In re TC Heartland LLC
United States Court of Appeals for the Federal Circuit
821 F.3d 1338 (2016)
- Written by Eric Miller, JD
Facts
Kraft Foods Group Brands LLC (plaintiff) brought a patent-infringement action against TC Heartland LLC (Heartland) (defendant) in the United States District Court for the District of Delaware. Heartland moved to dismiss for lack of personal jurisdiction. Although Heartland had shipped hundreds of thousands of dollars’ worth of the allegedly infringing product to Delaware, Heartland argued that it had no business presence in the state. The argument was apparently based on two changes made to a provision of the venue statute—28 U.S.C. § 1391—in 2011. One changed the words “for the purposes of venue under this chapter” to “for all venue purposes.” The other added “except as otherwise provided by law,” which Heartland argued referred to federal common law. The court denied the motion to dismiss. Heartland then petitioned the United States Court of Appeals for the Federal Circuit for a writ of mandamus to direct the court to either dismiss or transfer the suit.
Rule of Law
Issue
Holding and Reasoning (Moore, J.)
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