How have courts interpreted the "first to file" rule?

MultiRegion, United States of America

The following excerpt is from Church of Scientology of California v. U.S. Dept. of Army, 611 F.2d 738 (9th Cir. 1979):

We emphasize that the "first to file" rule normally serves the purpose of promoting efficiency well and should not be disregarded lightly. Cf. Motor Vessels Theresa Ann v. Kreps, 548 F.2d 1383, 1384 (9th Cir. 1977). Circumstances and modern judicial reality, however, may demand that we follow a different approach from time to time, as we do in the present case. 7

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