One of Edward Tufte’s principles is to keep the labels close to the content. In JMP 13, Graph Builder has the option to place the legend in the upper left or upper right within the graph. If your graph happens to have some empty space in a corner, this is one way to make the labels closer and keep the whole graph more compact.
Placing a legend in the upper left corner of the graph
The ideal is to label the content directly, but that often involves some manual placement and can’t be readily automated. Use the annotation tools in JMP when you need to go that extra step for a presentation graphic.