Cir. 2016) (citation modified). 
Here, the Court lacks general jurisdiction over Independence Lodging.  Independence 
Lodging is incorporated in Missouri with its principal place of business in Kansas.  (Compl. ¶ 19).  
It is thus considered “at home” in Missouri and Ka nsas, not New Jersey.  Plaintiff also fails to 
allege facts suggesting that this  is an “exceptional case” where “a corporation’s op erations in a 
forum other than its formal place  of incorporation or principa l place of business may be so 
substantial and of such a nature as to render the corporation at home in that State.”  Daimler, 571 
U.S. at 139 n.19.  Accordingly, this Court lacks general jurisdiction over Independence Lodging.  
Indeed, Plaintiff concedes this is the case.  (See D.E. No 11 at 4 n.2).  
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B.   Specific Jurisdiction  
Independence Lodging next argues that this Cour t lacks specific juri sdiction over it.  In 
response, Plaintiff argues that (i) Independence Lodging purposely directed its activities at New 
Jersey through its business rela tionship with the Wyndham Defendant s, (D.E. No. 11 at 6); (ii) 
Independence Lodging reached beyond its home state to establish an ongoing business 
relationship tied to New Jersey, as the franchise agreements included a New Jersey choice-of-law 
clause and a forum-selection provision requiring disputes to be resolved in New Jersey, and also 
contemplated continuing cont acts with New Jersey, including the routine submission of 
operational reports, royalty payments, and other communications to Wyndham in New Jersey, (id. 
at 8); (iii) Independence Lodging’s contacts with New Jersey relates to multiple elements of her 
beneficiary claim, including the alleged financial benefits, participation in the trafficking ventures, 
and knowledge of trafficking; (iv) the burden sh ifts to Independence Lodging to show that the 
exercise of jurisdiction would offe nd traditional notions of fair play and substantial justice, and 
Independence Lodging has failed to make the required showing; and (v) New Jersey has a “strong 
interest in regulating th e relevant conduct.”  ( Id. at 12–15).  In reply, Independence Lodging 
emphasizes that the only alleged connection to  New Jersey—a franchi se relationship with 
Wyndham—is legally inadequate, particularly where the alleged trafficking occurred entirely at a 
hotel in Missouri.5  (D.E. No. 17 at 4).  Independence Lodging further contends that Plaintiff relies 
almost entirely on conclusory allegations and assertions made “upon in formation and belief,” 
which are insufficient to establish minimum contacts.  ( Id. a t  5 – 7 ) .   A s  t o  r e l a t e d n e s s ,  
Independence Lodging argues that Plaintiff offers only a weak connection between the Franchisee 
 
5  Plaintiff concedes that a franchis e agreement alone is not a sufficient ba sis to establish specific jurisdiction 
over Independence Lodging in New Jerey and that it is “the ‘contours’ of a business relationship that create minimum 
contracts with the forum.” (D.E. No. 11 at 7 (Quoting Nat’l Women’s Pol. Caucus, Inc. v. Metro. Louisville Women’s 
Pol. Caucus, Inc., 359 F. Supp. 3d 13, 25 (D.D.C. 2019)).  
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Defendants, New Jersey, and Plaintiff’s  sexual trafficking allegations.  ( Id. at 8).  Specifically, 
Independence Lodging argues that Plaintiff iden tifies no New Jersey-based conduct that caused 
her injury, and that generalized allegations ab out franchisor policies, payment systems, or 
nationwide operations do not es tablish the required nexus.  ( Id. at 10–11).  As such, it contends 
that these contacts fall short of the “strong relationship” required for specific jurisdiction.   
Specific jurisdiction arises from “an ‘affili ation between the forum and the underlying 
controversy,’” and a district court exercising specific jurisdiction “is confined to adjudication of 
‘issues deriving from, or connected  with, the very controversy th at establishes jurisdiction.’”  
Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915, 919 (2011) (citations omitted).  
To determine whether specific ju risdiction is appropriate, courts  must conduct a three-pronged 
test.  First, the defendant must have “purposefully directed his activities at the forum.”  Marten v. 
Godwin, 499 F.3d 290, 296 (3d Cir. 2007) (quoting Burger King Corp. v. Rudzewicz , 471 U.S. 
