Takeaway: Apple has decided to close its store locations in the Eastern District of Texas to avoid patent litigation in that district.

Apple has decided to close two of its locations in the Eastern District of Texas and will be opening a new location a short distance away, which happens to be just over the boarder of the district court lines. The new location would be in the Northern District of Texas, which does not carry the same reputation for being plaintiff friendly in patent disputes.

After the decision by the Supreme Court in TC Heartland, this move may make a lot of sense. In that case, the Supreme Court decided that a company can only be sued in the district where it resides. A subsequent decision interpreting the ruling in TC Heartland also determined that simply having an employee working from home in the district is not enough. Because Apple has frequently been sued in the unfavorable Eastern District of Texas, this move may be wise financially.