Last week, the Federal Circuit issued its first precedential reversal of a convenience transfer denial from Western District of Texas Judge Alan D. Albright. In its June 30 In re: Samsung ruling, the appellate court held that Judge Albright erred in denying such a transfer request by LG Electronics (LGE) and Samsung—calling out plaintiffs Ikorongo Technology, LLC (“Ikorongo Tech”) and Ikorongo Texas, LLC for attempting to “manipulate venue” and keep the case in West Texas, and faulting Judge Albright’s ruling on the merits. That decision has now led the Federal Circuit to undo the denial of a transfer motion in another case, this one against Uber,from that same campaign. Meanwhile, Juniper Networks has cited the ruling in its own mandamuspetition, seeking to force Judge Albright to transfer a set of cases filed against it by WSOU Investments, LLC.
Following its mid-August suits against HP Enterprise (HPE), WSOU Investments, LLC (d/b/a Brazos Licensing and Development) has added an additional suit against that same defendant (6:20-cv-00783) and filed five separate suits (6:20-cv-00812; 6:20-cv-00813; 6:20-cv-00814; 6:20-cv-00815; 6:20-cv-00816) against Juniper Networks, allin the Western District of Texas. WSOU asserts in each complaint a single patent from a large portfolio of assets received from Nokia (including from Alcatel-Lucent). Together, the six new suits target a range of networking hardware and software provided by the defendants, with Juniper Networks joining Alphabet (Google), Dell (EMC), HPE, Huawei, Microsoft, and ZTE as the newest defendant in WSOU’s recent campaigns.