The Western District of Texas has seen a significant increase in patent litigation since the confirmation of District Judge Alan D. Albright. That trend that has accelerated in 2020, the second quarter of which saw the Western District overtake Delaware as the most popular patent venue. With that popularity has come greater scrutiny of Judge Albright’s posture toward certain types of motions—most notably inter-district motions to transfer for convenience, a form of relief that Judge Albright has never granted, according to one litigant. The Federal Circuit has now pushed back against Judge Albright’s approach to such motions, ruling that he improperly weighed the applicable factors in a decision that denied a convenience transfer motion filed by Adobe. However, the Federal Circuit also rejected a similar mandamus petition filed by Dropbox in another case by the same plaintiff, SynKloud Technologies, LLC, holding that the defendant must first seek reconsideration of Judge Albright’s underlying order denying transfer.