Anuwave LLC v. Assoc. Banc-Corp. d/b/a Assoc. Bank, N.A., No. 16 C 9925, Slip Op. (N.D. Ill. Oct. 26, 2016) (Shadur, Sen. J.).
Judge Shadur sua sponte dismissed plaintiff Anuwave’s patent complaint for improper venue with leave to refile in defendant Associated Bank’s “home territory (which it shares with the Green Bay Packers, not the Chicago Bears).”
Citing Supreme Court case law and accepting the complaint’s statements as true, the Court held that Illinois was neither Associated Bank’s home state nor was it a jurisdiction where Associated Bank committed alleged infringing acts and where it has a regular place of business.