Since the US Supreme Court issued its May 2017 decision in TC Heartland, holding that a corporate defendant “resides” for venue purposes only in its state of incorporation, patent litigation has dispersed from its prior epicenter in the Eastern District of Texas. While some defendants have since successfully challenged venue in that district on corporate residence grounds (the first prong of the patent venue statute, 35 USC Section 1400(b)), others have had to litigate the second prong of the statute not addressed in TC Heartland, under which suits can be brought where a defendant “has committed acts of infringement and has a regular and established place of business”. One such defendant is Google, which contested venue based on that second prong in litigation brought by Seven Networks LLC, an affiliate of Fortress Investment Group LLC. On October 29, a split Federal Circuit declined on mandamus to overturn District Judge Rodney Gilstrap’s July denial of that motion.