U.S. Supreme Court Unanimous Decision Limits Where Patent Infringement Suits Can Be Filed
The Supreme Court of the United States, in TC Heartland LLC v. Kraft Foods Group Brands LLC, decided 8-0 that in patent infringement cases, the patent holder can only sue where a corporate defendant resides, which the Court defined as the defendant's state of incorporation.
The Kraft Foods subsidiary of Kraft Heinz Co. sued TC Heartland, an Indiana-based maker of water flavoring packets, in Delaware, alleging infringement of three Kraft patents for water-enhancement products. TC Heartland argued that the case belonged in Indiana. The opinion, written by Justice Thomas, sided with TC Heartland, unanimously reversing the decision of the Federal Circuit below. The Court held that "residence" in the patent venue statute, 28 U.S.C. § 1400(b), refers only to the state of incorporation for domestic corporations.
The impact of this case is that it will eliminate forum-shopping by patent holders who often filed these cases in plaintiff-friendly districts in East Texas. Instead, these patent cases will likely now shift to Delaware and tech centers such as California and Massachusetts.
Justice Gorsuch did not participate in this case.