Venue in federal cases is controlled by the general venue statute unless there exists an applicable special venue statute that attaches to the particular cause of action under consideration. This note is concerned with the section of the general venue statute applicable to corporate defendants and its interaction with the special venue statute for civil actions in patent infringement cases ("patent venue statute"). As a first step in the discussion of venue, it is necessary to go back in history over 200 years. This note reviews the history of venue, both generally and in cases of patent infringement, the historical interactions of these venue statutes, the 1988 amendment to the general venue statute, the interpretation of this amendment by the Federal Circuit, and finally the effects these changes may have in future actions for patent infringement.
Note, The 1988 Revision of 28 U.S.C. 1391(C): Corporate Venue Is Now Equivalent to In Personam Jurisdiction Effects on Civil Actions for Patent Infringement, 39 Clev. St. L. Rev. 357 (1991)