462, 472 (1985)).  Second, the plaintiff’s claim must “arise out of or relate to at least one of those 
specific activities.”  Id.  The Court notes that the “central c oncern” of the second prong is “the 
relationship among the defendant, th e forum, and th e litigation.”  Daimler, 571 U.S. at 126 
(quoting Shaffer v. Heitner, 433 U.S. 186, 197 (1977)).  Third, if the prior two requirements are 
met, a court must consider whether the exercise of jurisdiction otherwise comports with “‘fair 
play and substantial justice.’”  Burger King, 471 U.S. at 476 (citation omitted).   
Turning to the first prong, the Court finds that Independence Lodging purposefully availed 
itself of this forum by en tering a franchising rela tionship with the Wyndham 
Defendants.  See Burger King, 471 U.S. at 480–82.  In Burger King, the Supreme Court held that 
a nonresident franchisee had suff icient minimum contac ts with Florida ev en though its only 
physical connection to the state was attending a brief training course.  Id.  The Court reasoned that 
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the franchisee established a substantial connecti on with Florida by reachi ng out to form a long-
term franchise relationship with a Florida franchisor and by engaging in ongoing obligations that 
tied the parties’ relationship to the forum.  Id. at 478–83.  Similarly, by entering into an ongoing 
franchise relationship with a New Jersey-based  franchisor that requi red regular operational 
coordination, the Franchisee Defendants purposefu lly availed themselves of the benefits of 
conducting activities in New Jersey.  See also Doe (S.A.T.) v. Wyndham Hotels & Resorts, Inc. , 
No. 24-11511, 2025 WL 2848587 at *3 (D.N.J. Oct. 8, 2025) (“Here, Franchisee LLC 
purposefully availed itself of this forum by entering a franchising relationship with Franchisor 
Defendants.”). 
Turning to the second prong, the Court finds instructive the reasoning in  Doe (S.A.T.), a 
similar case in this District involving materially indistinguishable allegations against a franchisee 
defendant.  There, applying Bristol-Myers, the court held that the plaintiff failed to satisfy the 
relatedness requirement where the conduct underlying the claim—namely, the alleged trafficking 
activity—occurred outside the forum notwith standing the franchisee’s ongoing business 
relationship with a forum-based franchisor an d its use of forum-based systems.  2025 WL 
2848587, at * 4 (citing Bristol-Myers, 582 U.S. at 259); see id. (“Although Franchisee LLC may 
have used Wyndham Defendants’ systems in carrying out certain actions, the conduct at the core 
of the alleged ventures, namely, the rental of rooms to sex traffickers, occurred in Texas.” (citation 
modified)).  Thus, the Court held that “the connection between the conduct underlying Plaintiff’s 
claim and this forum [was] too attenuated to find specific personal jurisdiction.”  Id.; see also Doe 
(M.J.J.) v. Wyndham Hotels & Resorts, Inc., No. 24-6490, 2026 WL 308896 (D.N.J. Feb. 5, 2026) 
(applying the Doe (S.A.T.) reasoning to hold that the court lacked personal jurisdiction over the 
franchisee defendants).  The cour t further emphasized that such  contacts standing alone were 
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insufficient to establish specific jurisdiction.  Id. (“Plaintiff’s reliance on Franchisee LLC’s 
routine interactions with Wyndham by virtue of their ongoing business relationship also does not 
constitute a strong connection to Plaintiff’s venture claim. Jurisdiction must be established on the 
basis of each defendant’s own contact with a given forum.” (citing Walden v. Fiore, 571 U.S. 277, 
286 (2014))).   
The Court finds that reasoning persuasive and applicable here.  As in Doe (S.A.T) and Doe 
(M.J.J.), the alleged conduct at the core of Plaintif f’s claims occurred outside New Jersey, and 
Independence Lodging’s routine interactions with a New Jersey-based franchisor do not establish 
the requisite connection to the forum.  Accordingly, Plaintiff has failed to satisfy the second prong 
of the specific jurisdiction analysis.  As the C ourt therefore finds that Independence Lodging is 
not subject to personal jurisdiction in this District with respect to Plaintiff’s claims, the Court need 
not address the third prong of the specific jurisdiction inquiry.  
