TC Heartland LLC v. Kraft Foods Group Brands LLC

Background

Petitioner is organized under Indiana law, headquartered in Indiana, and makes flavored drink mixes. Respondent is organized under Delaware law with its principal place of business in Illinois and competes in the same market. Respondent sued petitioner in the District of Delaware claiming patent infringement. Petitioner was not registered to do business in Delaware and had no meaningful local presence there, though it shipped the accused products into the State. Petitioner moved to dismiss or transfer, arguing venue was improper under the patent venue statute and relying on this Court’s earlier decision in Fourco; lower courts and the Federal Circuit denied relief, treating the general venue statute as changing patent venue rules.

Reasoning

The Court addressed whether amendments to the general venue law (§1391) changed the meaning of the patent venue statute (§1400(b)). It explained that Fourco held "resides" in §1400(b) means only the state of incorporation for domestic corporations and that Congress did not amend §1400(b). The Court found no clear congressional intent to alter Fourco, noted §1391’s 2011 saving clause, and rejected the Federal Circuit’s interpretation. The Court reversed the Federal Circuit and held that domestic corporations "reside" only in their state of incorporation for patent venue purposes.

Real world impact

The decision narrows where patent lawsuits against U.S. corporations may be filed, limiting venue to the state of incorporation rather than any district with personal jurisdiction. Plaintiffs who filed in districts based on where companies do business will face dismissal or transfer. The case is remanded for further proceedings consistent with this rule.