News & Analysis as of

Motion to Dismiss Patent Litigation Improper Venue

Baker Botts L.L.P.

Use of Amazon Warehouses for Distribution Alone Won't Establish Patent Venue, Court Rules

Baker Botts L.L.P. on

Key Takeaway: Just as over a million businesses use Amazon web servers, many independent sellers also use Amazon warehouses to store their inventory. More than 60% of sales in the Amazon store come from independent sellers,...more

McDermott Will & Emery

Dude, Where’s My Venue? Texas Car Dealerships Aren’t Distributor Agents

McDermott Will & Emery on

The US Court of Appeals for the Federal Circuit vacated a district court’s denial of motions made by two car distributors to transfer cases out of the Western District of Texas for improper venue, finding that the patent...more

Patterson Belknap Webb & Tyler LLP

You Don’t Belong Here – Judge Ramos Grants Defendants’ Motion to Dismiss for Lack of Personal Jurisdiction and Improper Venue

On September 28, 2021, United States District Judge Edgardo Ramos (S.D.N.Y.) granted Defendant JLC Tech LLC’s (“JLC”) motion to dismiss for lack of personal jurisdiction and improper venue. Judge Ramos also denied Plaintiff...more

Schwabe, Williamson & Wyatt PC

‎Latest Federal Court Cases - August 2021 #2

Our Case of the Week this week is a re-write of our Case of the Week on October 5, 2020. The case involves a drug that could be used for multiple therapeutic purposes. A patent covered use of the product for a specific...more

Morrison & Foerster LLP - Federal Circuitry

Last Week in the Federal Circuit (August 2-6): No Secret For Obtaining Venue

The Federal Circuit wrapped up another (perhaps final) week of telephone arguments last week. As of now, the Court is still set to restart in-person arguments next month. But we’ll have to see if those plans change. Below we...more

Patterson Belknap Webb & Tyler LLP

Lights Out: Judge Carter Grants Motion to Dismiss For Improper Venue

On September 30, 2019—more than two years after Plaintiff, Electric Mirror, LLC (“Electric Mirror”) first brought suit for patent infringement in the Southern District of New York—United States District Judge Andrew L. Carter...more

Fish & Richardson

California Court Confirms that Venue Does Not Require a Nexus Between an “Act of Infringement” and a “Regular and Established...

Fish & Richardson on

In Genentech, Inc. v. Eli Lilly and Co., 18-cv-1518 JLS (JLB) (S.D. Cal.), the California district court denied Lilly’s motion to dismiss for improper venue under the patent venue statute, 28 U.S.C. § 1400(b). Opinion, Sept....more

Knobbe Martens

Parroting Language of Venue Statute Is Not Enough to Avoid Dismissal

Knobbe Martens on

WESTECH AEROSOL CORPORATION v. 3M COMPANY - Before Lourie, Mayer, and Reyna. Appeal from the United States District Court for the Western District of Washington. Summary: To establish proper venue, a plaintiff must...more

Fox Rothschild LLP

Judge Andrews Affirms His Prior Decision To Dismiss Patent Infringement Action Against Washington Corporation For Improper Venue

Fox Rothschild LLP on

By Memorandum Order entered by The Honorable Richard G. Andrews in T-JAT Systems 2006 LTD. v. Expedia, Inc. (DE) et al., Civil Action No. 16-581-RGA (D.Del. January 29, 2019), the Court denied Plaintiff’s motion for...more

Patterson Belknap Webb & Tyler LLP

Judge Oetken Sua Sponte Transfers Action to California Upon Holding that Pendent Venue Cannot Be Exercised Over a Patent...

On January 2, 2019, District Judge Paul Oetken (S.D.N.Y.) transferred to the U.S. District Court for the Central District of California ("CDCA") an action brought by Plaintiff NextEngine, Inc. against Defendants NextEngine,...more

Schwabe, Williamson & Wyatt PC

Latest Federal Circuit Court Cases - November 2018 #3

ArcelorMittal Atlantique Et Lorraine v. AK Steel Corporation, Appeal No. 2017-1637 (Fed. Cir. Nov. 14, 2018) - In an opinion originally filed as sealed on Nov. 5 and unsealed on Nov. 18, the Federal Circuit vacated and...more

Knobbe Martens

In Re Oath Holdings Inc.