C.   Transfer is Appropriate 
As the Court has found that it lacks jurisdiction over Independence Lodging, it must now 
determine the best approach for moving this matter forward.  The Third Circuit has made clear that 
“a district court that lacks personal jurisdiction must at least consider a transfer.”  Danziger & De 
Llano, LLP v. Morgan Verkamp LLC , 948 F.3d 124, 132 (3d Cir. 2020).  Indeed, pursuant to 28 
U.S.C. § 1631 (“Section 1631”), when a civil action is filed in a court that lacks jurisdiction, “the 
court shall, if it is in the interest of justice, transfer such action . . . to any other such court in which 
the action . . . could have been brought at the time it was filed.”  Moreover, 28 U.S.C. § 1404(a) 
(“Section 1404(a)”) “permits a court to sua sponte transfer a civil action from one proper venue to 
another proper venue.”  Doe (S.A.T.), 2025 WL 2848587 at *5 (first citing  Jumara v. State Farm 
Ins. Co., 55 F.3d 873, 878 (3d Cir. 1995); then citing Sondhi v. McPherson Oil Co., No. 20-13986, 
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2021 WL 5356182, at *4 (D.N.J. Nov. 17, 2021)). “Conversely, Section 1406 [28 U.S.C. § 1406] 
applies when the original venue is improper.”  Id. (citing Jumara, 55 F.3d at 878). 
The Court holds that venue is proper in the District of New Jersey pursuant to 28 U.S.C. § 
1391 (“Section 1391”) and will therefor e analyze the propriety of a transfer pursuant to Section 
1404(a).6  That statue provides: “For the convenience of parties and wi tnesses, in the interest of 
justice, a district court may transfer any civil action to any other district or division where it might 
have been brought or to any district or division to which all parties have consented.”  The purpose 
of Section 1404(a) is to “preve nt the waste of time, energy, and money and to protect litigants, 
witnesses and the public against unnecessary inconvenience and expense.”  Kremer v. Lysich, No. 
18-03676, 2019 WL 3423434, at *3 (D.N.J. July 30, 2019)  (internal quotati on marks omitted).  
Accordingly, when considering transfer pursuant to Section 1404(a), a court must determine: (i) 
whether the proposed forum is one in which plaintiff could have originally brought suit (or one to 
which the parties have consented), and (ii) whether transfer would be in the interest of justice and 
for the convenience of parties and witnesses.  Id.  As to the former, the Court finds that Plaintiff 
could have originally filed this action in the Western District of Missouri, as a “substantial part of 
the events . . . giving rise” to Plaintiff’s claim occurred there.  28 U.S.C. § 1391(b).  Specifically, 
 
6  In so holding, the Court adopts the reasoning of several of its colleagues in this District on related TVPRA 
claims brought against Wyndham and its franchisees.  See, e.g., Doe (S.A.T.), 2025 WL 2848587, at *5 (holding (i) 
that the Court lacked personal jurisdiction over the franchisee defendants; (ii) that venue was proper in the District of 
New Jersey, such that Section 1404(a) applied; and transfer ring the entire matter to the Northern District of Texas); 
Doe v. Wyndham Hotels & Resorts, Inc. , No. 25-1550, 2025 WL 3754148 (D.N.J. Dec. 24, 2025) (finding venue in 
the District of New Jersey appropriate because “[t]he relationship between [Franchisee Defendant], enforcing 
Wyndham’s polices, and Wyndham, setting the policies, cannot be separated from the harm alleged.  Their franchising 
agreement directed how [Franchisee Defendant] would be paid, what Wyndham’s cut would be, how payments would 
be processed back in New Jersey, and additionally outlin ed when and how [Franchisee Defendant] must report 
suspected sex trafficking to Wyndham. And Wyndham’s  corporate decision-making— which includes decisions 
related to its policies, reporting requ irements, and its supervision and training of [Franchisee Defendant]—and its 
profit-sharing from its corporate headquarters in New Jersey mean that a ‘subst antial part of the events or omissions 
giving rise to’ [Plaintiff’s] claims occurred here.” (citation modified)).  The Court accordingly holds that the District 
of New Jersey is a proper venue pursuant to Section 1391(b), as it is “a judicial district in which a substantial part of 
the events or omissions giving rise to the claim occurred.”   
 
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both of the hotels at issue in this case are located in that District.  (Compl. ¶¶ 31 & 32).  The Court 
must next determine whether transfer to that District would be “in the interest of justice” and serve 
the “convenience of parties and witnesses.”  28 U.S.C. § 1404(a).  In pe rforming this analysis, 
courts in the Third Circuit consider all “relevant public and private interests.”  Santi v. Nat’l Bus. 
