By Sue Robinson (December 12, 2017, 12:44 PM EST) -- Much has been written about venue since the U.S. Supreme Court in TC Heartland LLC v. Kraft Foods Group Brands LLC[1] reversed the Federal Circuit's holding in VE Holding Corp. v. Johnson Gas Appliance Co.[2] In its TC Heartland decision, the Supreme Court related the history of the relevant venue statutes, going back to the first general venue statute enacted in the Judiciary Act of 1789[3] and the amendment to that statute in 1887 that limited suit to only that district "of which the defendant was an inhabitant or, in diversity cases, of which either the plaintiff or defendant was an inhabitant."[4] Because a subsequent opinion of the Supreme Court[5] created some confusion as to whether the Act of 1887 applied to patent cases, the first patent-specific venue statute was enacted by Congress in 1897.[6] In its historical recitation, the Supreme Court in TC Heartland refers to its decision in Stonite Products Co. v. Melvin Lloyd Co.[7] for the relatively straightforward proposition that "the patent venue statute constituted 'the exclusive provision controlling venue in patent infringement proceedings' and thus was not supplemented or modified by the general venue provisions."[8] The Supreme Court concluded that the first prong of § 1400(b), "[a]s applied to domestic corporations," limits "residen[nce]" "to the State of incorporation."[9]...