The US Supreme Court’s TC Heartland decision on proper venue in patent cases has prompted new filings in multiple litigation campaigns, including in the group voice messaging campaign of Uniloc USA, Inc. and Uniloc Luxembourg S.A. (Uniloc). In March, before TC Heartland, Uniloc filed three complaints in the Eastern District of Texas against different Google products: Google Hangouts (alleging infringement of 7,535,890; 8,199,747; 8,724,622; 8,995,433); the Android Messages app (alleging infringement of the ‘890, ‘622, and ‘433 patents); and the Allo messaging app (also alleging infringement of the ‘890, ‘622, and ‘433 patents). Just over a week after TC Heartland, Uniloc has responded, at least with respect to its cases against Alphabet (Google) in this campaign, by filing amended complaints in each of those March cases that both drop the ‘890 and ‘433 patents and add lengthy allegations in support of Uniloc’s contention that venue remains proper in the Eastern District. On the same day, Uniloc also filed new, original complaints against Google, asserting the ‘890 and ‘433 patents against Hangouts (2:17-cv-00465), the Android Messages app (2:17-cv-00467), and the Allo messaging app (2:17-cv-00466), again with much more detailed venue allegations.