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Analyzes Illinois Appellate ruling denying improper venue and forum non conveniens in case where co-defendant was dismissed after time required to appear

In the Seventh Circuit it has long been acceptable to file a Motion to Dismiss in order to enforce a forum selection clause. See Auto. Mechanics Local 701 Welfare & Pension Funds v. Vanguard Car Rental USA, Inc., 502 F.3d 740, 746 (7th Cir. 2007).

But a just-published case out of the Northern District of Illinois reflects a different practice:  that a forum-selection clause, if it permits federal jurisdiction, should now be enforced via a motion to transfer, not a motion to dismiss. The history of this change can help inform practitioners when deciding how to enforce forum selection ...