InDodocase VR v. MerchantSource dba Sharper Image (CAFC 04-18-2019), the Federal Circuit confirmed that Inter Partes Review (IPR) is precluded by a typical exclusive venue provision in a patent license agreement.  As is typical, the license in this case specified that “any dispute arising out of or under this Agreement . . . shall be litigated before the courts in San Francisco County or Orange County, California.”  The licensee filed an IPR challenging the validity of the same patents that were subject to the license.  In response, the patent owner filed for preliminary injunction in the co-pending infringement litigation, asking the court to order the licensee to withdraw the IPR.  The district court granted the preliminary injunction and the Federal Circuit affirmed.  Remember that 35 U.S.C. § 315(b) forbids IPR unless it is filed within one year after an infringement lawsuit.  Thus, the practical effect of the exclusive venue provision will be to entirely preclude IPR.