CAFC Rules Improper Venue Does Not Bar Patent Ineligibility Dismissal
The Federal Circuit affirmed that a district court has the discretion to dismiss a patent infringement case for both improper venue and patent ineligibility, promoting judicial economy.
WISECODE Take
On August 28, 2026, the Federal Circuit in AML IP v. Bath & Body Works (No. 2025-1280) confirmed that district courts may dismiss a case for patent ineligibility even after finding venue improper. This dispels the misconception that improper venue shields a patent from merits review. In this case, Judge Sean D. Jordan dismissed the suit involving U.S. Patent No. 6,876,979 on both procedural and substantive grounds, which the CAFC affirmed as a proper exercise of docket management. For Taiwanese companies, this means a dual-track defense can efficiently eliminate weak patents. We recommend that defendants raise both venue and Section 101 challenges concurrently, while R&D teams should avoid filing abstract business method patents.
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