AML IP, LLC v. Bath & Body Works Direct, Inc.

AML IP, LLC v. Bath & Body Works Direct, Inc. The Federal Circuit affirmed, holding that the district court did not abuse its discretion by deciding both improper venue and § 101 eligibility grounds in the same dismissal order. The court also declined to opine on the preclusive effect of the § 101 ruling in future litigation. A district court may, at least in these circumstances, dismiss on a Rule 12(b)(6) patent-eligibility ground even after concluding that patent venue is improper, where both issues were fully briefed and no transfer destination was identified. Affirmed. AML sued on the ’979 patent, directed to e-commerce methods involving a bridge computer facilitating interactions among service providers. The district court first held venue improper under § 1400(b), then separately held the asserted claims patent-ineligible under § 101 and dismissed on both grounds. Applying Fifth Circuit abuse-of-discretion review to docket management, the Federal Circuit distinguished venue from subject-matter jurisdiction: improper venue is waivable and does not deprive a court of power to act. The court rejected AML’s reliance on cases prioritizing venue motions, reasoning that the district court did give venue priority and that judicial economy can favor deciding concurrently raised Rule 12(b)(3) and Rule 12(b)(6) grounds together. The Federal Circuit refused AML’s request for a statement that the § 101 dismissal lacks preclusive effect, treating that issue as advisory until raised in a later case. § 101 standing / jurisdiction claim preclusion precedential § 101 standing / jurisdiction claim preclusion precedential § 101 standing / jurisdiction claim preclusion