If I were some type of lawyer, I would be more confident in my assertion but I think the possibility exists that it's taken into account. Along with the other factors that you allude to, including U1.
Lawyers make up stuff as they go along all the time. Just depends on what they can get away with. Eh?
Of course, And venue can be hotly litigated. Courts can also remove cases from one jurisdiction to another, and defendants have the right to ask for removal, on many different rationales, including convenience.
The set of NSA civil cases, some 20 of them, were consolidated and removed to Federal court in San Francisco, for example. Plaintiffs from Maine, to Washington State, to Indiana, and 15 or so other states. Not removed to Utah, where the data was all directed.