4. Of what relevance is the Van Dusen rule when the district court transfers an action within its federal question jurisdiction? See Marcus, Conflict Among Circuits and Transfers Within the Federal Judicial System, 93 Yale L.J. 677, 721 (1984). The circuits currently are divided on this question. Because federal law is assumed to be unitary, some circuits have held that the transferee court should exercise its own judgment when determining the requirements of federal law and not be bound by the law of the transferor court. E.g., Lanfear v. Home Depot, Inc., 536 F.3d 1217, 1223–24 (11th Cir. 2008). Other circuits have recognized a narrow role for Van Dusen in specific statutory contexts that, because of “unique language and purpose,” contemplate “circuit disharmony.” Olcott v. Delaware Flood Co., 76 F.3d 1538, 1546–47 (10th Cir. 1996). How does your analysis change if a federal statute mandates the borrowing of a state statute of limitations? The Ninth Circuit, addressing this question as a matter of first impression, held that under this circumstance a transferee court must apply the state statute of limitations that the transferor court would have applied had the case not been transferred. See Hooper v. Lockheed Martin Corp., 688 F.3d 1037, 1046 (9th Cir. 2012).

What are the arguments against taking this approach?