Unreported / Non-Citable
Background
Cactus Wellhead, LLC filed a patent infringement action against Cameron International Corporation in the Eastern District of Texas, alleging that Cameron’s Automated Valve Greasing System infringes U.S. Patent No. 11,137,109. The patent relates to systems for greasing valves in fracking and well applications. Cameron operates the accused systems in both the Haynesville and Eagle Ford shale basins in Texas.
Cameron filed a motion to transfer the case to the Southern District of Texas, arguing that the Southern District would be a proper venue. Cameron contended that it maintains a principal place of business in Houston and uses the accused systems in the Eagle Ford and Haynesville basins, portions of which lie outside the Eastern District. The court had to determine whether the Southern District of Texas would have been a proper venue if the case had been initially filed there.
The Court’s Holding
The court denied Cameron’s motion to transfer venue, finding that Cameron failed to satisfy the threshold statutory requirement for proper venue in the Southern District of Texas. The court held that 28 U.S.C. § 1400(b)—not the general venue statute—is the sole and exclusive provision controlling venue in patent infringement actions. Under § 1400(b), venue lies where the defendant resides or where the defendant has committed acts of infringement and maintains a regular and established place of business.
The court found that Cameron, as a Delaware corporation, resides solely in Delaware for patent venue purposes under the Supreme Court’s TC Heartland decision. The court rejected Cameron’s argument that it could rely on personal jurisdiction under the general venue statute (28 U.S.C. § 1391(c)(2)), emphasizing that this general statute does not apply to patent cases. Additionally, Cameron failed to meet its burden of demonstrating that the alleged acts of infringement occurred in the Southern District of Texas. While Cameron has a Houston office and may use systems in the Eagle Ford basin, Cameron identified no specific locations in the Southern District where the accused systems were used. The court noted that general vicinity and regional references are insufficient—specific acts of infringement must be established.
Key Takeaways
- A domestic corporation “resides” only in its state of incorporation for patent venue purposes, regardless of where it maintains offices or conducts business operations.
- Patent venue is exclusively governed by 28 U.S.C. § 1400(b); general venue statutes do not supplement or modify patent venue requirements.
- The defendant moving for a transfer bears the burden of proving that the proposed district would have been a proper venue if the case had been filed there initially.
- Vague references to regional activity or general place of business are insufficient; defendants must identify specific acts of infringement in the proposed district.
Why It Matters
This decision reinforces the strict application of venue requirements in patent litigation following TC Heartland LLC v. Kraft Foods Group Brands LLC. By denying transfer based on Cameron’s failure to meet the statutory threshold, the court demonstrates that venue rules in patent cases will be applied rigorously and defendants cannot circumvent them through general jurisdiction arguments. This is particularly significant for patent litigants operating across multiple districts, as it confirms that the location of a corporation’s headquarters or regional operations does not establish patent venue.
The ruling also underscores the Eastern District of Texas’s role as a forum for patent cases filed within its jurisdiction, particularly in the Marshall Division, which has become prominent in patent litigation. Defendants seeking to transfer patent cases out of this district must meet exacting standards with specific, particularized evidence of infringement locations rather than general business operations. This decision will likely guide future venue disputes in patent cases involving multi-district business operations, especially in oil and gas and other industries with geographically dispersed manufacturing or use locations.