Recs. Mgmt., LLC, 722 F. Supp. 2d 602, 606 (D.N.J. 2010) (citing Jumara, 55 F.3d at 879).  Those 
private interests typically incl ude: (i) the plaintiff’s forum pr eference; (ii) the defendant’s 
preference; (iii) whether the cla im arose elsewhere; (iv) the conve nience of the parties; (v) the 
convenience of the witnesses; and (vi) the location of books and records.  Jumara, 55 F.3d at 879 
(citations omitted).  The relevant public interests include (i) the enforceability of the judgment; (ii) 
practical considerations that could make the trial easy, expeditious, or inexpensive; (iii) the relative 
administrative difficulty in the two fora from court congestion; (iv) the local interest in deciding 
controversies at home; (v) the public policies of the fora; and (vi) the familiarity of the trial judge 
with the applicable state law in diversity cases.  Id. at 879–80 (citations om itted).  Courts have 
broad discretion when resolvi ng a Section 1404(a) motion to transfer, and must consider 
“convenience and fairness  . . . on a case-by-case basis.”  Santi, 722. F. Supp. 2d at 606; Stewart 
Org., Inc. v. Ricoh Corp., 487 U.S. 22, 29 (1988). 
The Court finds that, on balance, the relevant public and private interests favor transferring 
this matter.  The record reflects that Plaint iff lives in Missouri and Independence Lodging is a 
Missouri company with its principal place of business in Kansas.  (Compl. ¶¶ 10 & 19).  Critically, 
as the hotels at issue in this cas e are located within the Western Di strict of Missouri, most of the 
activities underlying Plaintiff’s claims occurred therein.  ( See Compl. ¶¶ 31 & 32).  In turn, it is 
likely that witnesses and evidence related to the alleged trafficking at issue are also located there.  
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Further, this Court is confident that Missouri “has an interest in deciding this matter.”  Doe (S.A.T.), 
2025 WL 2848587, at *5.  As my colleagues in this District have held: 
Taking into account judicial economy and the TVPRA’s purposes 
of combatting trafficking, ensuring “just and effective punishment 
of traffickers,” and victim protection, this Court deems the transfer 
of this case to the United States District Court for the Northern 
District of Texas proper. H.R. Conf. Rep. No. 106-939, at 
3 (2000); see Doe v. Choice Hotels Int’l, Inc. , No. 24-1598, 2025 
WL 2108792, at *12 (D. Md. July 28, 2025) (“[T]he [c]ourt finds 
that its lack of personal jurisd iction over [franchisee] GP4, a key 
party in this litigation, strongly counsels in favor of transferring this 
case to the Middle District of Fl orida, a proper venue where, as 
acknowledged at the hearing by De fendants, personal jurisdiction 
would exist over both GP4 and [franchisor] Choice.”); Doe v. 
Choice Hotels Int’l, Inc., No. 24-2836, 2025 WL 2430024, at *6–7 
(D. Md. Aug. 22, 2025) (affording minimal weight to the plaintiff's 
choice of venue where the alle ged trafficking occurred in 
Wisconsin, the same state as Plaintiff's domicile, and transferring 
the case to Wisconsin). 
Id.  Judicial economy concerns al so favor transfer, as  the alternative woul d involve splitting 
Plaintiff’s claims between two fo ra.  The Court finds that most of the remaining public interest 
factors (e.g., enforceability of a judgment, judicial familiarity with state law,  etc.) are neutral to 
the analysis.  Accordingly, this C ourt concludes that transfer to th e United States District Court 
for the Western District of Missouri is warranted. 
IV. Conclusion 
For the foregoing reasons, Independence Lodging’s motion to dismiss is GRANTED IN 
PART and DENIED IN PART .  The Court concludes that it lacks personal jurisdiction over 
Independence Lodging.  Rather than dismissing Plaintiff’s claims against that entity, however, the 
Court finds that a transfer to the United States District Court for the Western District of Missouri 
is appropriate.   The Court will therefore transfer this matter, sua sponte, to that District pursuant 
to 28 U.S.C. § 1404(a).  In light of this transf er, the Court does not addr ess the merits of the 
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Wyndham Defendants’ motion to dismiss under Ru le 12(b)(6).  The Wyndham Defendants may 
re-file that application, post-transfer, at the direction of the transferee court.   
An appropriate Order follows this Opinion.   
Date: April 27, 2026 
 
s/ Esther Salas    
      E s t h e r  S a l a s ,  U . S . D . J .  
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