TC Heartland LLC v. Kraft Foods Group Brands LLC
The Court ruled that a company can only be sued for patent infringement in the state where it was legally incorporated, rejecting a broader rule that let patent owners sue almost anywhere a company did business.
The decision overturns nearly three decades of practice that had let patent holders file suits in whichever court was seen as most favorable to them, and is expected to sharply reduce the number of patent cases filed in a small handful of popular districts.
“As applied to domestic corporations, “reside[nce]” in §1400(b) refers only to the State of incorporation.”
The Court's core holding on where patent infringement suits can be filed against domestic corporations.
How it got here: A federal trial court rejected the defendant's venue objection, and the Federal Circuit denied a mandamus petition, so the defendant asked the Supreme Court to review the venue ruling.
The Case in Depth
What happened
A drink-mix maker incorporated in Indiana and headquartered there was sued for patent infringement by a competing food company in a Delaware federal court, even though the drink-mix maker had no offices or registration in Delaware — it merely shipped some products there. The drink-mix maker argued Delaware was the wrong place to be sued.
The question before the Court
Where can a company be sued for patent infringement — anywhere it can be sued at all, or only in the state where it was incorporated?
Why it matters
Companies accused of patent infringement will now face lawsuits mainly in their home state of incorporation, rather than in distant courts patent owners had chosen for strategic reasons. This is expected to shift patent litigation away from a few heavily favored courts and reduce forum-shopping by patent holders nationwide.
What changes now
The case returns to the lower courts for further proceedings consistent with this ruling, including resolving a separate factual dispute over whether the defendant company is actually incorporated or an unincorporated entity. More broadly, patent infringement suits nationwide will need to be filed in the defendant's state of incorporation or where it has committed infringement and has a regular business, ending the practice of filing almost anywhere a company merely sells products.
What this does not decide
The Court expressly did not decide how the venue rule applies to foreign corporations, and left open whether the defendant company here is actually incorporated or an unincorporated entity, leaving that factual question for the lower courts on remand.
How the Court got there
The legal reasoning, step by step
- The Court examined its 1957 decision in Fourco Glass Co. v. Transmirra Products Corp., which held that under the patent venue statute a domestic corporation 'resides' only in its state of incorporation, and found that ruling had never been overturned or amended by Congress.
- Because Congress had left the patent venue statute untouched since Fourco while separately amending the general venue statute, the Court asked whether those general-venue amendments quietly changed the meaning of the patent-specific statute — noting that Congress usually signals such a change clearly when it intends one.
- The Court compared the wording Congress used in the amended general venue statute ('for all venue purposes') to the wording in place when Fourco was decided ('for venue purposes') and found no meaningful difference between the two.
- The Court noted that the current general venue statute now contains an express exception for situations 'otherwise provided by law,' which if anything reinforces rather than undermines Fourco's holding that the patent venue statute stands on its own.
- The Court found no sign that Congress, in later amending the general venue law, meant to approve of a Federal Circuit ruling that had read the amendments as redefining patent venue, since the relevant statutory language Congress once relied on for that reading had since been deleted.
- Applying Fourco's undisturbed meaning, the Court concluded that a domestic corporation 'resides' only in its state of incorporation for purposes of the patent venue statute.
Doctrinal impact
Cases affected by this decision
Reaffirms Fourco Glass Co. v. Transmirra Products Corp. (353 U. S. 222)
The Court reaffirmed that a corporation resides only in its state of incorporation for patent-suit venue purposes.
Reaffirms Stonite Products Co. v. Melvin Lloyd Co. (315 U. S. 561)
The Court reaffirmed that the patent venue statute stands alone and isn't supplemented by general venue rules.