8. In GOLDLAWR, INC. v. HEIMAN, 369 U.S. 463, 82 S.Ct. 913, 8 L.Ed.2d 39 (1962), discussed in the principal case, the Supreme Court held that 28 U.S.C. § 1406 authorizes the transfer of an action even if the transferor court lacks personal jurisdiction. Is this use of Section 1406 now foreclosed by the enactment in 1982 of 28 U.S.C. § 1631, permitting transfer of an action between any two federal courts when the original court lacks jurisdiction? Unfortunately, Section 1631 does not specify what the word “jurisdiction”

means in this context. Those circuits that have considered the question are divided as to whether jurisdiction means subject-matter jurisdiction, personal jurisdiction, or both.

See Cimon v. Gaffney, 401 F.3d 1, 7 n.21 (1st Cir. 2005).