Brunette MacHine Works, Ltd. v. Kockum Industries, Inc.

Background

A U.S. company that makes a log‑debarking machine says a Canadian company helped American manufacturers copy the machine and sued for patent infringement in Oregon after serving the Canadian firm under Oregon’s long‑arm law. The Oregon district court dismissed the case for improper location, relying on the patent‑specific venue rule; the Court of Appeals reversed, and the issue reached this Court.

Reasoning

The Court examined the long history of federal rules about where lawsuits can be filed. From the start, suits against foreigners could be brought in any district. A late‑1800s law created a special rule for patent cases, and later decisions sometimes treated that patent rule as exclusive. But in 1948 Congress codified a separate rule saying an alien may be sued in any district. The Court read that 1948 rule as a broad statement that suits against foreign defendants are outside all the usual venue limits. Because of that long‑standing rule, the special patent rule does not let a foreign company avoid being sued in Oregon.

Real world impact

The decision means a U.S. patent owner can sue a foreign corporation in a district where the foreign defendant can be served, even if the patent venue rule would not otherwise allow suit there. Foreign companies now face the possibility of patent suits in more federal districts. The ruling decides where this case may be heard; it does not decide whether the patent was actually infringed.