TC Heartland v. Kraft Foods Group Brands LLC

The residence of a domestic corporation under the patent infringement venue statute, 28 U. S. C. §1400(b), is the state in which the entity is incorporated.

Respondent filed a patent infringement claim against Petitioner in Delaware federal district court. Petitioner was organized pursuant to Indiana business law, where it also maintained its principal place of business. Petitioner’s motion to dismiss or transfer venue to the federal district in Indiana was denied by the district court; and Petitioner’s subsequent petition for writ of mandamus was denied by the Federal Circuit Court of Appeals. The Federal Circuit concluded that the general venue statute of 28 U. S. C. §1391(c) defined “resides” to expressly include all courts where the party is “subject to personal jurisdiction,” and thereby modified the patent venue statute, 28 U. S. C. §1400(b), to include the same personal jurisdiction interpretation. The United States Supreme Court reviewed §1400(b) and contrasted it with §1391(c) by noting the conflicting interpretations and historical language of the statutes. The Court recognized that Congress declined to amend §1400(b) to provide the personal jurisdiction provision found in §1391. The Court also found that the saving clause of §1391(c) that extends to “all venue purposes,” did not supersede the Court’s distinct interpretation of “resides” under §1400(b). Ultimately, the Court held that “resides,” under §1400(b), refers to the state of incorporation as it relates to patent infringement claim venue. REVERSED.