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ARTICLE · 09 JANUARY 2026

Intellectual Property Report

Baker Botts L.L.P.
Baker Botts L.L.P.
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Baker Botts L.L.P.

Baker Botts L.L.P.

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As discussed in our previous article, Comcast sought mandamus relief after Judge Gilstrap of the Eastern District of Texas denied the company's motion to dismiss or transfer for improper venue.

United StatesIntellectual Property
Baker Botts
Baker Botts

Patent Venue for Method Claims: The "One-Step Rule" Survives (For Now)

Jaemin Sung, Lauren Dreyer

As discussed in our previous article, Comcast sought mandamus relief after Judge Gilstrap of the Eastern District of Texas denied the company's motion to dismiss or transfer for improper venue. On December 9, 2025, the Federal Circuit denied Comcast's petition for a writ of mandamus in In re Comcast Cable Communications, LLC. The nonprecedential order leaves the contentious "one-step rule" for patent venue intact—at least for now—allowing district courts to continue finding venue proper where even a single step of a patented method is performed. For tech companies facing patent infringement suits involving distributed systems and cloud-based infrastructure, the landscape remains as uncertain as before.

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