Next week marks the one-year anniversary of the U.S. Supreme Court’s TC Heartland v. Kraft Foods Group Brands decision on venue in patent infringement cases, and the U.S. Court of Appeals for the Federal Circuit has been working overtime to further flesh out the rules.

Although Chief Judge Sharon Prost warned last week that the court would prefer to decide venue issues after trial, the court’s motions panel issued two precedential decisions granting mandamus petitions. In re ZTE, decided Monday, held that plaintiffs bear the burden of establishing that venue is proper. In In re BigCommerce, the court said companies may be sued only in the judicial district in which they’re incorporated, not any judicial district within the state.

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