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Courts are skeptical that the commencement of a suit in an inconvenient forum may be the basis of Rule 11 sanctions where venue was not improper. 'Attorneys are not under an affirmative obligation to file an action in the most convenient forum; their only obligation is to file in a proper forum.' Newton v. Thomason, 22 F.3d 1455, 1463-64 (9th Cir. 1994) (reversing order imposing sanctions 'for an 'unnecessary and frivolous' choice of venue,' where district court found venue tenuous but not improper).
