In May, roughly two weeks before the US Supreme Court issued its TC Heartland decision on proper venue in patent cases, individual inventor Uri Cohen sued Apple, Huawei, and TSMC in a single Eastern District of Texas case alleging infringement of four semiconductor fabrication patents. This past week Cohen filed an amended complaint that dropped Apple and the US subsidiary of TSMC (both without prejudice) from the suit. The same day, Applied Materials (3:17-cv-04990) and TSMC (5:17-cv-05001) filed separate actions in the Northern District of California, each seeking declaratory judgment of non-infringement of the four patents that Cohen asserted in Texas. The complaints note that Cohen’s infringement allegations target TSMC’s use of the Applied Materials Endura Volta system to form certain metal interconnects in chips purportedly incorporated into smartphones sold by Apple and Huawei (and others). TSMC’s complaint announces its intention to file a motion to dismiss for improper venue in Texas.