News & Analysis as of

Motion to Dismiss Patent Litigation Venue

Patterson Belknap Webb & Tyler LLP

Not a Repeat Offender: Magistrate Judge Bloom Declines to Sanction “Ernest” Pro Se Plaintiff for Re-filing Dismissed Case in a...

On April 4, 2025, Magistrate Judge Lois Bloom (E.D.N.Y.) declined to sanction a pro se plaintiff for failing to conduct an adequate pre-suit investigation of whether his patent was infringed. Plaintiff initially filed a...more

Baker Botts L.L.P.

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

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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

Bond Schoeneck & King PLLC

Will EDTX Sanctions Decision Deter Improper Venue Allegations in Patent Lawsuits?

Following the Supreme Court’s TC Heartland decision in 2017, a patent owner may only sue an alleged infringer in either: (1) a judicial district of the state where the defendant is incorporated; or (2) a judicial district...more

McDermott Will & Emery

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

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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

Haug Partners LLP

The Federal Circuit Analyzes Venue Requirements in Hatch-Waxman Cases

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Since the Supreme Court’s decision in TC Heartland (137 S. Ct. 1514 (2017)), the venue statute for patent cases, 28 U.S.C. § 1400(b), has been interpreted to mean that venue is proper only where the defendant “resides” or...more

McDonnell Boehnen Hulbert & Berghoff LLP

Celgene Corp. v. Mylan Pharmaceuticals Inc. (Fed. Cir. 2021)

The question of the proper court for a branded pharmaceutical maker to bring suit against an Abbreviated New Drug Application filer under the Hatch-Waxman Act is surprisingly unsettled seeing as the Act was enacted in 1984. ...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

McDonnell Boehnen Hulbert & Berghoff LLP

Valeant Pharmaceuticals North America LLC v. Mylan Pharmaceuticals Inc. (Fed. Cir. 2020)

Somewhat remarkably, there is no settled Federal Circuit precedent regarding where a patentee can bring suit against a generic competitor in Hatch-Waxman litigation under 35 U.S.C. § 271(e)(2).  While recognizing that this...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

McDermott Will & Emery

Still Open for Discussion: Venue Based on Presence of Servers

McDermott Will & Emery on

The US Court of Appeals for the Federal Circuit elected not to decide en banc whether servers or similar equipment in third-party facilities constitute a regular and established place of business under the patent venue...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

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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

Fenwick & West LLP

Under Patent Venue Statute, Servers Housed in Texas District Count as Regular and Established Place of Business

Fenwick & West LLP on

The District Court for the Eastern District of Texas has denied Google’s motion to dismiss or transfer the patent infringement case SEVEN Networks v. Google for improper venue, finding that Google’s servers housed by...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

Akin Gump Strauss Hauer & Feld LLP

Corporate Defendant in Patent Infringement Suit Does Not Necessarily Reside in All of the Judicial Districts in a State with...

The Federal Circuit ruled that when a defendant is incorporated in a state that has multiple judicial districts, the defendant will reside in only one of the districts for venue purposes under the patent venue statute, 28...more

Mintz - Intellectual Property Viewpoints

Federal Circuit Holds Federal Circuit Law Applies to Patent Venue Challenges and Places Burden on Plaintiffs to Establish Venue

On May 14, 2018, the United States Court of Appeals for the Federal Circuit, In re: ZTE (USA) Inc., No. 2018-113, held that Federal circuit law governs the burden of proof for venue challenges under 28 U.S.C. § 1400(b) and...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

Knobbe Martens

In Re ZTE (USA) Inc.

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Federal Circuit Summaries - Before Reyna, Linn, and Hughes. On Petition for Writ of Mandamus to the Eastern District of Texas. Summary: Under Federal Circuit law, the plaintiff bears the burden of showing that venue is...more

Akin Gump Strauss Hauer & Feld LLP

District Court Holds That Distributor Relationships Alone Do Not Establish Venue

A federal district court in the Southern District of Texas recently addressed venue issues relating to supplier-distributor relationships. Given the defendant’s lack of physical presence in the district, Chief Judge Lee...more

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