Based on its review of the cases cited by the parties, the Court agrees with Plaintiff that there is no bright line favoring motions to stay when a defendant asserts lack of personal jurisdiction in a case. See Childress v. DeSilva Auto. Servs., LLC, No. CIV 20-0136 JB\JHR, 2020 WL 3572909, at *14 (D. N.M. July 1, 2020) (“This lack of clearly prevailing principles is perhaps attributable to stays' discretionary nature and dependence on each case's unique facts.”). Instead, the Court is to consider the circumstances of each case and weigh the burden of discovery on a defendant versus the hardship to a plaintiff if discovery is stayed.

Further, Defendants' contention “that the Supreme Court may soon issue a dispositive opinion” in Texas “cuts both ways . . . because an imminent resolution means that the parties will not spend considerable time or resources before the Supreme Court acts.” Childress v. DeSilva Auto. Servs., LLC, No. 20-cv-0136-JB\JHR, 2020 WL 3572909, at *13 (D.N.M. July 1, 2020). The balance of hardships also weighs against granting a stay.

However, it is noteworthy that many TCPA cases have been removed from state court to courts in this District without incident. See, e.g., Childress v. DeSilva Automotive Services, LLC, 20-cv-136 JB/JHR, 2020 WL 3572909 (D.N.M. July 1, 2020). Moreover, countless TCPA cases that were removed from state courts to federal courts on the basis of federal question jurisdiction have come before other circuits without incident.