TC Heartland LLC v. Kraft Foods Group Brands LLC

The patent venue statute, 28 U.S.C. § 1400(b), limited proper venue in a patent-infringement case filed against a domestic corporation to the place where the corporation resided, which was its state of incorporation. Congress never amended the patent venue statute, but in 1988 Congress amended the general venue statute, 28 U.S.C. § 1391(c). The amendment added that “for purposes of venue under this chapter” a corporate defendant resided in any jurisdiction where the court had personal jurisdiction over the corporation. In 1991 the Federal Circuit found that because the patent venue statute and general venue statute were part of the same chapter, the amended general venue provisions extended to corporate defendants in patent-infringement actions. Congress again amended the general venue statute in 2011 by removing “for purposes of venue under this chapter” and replacing it with “for all venue purposes.” The 2011 amendment also established that the general venue statute provided default venue rules “except as otherwise provided by law. Nothing in the 2011 amendment suggested Congress intended for the amended general venue statute to alter the meaning of the patent venue statute. TC Heartland LLC (Heartland) (defendant) produced drink mixes and was incorporated and headquartered in Indiana. Kraft Foods Group Brands, Inc. (Kraft) (plaintiff) was incorporated in Delaware and sold products in competition with Heartland. Kraft sued Heartland for patent infringement in the United States District Court for the District of Delaware. Heartland moved to dismiss or transfer the claim, arguing Delaware was an improper venue. The district court denied the motion. Heartland petitioned for a writ of mandamus. The United States Court of Appeals for the Federal Circuit denied the petition. Heartland petitioned the United States Supreme Court for a writ of certiorari, which was granted.