TC Heartland LLC v. Kraft Foods Group Brands LLC
137 S. Ct. 1514
| SCOTUS | 2017Background
- TC Heartland (petitioner) is organized under Indiana law and shipped accused products into Delaware; Kraft Foods (respondent) is a Delaware corporation that sued in D. Del. for patent infringement.
- TC Heartland moved to dismiss or transfer for improper venue under 28 U.S.C. §1406, arguing it did not “reside” in Delaware and had no regular and established place of business there.
- The District Court denied the motion; the Federal Circuit denied mandamus, holding that the general venue statute §1391(c) now defines “resides” for §1400(b), so a corporation resides where it is subject to personal jurisdiction.
- The Supreme Court granted certiorari to decide whether amendments to §1391 altered the meaning of “resides” in the patent venue statute §1400(b).
- The Court reaffirmed Fourco: for domestic corporations, “resides” in §1400(b) means the state of incorporation; amendments to §1391 did not change that meaning.
Issues
| Issue | Plaintiff's Argument (Kraft) | Defendant's Argument (TC Heartland) | Held |
|---|---|---|---|
| Does §1391(c)’s post‑1948 amendments redefine “resides” in the patent venue statute §1400(b)? | §1391(c) now defines residence “for all venue purposes,” so §1400(b) includes any district where defendant is subject to personal jurisdiction. | Fourco controls: §1400(b) is a standalone patent‑venue provision; “resides” means state of incorporation for domestic corporations. | Held for TC Heartland: Fourco remains binding; §1400(b) means state of incorporation; §1391 did not modify §1400(b). |
| Does the 2011 wording and the saving clause in §1391 change or ratify the Federal Circuit’s VE Holding approach? | The phrase “for all venue purposes” and prior amendments show Congress intended §1391 to govern all venue statutes, ratifying VE Holding. | The 2011 revisions actually restore the original phrasing and add an ‘‘except as otherwise provided by law’’ saving clause, undermining VE Holding and preserving §1400(b)’s independence. | Held for TC Heartland: the 2011 text does not ratify VE Holding; the saving clause reinforces that §1391 does not override specific venue statutes like §1400(b). |
Key Cases Cited
- Fourco Glass Co. v. Transmirra Prods. Corp., 353 U.S. 222 (1957) (holding §1400(b) is the exclusive patent‑venue provision and domestic corporation “resides” only in state of incorporation)
- Stonite Prods. Co. v. Melvin Lloyd Co., 315 U.S. 561 (1942) (patent venue statute is exclusive and not to be supplemented by general venue rules)
- VE Holding Corp. v. Johnson Gas Appliance Co., 917 F.2d 1574 (Fed. Cir. 1990) (Federal Circuit holding that §1391(c) redefined venue for §1400(b))
- Pure Oil Co. v. Suarez, 384 U.S. 202 (1966) (construing "for venue purposes" as covering venue statutes)
- Brunette Machine Works, Ltd. v. Kockum Indus., Inc., 406 U.S. 706 (1972) (addressing venue for foreign corporations under earlier statutes)
- United States v. Madigan, 300 U.S. 500 (1937) (principle that an amendment should clearly indicate intent to modify settled construction)