In this past year the U.S. Supreme Court decided TC Heartland LLC v. Kraft Foods Grp. Brands LLC and made a major change in the prevailing practice in federal courts regarding proper venue in patent infringement cases. By way of background, venue in federal civil cases generally is controlled by the federal venue statute, 28 U.S.C. § 1391, while venue in patent infringement cases is governed by the patent venue statute, 28 U.S.C. § 1400(b).