For more than two decades, the Federal Circuit has held that correspondence alone from a patentee to a possible infringer would not subject it to personal jurisdiction in any declaratory-judgment action the alleged infringer might file in its “home” jurisdiction.1 In Trimble, Inc. v. PerDiemCo LLC,2 the Federal Circuit seems to have changed course. In Trimble, over the course of several months, the patentee communicated with the alleged infringer at least 22 times by letter, email, and telephone.