On Nov. 5, 2020, the Federal Circuit affirmed a lower court's order dismissing the claims against two defendants for improper venue. Valeant Pharm. v. Mylan Pharm., No. 19-2402 (Fed. Cir. Nov. 5, 2020). The Federal Circuit concluded that for venue purposes in ANDA cases, infringement occurs only in districts where actions related to the submission of an ANDA occur and not all locations where future distribution of the generic products is contemplated.
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