TC Heartland LLC v. Kraft Foods Grp. Brands LLC
Supreme Court of the United States
March 27, 2017, Argued; May 22, 2017, Decided
Justice Thomas delivered the opinion of the Court.
The question presented in this case is where proper venue lies for a patent infringement lawsuit brought against a domestic corporation. The patent venue statute, 28 U. S. C. §1400(b), provides that “[a]ny civil action for patent infringement may be brought in the judicial district where [***6] the defendant resides, or where the defendant has committed acts of infringement and has a regular and established place of business.” In [*1517] Fourco Glass Co. v. Transmirra Products Corp., 353 U. S. 222, 226, 77 S. Ct. 787, 1 L. Ed. 2d 786 (1957), this Court concluded that for purposes of §1400(b) a domestic corporation “resides” only in its State of incorporation.
In reaching that conclusion, the Court rejected the argument that §1400(b) incorporates the broader definition of corporate “residence” contained in the general venue statute, 28 U. S. C. §1391(c). 353 U. S., at 228, 77 S. Ct. 787, 1 L. Ed. 2d 786. Congress has not amended §1400(b) since this Court construed it in Fourco, but it has amended §1391 twice. Section 1391 now provides that, “[e]xcept as otherwise provided by law” and “[f]or all venue purposes,” a corporation “shall be deemed to reside, if a defendant, in any judicial district in which such defendant is subject to the court’s personal jurisdiction with respect to the civil action in question.” §§1391(a), (c). The issue in this case is whether that definition supplants the definition announced in Fourco and allows a plaintiff to bring a patent infringement lawsuit against a corporation in any district in which the corporation is subject to personal jurisdiction. We conclude that the amendments to §1391 did not modify the meaning of §1400(b) as interpreted by Fourco. We therefore hold that a domestic corporation “resides” [***7] only in its State of incorporation for purposes of the patent venue statute.
Petitioner, which is organized under Indiana law and headquartered in Indiana, manufactures flavored drink mixes. Respondent, which is organized under Delaware law and has its principal place of business in Illinois, [**821] is a competitor in the same market. As relevant here, respondent sued petitioner in the District Court for the District of Delaware, alleging that petitioner’s products infringed one of respondent’s patents. Although petitioner is not registered to conduct business in Delaware and has no meaningful local presence there, it does ship the allegedly infringing products into the State.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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137 S. Ct. 1514 *; 197 L. Ed. 2d 816 **; 2017 U.S. LEXIS 3213 ***; 122 U.S.P.Q.2D (BNA) 1553 ****; 85 U.S.L.W. 4249; 26 Fla. L. Weekly Fed. S 575; 2017 WL 2216934
TC HEARTLAND LLC, Petitioner v. KRAFT FOODS GROUP BRANDS LLC
Notice: The LEXIS pagination of this document is subject to change pending release of the final published version.
Prior History: [***1] ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FEDERAL CIRCUIT
In re TC Heartland LLC, 821 F.3d 1338, 2016 U.S. App. LEXIS 7753 (Fed. Cir., Apr. 29, 2016)
Disposition: Reversed and remanded.
venue, resides, venue statute, patent, patent infringement, inhabitant, venue purposes, incorporation, cases, judicial district, domestic corporation, civil action, purposes, personal jurisdiction, place of business, current version, district court, saving clause, infringement
Patent Law, Jurisdiction & Review, Personal Jurisdiction & Venue, Places of Business & Residence, Governments, Legislation, Interpretation, Civil Procedure, Preliminary Considerations, Venue, General Overview