There are other potential loopholes unrelated to the "place of business" language. Matthew Rizzolo, an IP lawyer with Ropes & Gray who represents both plaintiffs and defendants, noted Monday's decision did not address either foreign companies or limited liability companies, leaving both still potentially vulnerable to lawsuits in the Eastern District.
"Now you are going to see a lot of fights over those issues," he said.
https://www.ropesgray.com/utility/search-resu...e&os=0
Btw, Matthew Rizzolo is on the SFOR leagle team at Ropes & Gray. :*)