In Xilinx Inc. v. Papst Licensing GmbH & Co. KG, Appeal No. 2015-1919 (Fed. Cir. Feb. 15, 2017), the Federal Circuit applied the usual test for in personam jurisdiction, in an apparently new way, to reverse dismissal of a declaratory judgment suit against an alien patent owner seeking to avoid the alleged infringer’s home forum. More specifically, a panel consisting of Chief Judge Prost and Circuit Judges Newman and Dyk held that the Northern District of California had specific personal jurisdiction over a German patent owner, Papst Licensing GmbH & Co. KG, that, as a nonpracticing entity and in accordance with its usual practice, mailed notice to the alleged infringer, Xilinx, Inc., that it was infringing and should consider taking a license. After Papst mailed that notice, Papst representatives traveled to California and met with Xilinx representatives to discuss Papst’s allegations and potential licensing. When no agreement was reached, Xilinx filed a declaratory judgment suit in the Northern District seeking a declaration of invalidity and noninfringement. Papst moved to dismiss for lack of in personam jurisdiction or to transfer to the District of Delaware, where Papst had filed an infringement suit against Xilinx.