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  • Federal Circuit Affirms District Court’s Decision To Reach A Patent-Eligibility Issue After Concluding Venue Improper
    09/15/2026
    On August 28, 2026, the U.S. Court of Appeals for the Federal Circuit (Judges Prost, Bryson, and Reyna) affirmed a district court’s dismissal of AML’s patent-infringement claims against Bath & Body Works Direct, Inc. and The Buckle, Inc. on two independent grounds: improper venue and patent ineligibility under 35 U.S.C. § 101.  The Federal Circuit held that the district court did not abuse its discretion by reaching the patent-eligibility issue after concluding that venue was improper.  AML IP, LLC v. Bath & Body Works Direct, Inc., No. 2025-1280 (Fed. Cir. Aug. 28, 2026).  The decision addresses what a district court may do after determining that venue is improper, and confirms that a court presented with concurrent Rule 12(b)(3) and Rule 12(b)(6) grounds may resolve both.