Commonwealth Scientific and Industrial Research Organisation v. MediaTek Inc. et. al., 6-12-cv-00578 (TXED September 12, 2013, Order) (Davis, J.).
Monday, September 16, 2013
In Determining Venue and Personal Jurisdiction, Defendant “Cannot Target the U.S. Wireless Market Without Targeting the Eastern District of Texas."
The court denied a Taiwanese defendant's motion to dismiss plaintiff's infringement action for improper venue. "The question of personal jurisdiction in the context of venue is limited to the judicial district where the suit was brought. Therefore, a plaintiff must demonstrate that the defendant has sufficient minimum contacts with the district where the suit was brought to show venue was proper. . . . [Plaintiff] has demonstrated that [defendant] placed its products into the stream of commerce with knowledge and intent that they would be sold in the Eastern District of Texas. [Defendant] describes itself as 'one of the world’s leading IC providers.'. . . Within the United States, Texas is the second most populous state. The Eastern District of Texas includes two of the ten most populated counties in Texas and several counties within the Eastern District form portions of two of the ten largest metropolitan areas in the United States. Thus, [defendant] cannot target the U.S. wireless market without targeting the Eastern District of Texas."