In Re LENOVO GROUP LIMITED v. U.S. Dist. Ct. for D.C., 542 U.S. 367, 380-81 2004 internal quotation marks

NOTE: This order is nonprecedential.
United States Court of Appeals
for the Federal Circuit
______________________
In Re LENOVO GROUP LIMITED,
Petitioner
______________________
2025-111, 2025-112
______________________
On Petition for Writ of Mandamus to the United States
District Court for the Eastern District of Texas in No. 2:23-
cv-00449-JRG and No. 2:24-cv-00239-JRG, Chief Judge J.
Rodney Gilstrap.
______________________
ON PETITION
______________________
Before TARANTO, CHEN, and STARK, Circuit Judges.
STARK, Circuit Judge.
O R D E R
In these related petitions, which we consolidate for
purposes of resolution, Lenovo Group Limited seeks a writ
of mandamus directing the United States District Court for
the Eastern District of Texas to dismiss the underlying
cases for lack of personal jurisdiction. Universal Connec-
tivity Technologies Inc. and Eireog Innovations Ltd. op-
pose.
Universal and Eireog brought these suits in the East-
ern District of Texas alleging that Lenovo directly and
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IN RE LENOVO GROUP LIMITED 2
indirectly infringed claims of their patents. Lenovo, a Chi-
nese company based in Hong Kong, moved to dismiss the
complaints for lack of personal jurisdiction. In support,
Lenovo submitted a declaration from its Director of Group
Financial Reporting and Accounting Policy, stating that
Lenovo “is and has been a holding company” that “does not
itself manufacture, sell, offer for sale, export, import or oth-
erwise distribute” the accused products and that it does not
itself operate or do business in the state of Texas.1
The district court declined to grant Lenovo’s motions in
light of “open factual disputes as to whether [Lenovo] cre-
ated, controls, or directs its subsidiaries to place the alleg-
edly infringing products into the stream of commerce in
Texas.”2 Accepting the plaintiffs’ allegations as true and
viewing factual conflicts in favor of plaintiffs given the pro-
cedural posture the motion came before it, the court con-
cluded that there was at least a prima facie showing of
personal jurisdiction over Lenovo based on its specific con-
tacts with the forum state, Texas, or alternatively, under
Federal Rule of Civil Procedure 4(k)(2), based on Lenovo’s
contacts with the United States as a whole.
Generally, for mandamus to issue, a petitioner must
establish not only that its right to relief is “clear and indis-
putable,” but also that it has “no other adequate means to
attain the relief [it] desires.” Cheney v. U.S. Dist. Ct. for
D.C., 542 U.S. 367, 380–81 (2004) (internal quotation
marks and citations omitted). We have recognized a “nar-
row” exception to these requirements, but to qualify, a pe-
titioner must show that our immediate intervention is
“important to proper judicial administration, such as when
1 Appeal No. 2025-111, ECF No. 2 at Appx49–51; Ap-
peal No. 2025-112, ECF No. 2 at Appx42–45.
2 Appeal No. 2025-111, ECF No. 2 at Appx7; Appeal
No. 2025-112, ECF No. 2 at Appx9.
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IN RE LENOVO GROUP LIMITED 3
an appellate court corrects a district court’s answers to
basic, undecided legal questions concerning judicial admin-
istration matters.” In re Stingray IP Sols., LLC, 56 F.4th
1379, 1382 (Fed. Cir. 2023) (cleaned up). Lenovo has not
met those demanding requirements here.
Consistent with Cheney, courts have found mandamus
unavailable to review rulings on motions to dismiss for
want of personal jurisdiction, because a post-judgment ap-
peal is an adequate remedy. See Dubea v. Simpson, 277 F.
App’x 458, 459 (5th Cir. 2008) (“Because the district court’s
order is reviewable on appeal from a final judgment, Simp-
son cannot show that he has ‘no other adequate means to
attain the relief he desires,’ which is one of the prerequi-
sites for mandamus relief.”); see also In re BNY ConvergEx
Grp., LLC, 404 F. App’x 484, 485 (Fed. Cir. 2010) (“To grant
mandamus simply because a party asserts it will be forced
to expend unnecessary costs would make a large class of
interlocutory orders routinely reviewable.”).
Lenovo also has not shown that mandamus review is
warranted for proper “judicial administration,” which is
generally limited to rulings that necessitate immediate ap-
pellate intervention because they implicate “a basic, unset-
tled, recurring legal issue over which there is considerable
litigation producing disparate results, or similar [extraor-
dinary] circumstances.” In re Monolithic Power Sys., Inc.,
50 F.4th 157, 160 (Fed. Cir. 2022) (cleaned up). No such
urgency has been shown here.3 And there are good reasons
3 Lenovo points to two district court cases, 3G Li-
censing, S.A. v. Lenovo Grp. Ltd., No. 17-84-LPS, 2019 WL
3974539 (D. Del. Aug. 22, 2019), report and recommenda-
tion adopted, 2019 WL 7635823 (D. Del. Sept. 19, 2019) and
Theta IP, LLC v. Motorola Mobility LLC, No. 22C3441,
2024 WL 1283706 (N.D. Ill. Mar. 25, 2024), that dismissed
cases against Lenovo for want of specific personal
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IN RE LENOVO GROUP LIMITED 4
not to intervene at this time to review what amounts to a
preliminary assessment of the facts and allegations pre-
sented. Most obviously, it will allow for the development of
a more fulsome record of relevant facts and for the oppor-
tunity to define the precise legal issues at play.
Accordingly,
IT IS ORDERED THAT:
The petitions are consolidated and denied.
March 4, 2025
Date
FOR THE COURT
jurisdiction in other forums. However, those decisions
were based on the specific records before those courts, re-
late to Lenovo’s status at different times, and did not ad-
dress whether there was personal jurisdiction over Lenovo
under Federal Rule of Civil Procedure 4(k)(2). In any
event, our holding today does not address the merits of the
question of whether the Eastern District of Texas, or any
other district court, may exercise personal jurisdiction over
Lenovo.
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