This decision affirms an order in coordinated suits against Uber by women allegedly assaulted by Uber drivers, staying suit in California on forum non conveniens grounds to allow the plaintiffs to sue instead in the states where the assaults allegedly occurred. The trial court properly determined that those states were “suitable” forums based on Uber’s stated willingness to stipulate to personal jurisdiction there and to waive or toll the statute of limitations from the filing of the California complaint to the filing of a new suit in the state of the assault. Counsel’s offer to stipulate suffices. The moving defendant need not actually stipulate in order to show the alternative forum is suitable. The moving defendant need only show that the forum in which suit was filed is inconvenient, not “seriously inconvenient.” Although the state in which Uber has its headquarters is presumed to be a convenient forum for it, that presumption can be overcome by other evidence, including evidence on the three public interest factors. The order coordinating the California-filed actions in one superior court did not bind the coordination judge or operate as collateral estoppel on the issue of convenient forum.