Northern District of California Transfers GS Labs’ COVID-19 Reimbursement Suit Against Cigna to Connecticut

In GS Labs, LLC v. Cigna Health and Life Insurance Company, et al., No. 24-cv-08749-AMO, 2025 WL 3019519 (N.D. Cal. Oct. 29, 2025), Judge Araceli Martínez-Olguín granted Cigna’s motion to transfer venue, sending the case to the District of Connecticut. The court concluded that Connecticut—not California—was the proper venue for the dispute over alleged underpayment of COVID-19 testing claims.

Background

Nebraska-based GS Labs sued Cigna Health and Life Insurance Company and Cigna General Life Insurance Company, along with six “Administrative-Services-Only” self-funded health plans that used Cigna’s claim administration services: Workday, Visa, Nvidia, Electronic Arts, Oportun, and Databricks. GS Labs alleged Cigna and its ASO clients engaged in a civil racketeering scheme by refusing to pay tens of millions of dollars in reimbursements for COVID-19 diagnostic testing.

Cigna moved to dismiss the case for lack of jurisdiction and improper venue, or alternatively, to transfer the action to Connecticut under 28 U.S.C. § 1404(a). Several of the ASO defendants joined Cigna’s motion. After oral argument on October 28, 2025, the court granted the transfer motion without reaching the merits.

The Court’s Analysis

To transfer a case under § 1404(a), courts weigh the convenience of the parties and witnesses and the interests of justice. Here, Judge Martínez-Olguín found that all relevant factors favored transfer.

1. Plaintiff’s Choice of Forum:
   Although plaintiffs’ choice of forum is typically given deference, the court afforded GS Labs’ selection of California minimal weight. GS Labs is based in Nebraska, Cigna in Connecticut, and none of the 205,442 disputed testing claims occurred in California. The six California-based ASO Plans represented only 0.71% of the $40.8 million in disputed charges, undermining GS Labs’ argument that California had a meaningful connection to the case.
2. Convenience of the Parties and Witnesses:
   Most of the evidence, witnesses, and relevant Cigna personnel are located in Connecticut, where Cigna’s COVID-19 reimbursement policies were developed and where its claims-processing system operates. The policies at issue were formulated in Bloomfield, Connecticut, and payments were issued to GS Labs in Nebraska. Because nearly all material witnesses are in Connecticut or Nebraska, and the ASO Plans consented to jurisdiction in Connecticut, the court found the balance of convenience decisively favored transfer.
3. Local Interests:
   California’s connection to the dispute was minimal—none of the disputed COVID tests took place there, and less than 1% of the alleged damages involved California entities. In contrast, Connecticut had a strong interest in adjudicating a case centered on Cigna’s policies and conduct within its borders.

Distinguishing Prior Cases

GS Labs relied on Ridenour v. Cigna Health & Life Ins. Co., 2015 WL 6674662 (N.D. Cal. 2015), where the court denied a venue transfer in an ERISA case. Judge Martínez-Olguín found Ridenour distinguishable: the plaintiff in Ridenour had direct ties to California and the California Department of Insurance had investigated Cigna’s conduct. No similar ties existed here.

Conclusion

Finding that the operative facts arose in Connecticut and that California had little interest in the matter, the court transferred the action to the District of Connecticut. Workday’s pending motion to dismiss was denied as moot, leaving those arguments to be revisited in the transferee court.