Knobbe Martens on

Federal Circuit Summary - Before Dyk, Reyna, and Taranto, per curiam. Petition for Writ of Mandamus from the District Court for the Eastern District of New York. Summary: In a case pending before TC Heartland was...more

Mintz - Intellectual Property Viewpoints

Franchised Automobile Dealerships Count as Regular and Established Places of Business for Purposes of Proper Patent Infringement...

In our continuing post-TC Heartland coverage, Judge Rodney Gilstrap of the Eastern District of Texas recently issued an interesting decision regarding the venue analysis for car companies selling into a particular...more

Hogan Lovells

US: Authorized automobile dealerships drive discussion on patent venue in the Eastern District of Texas

Hogan Lovells on

In May 2017, the Supreme Court tightened the rule for venue over domestic defendants in patent infringement cases finding that, under 28 U.S.C. § 1400(b), venue is proper only “in the judicial district where the defendant...more

Knobbe Martens

Federal Circuit Review - June 2018

Knobbe Martens on

A Complaint Identifying Infringing Products and the Patents Allegedly Infringed, Accompanied by Statements that the Products Meet All Elements of at Least One Claim of the Asserted Patents, May be Sufficient to Meet the...more

Fish & Richardson

Federal Circuit Holds That Plaintiff Bears the Burden of Proving Venue in Patent Cases

Fish & Richardson on

In an order issued May 14, 2018, the Court of Appeals for the Federal Circuit vacated a District Court order that denied a motion to dismiss for improper venue. The Court held that, in challenges to venue under 28 U.S.C. §...more

Fish & Richardson

EDTX & NDTX Monthly Wrap-Up — March 2018

Fish & Richardson on

This post is another entry in our monthly survey of substantive orders in the Eastern and Northern Districts of Texas. This month, there were several decisions in two areas of interest: (1) awards of attorneys’ fees, and (2)...more

Fish & Richardson

Minnesota Patent Litigation Wrap-Up – February 2018

Fish & Richardson on

This post continues our monthly summary of patent litigation in the District of Minnesota, including short summaries of various substantive orders issued in pending cases. Cutsforth, Inc. v. LEMM Liquidating Co., No....more

Mintz - Intellectual Property Viewpoints

Lower Courts Continue to Grapple with Venue in the Wake of In re Micron and In re Cray

Further to our ongoing coverage of the post-TC Heartland patent litigation landscape, a pair of recent and interesting cases from Texas and Delaware further evolved this important venue-related jurisprudence....more

Patterson Belknap Webb & Tyler LLP

Judge Broderick Finds That TC Heartland Affected a “Sea Change” and Grants Motion to Dismiss For Improper Venue

On October 20, 2017, District Judge Vernon Broderick (S.D.N.Y.) granted Defendants' Watters Design, Inc.'s, Essense of Australia, Inc.'s, and David's Bridal, Inc.'s motions to dismiss under Federal Rule of Civil Procedure...more

Proskauer - New England IP Blog

Planned Motion to Dismiss Insufficient to Extend Rule 26(f) Deadlines

In an ongoing patent infringement case involving patents for floor-mounted electrical outlet housings, a federal court in Connecticut recently denied a Joint Motion for a Discovery Dispute Conference, signaling the court’s...more

Womble Bond Dickinson

Comprehensive Ruling on Personal Jurisdiction and Transfer Issues Offers Cautions and Gems for In-house Counsel and Trial Lawyers

Womble Bond Dickinson on

In a 46-page order, Judge Timothy Batten denied a motion to dismiss under FRCP 12(b)(2) and (3) for lack of personal jurisdiction and improper venue, or in the alternative to transfer venue brought by OMsignal, Inc....more

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