Jack Henry & Associates, Inc.. v. Plano Encryption Technologies, LLC

PET, a Texas LLC registered to do business throughout Texas, has its registered address in Plano, which is in the Eastern District of Texas. The Banks all have their principal offices or branches or customers in the Northern District of Texas. PET's “sole business is to enforce its intellectual property.” PET’s CEO wrote to each of the Banks, identifying PET’s patents, stating that the Banks are believed to be infringing the patents, and inviting non-exclusive licenses. All the Banks conduct banking business in the Northern District of Texas. All the letters from PET referred to PET’s pending lawsuit against Citizens National Bank in the Eastern District. The Northern District of Texas dismissed the Banks’ declaratory judgment action, reasoning that PET’s contacts with the Northern District did not subject it to personal jurisdiction. The Federal Circuit reversed, finding that PET is subject to personal jurisdiction in the Northern District under 28 U.S.C. 1391: Venue in a multidistrict state. PET “purposefully directed” its charges of infringement to banks conducting banking business in the Northern District. The charges “arise out of or relate to” PET’s patent licensing activities in the Northern District. PET has met the minimum contacts requirement without offense to due process. View "Jack Henry & Associates, Inc.. v. Plano Encryption Technologies, LLC" on Justia Law