Four days after the US Supreme Court issued its TC Heartland decision, returning to its previous, narrower interpretation of where proper venue lies in patent cases, an affiliate of Texas-based monetization firm IP Edge LLC has taken the rare step of filing litigation outside the Eastern District of Texas. Venadium LLC has asserted the sole patent at issue in its campaign (6,330,549) in Northern District of Illinois complaints against three companies allegedly formed in that state—Paylocity (1:17-cv-04002), State Farm Mutual Automobile Insurance (1:17-cv-04004), and W.W. Grainger (1:17-cv-03999)—as well as against two Delaware companies—Allstate Insurance (1:17-cv-03998) and Hyatt Hotels (1:17-cv-04001). Meanwhile, Somaltus LLC, another IP Edge affiliate, agreed to postpone a scheduling conference in an ongoing Eastern District of Texas case to allow that court to rule on a pending motion to dismiss filed by the Ohio defendant, The Noco Company, for lack of personal jurisdiction and improper venue. Late this past week, Magistrate Judge Roy S. Payne granted the motion, transferring that case out of Texas to the Northern District of Ohio. Finally, last week two Southern District of New York judges asked IP Edge affiliate Kaldren LLC to submit letters explaining why venue is proper in cases that that the NPE brought earlier this month in that district.