Federal Circuit Says Improper Venue Does Not Bar Ruling on Patent Eligibility

Federal Circuit affirmed Eastern District of Texas dismissal of AML IP, LLC's patent suit against Bath & Body Works and The Buckle on both improper venue and patent ineligibility grounds. AML sued over U.S. Patent No. 6,876,979 covering e-commerce methods. Court rejected AML's argument that district court should not have reached patent eligibility after finding improper venue, distinguishing venue from subject matter jurisdiction and citing judicial economy considerations favoring dual dismissal analysis.