TC Heartland LLC v. Kraft Foods Group Brands LLC

Kraft Foods Group Brands LLC sued TC Heartland LLC for patent infringement in the United States District Court for the District of Delaware. TC Heartland, an Indiana-based company, moved to dismiss or transfer the case for improper venue, arguing that it did not reside in Delaware under the patent venue statute, 28 U.S.C. § 1400(b). The district court and the Federal Circuit denied the motion, relying on precedent that a domestic corporation resides anywhere it is subject to personal jurisdiction. The Supreme Court granted certiorari to clarify the meaning of residence in patent cases. In a unanimous decision authored by Justice Clarence Thomas, the Court reversed, holding that a domestic corporation resides only in its state of incorporation for purposes of § 1400(b), thereby restricting where patent lawsuits may be filed against corporate defendants.

The Supreme Court reversed the Federal Circuit, ruling unanimously that under 28 U.S.C. § 1400(b) a domestic corporation resides only in its state of incorporation. The broader interpretation allowing venue in any district with personal jurisdiction was rejected.

Whether, for purposes of the patent venue statute 28 U.S.C. § 1400(b), a domestic corporation "resides" only in its state of incorporation, or in every judicial district where it is subject to personal jurisdiction.

The decision dramatically reshaped patent litigation in the United States. It curtailed the widespread practice of forum shopping, particularly in the patent-friendly Eastern District of Texas, and led to a significant redistribution of patent cases to districts where corporate defendants are incorporated, such as Delaware. The ruling also prompted legislative discussions about further venue reform.