In January of this year, Central District of California Judge James V. Selna denied a VIZIO motion for attorney fees, finding nothing exceptional in the conduct of the last active case filed by Polaris PowerLED Technologies, LLC. Now, that plaintiff has filed another case in the campaign, suing Dell and Microsoft (6:22-cv-00254) in a single Western District of Texas complaint. Asserted is a single former Microsemi patent generally related to adjusting an LED display backlight, with direct infringement allegations targeting Dell laptops and Microsoft Surface products “that contain ambient light sensors and automatic brightness control features”. Microsoft is also charged with indirect infringement through the alleged inducement of “third parties who use Microsoft’s software (e.g., Windows) on their computers”, including Dell.