Samsung's Venue Shuffle Shut Down: Federal Circuit Keeps Patent Suit in Texas

The case originated in January 2024 when Mullen Industries LLC filed suit against Samsung, alleging that the tech giant infringed on nine patents related to geolocation and positioning technologies used in Samsung’s mobile devices, including smartphones, tablets, and wearable tech like the Galaxy Watch. These patents cover innovations tied to how a device determines and uses location data—a cornerstone of modern consumer electronics.

Samsung, as is common in such high-stakes intellectual property (IP) disputes, quickly sought to relocate the case to the Northern District of California, a jurisdiction closer to its U.S. operations and key witnesses. Samsung’s legal team argued that the California court would be a more convenient and appropriate forum, given that many of the relevant documents, employees, and engineers are located there.

However, the Eastern District of Texas—a long-standing hotbed for patent litigation—declined to grant the venue transfer. Samsung then escalated the matter to the Federal Circuit, claiming the district court abused its discretion in denying the motion.

But the Federal Circuit disagreed. In a 2-1 decision, the panel affirmed the Texas court's ruling, emphasizing that while California may be more convenient for Samsung, it did not outweigh the plaintiff’s right to choose a legally valid venue. The majority opinion also highlighted the fact that Samsung maintains a regular and established place of business in the Eastern District of Texas, which solidifies the legitimacy of Mullen’s choice of venue under current patent law.

This ruling reinforces a critical message: defendants in patent suits can't easily sidestep jurisdictions perceived as favorable to plaintiffs. For years, companies like Samsung and Apple have tried to shift cases away from Texas, citing convenience and neutrality, while plaintiffs strategically file there due to its speedy trials, experienced judges, and plaintiff-friendly juries.

The Federal Circuit’s decision is especially important in light of ongoing judicial efforts to curb forum shopping and standardize venue rules in patent litigation. While the Supreme Court’s 2017 TC Heartland decision narrowed venue options, this case shows that companies with meaningful operations in multiple districts may still be held to account wherever they do business.