This factor, therefore, weighs in favor of dismissal. Plaintiffs argue that defendants "are silent" on this issue, Pls.' Resp 70, ECF #42, and attempt to compare this case to this court's decision in Birdwell & Janke, LLP v. Farkas, 3:18-CV-00910-YY, 2018 WL 6072030 (D. Or. Oct. 19, 2018), findings and recommendations adopted, 3:18-CV-00910-YY, 2018 WL 6070339 (D. Or. Nov. 20, 2018). The dispute in Birdwell centered around unpaid legal fees for services that Oregon patent attorneys performed in Oregon for California defendants.