Summary
The Supreme Court held that, for purposes of the patent venue statute, a domestic corporation resides only in its State of incorporation. The Court concluded that subsequent amendments to the general venue statute, 28 U.S.C. § 1391, did not alter the meaning of 28 U.S.C. § 1400(b) as established in Fourco Glass Co. v. Transmirra Products Corp. The judgment of the Federal Circuit was reversed and the case was remanded.
Topics
Practice areas
Questions Presented
- Whether the term "resides" in the patent venue statute, 28 U.S.C. § 1400(b), refers only to the State of incorporation for a domestic corporation.
- Whether Congress's amendments to the general venue statute, 28 U.S.C. § 1391, displaced the meaning of "resides" established in Fourco Glass Co. v. Transmirra Products Corp.
Holdings
- As applied to domestic corporations, "resides" in 28 U.S.C. § 1400(b) refers only to the State of incorporation.
- The amendments to § 1391 did not modify the meaning of § 1400(b) as interpreted by Fourco.
Key quotations
“When Congress intends to effect a change of that kind, it ordinarily provides a relatively clear indication of its intent in the text of the amended provision.” (581 U.S. 258, 268)
“As applied to domestic corporations, “reside[nce]” in §1400(b) refers only to the State of incorporation.” (581 U.S. 258, 273)
Factual background
TC Heartland was organized under Indiana law and headquartered in Indiana, while Kraft Foods was organized under Delaware law and had its principal place of business in Illinois. Kraft Foods sued TC Heartland for patent infringement in Delaware. TC Heartland was not registered to conduct business in Delaware and had no meaningful local presence there, although it shipped allegedly infringing products into the State. The case was litigated at the pleading stage on the understanding that TC Heartland was a corporation.
Procedural history
Kraft Foods sued TC Heartland for patent infringement in the District of Delaware. TC Heartland moved to dismiss or transfer the case to the Southern District of Indiana, arguing that it did not reside in Delaware and lacked a regular and established place of business there. The District Court rejected the arguments, and the Federal Circuit denied mandamus, concluding that 28 U.S.C. § 1391(c) supplied the definition of residence in 28 U.S.C. § 1400(b). The Supreme Court granted certiorari, reversed, and remanded.
Remand instructions
Remand for further proceedings consistent with the opinion, including consideration by the lower courts of petitioner's legal status and the remaining requirements of § 1400(b).