Last month, RPX surveyed the effective use of inter partes review (IPR) by defendants in the many campaigns launched over patents once held by Uniloc Corporation Pty. Limited. The Australian NPE—and Fortress Investment Group LLC after its takeover of those campaigns in May 2018—has hit multiple invalidity walls in district court as well. For example, this past April was not a good month for a wireless communications patent, issuing to Philips, that Uniloc began asserting in early 2018. On April 5, Magistrate Judge Roy S. Payne of Texas invalidated claims 1 and 8 from that patent as indefinite, and four days later, District Judge Lucy H. Koh in California took the whole patent down as patent-ineligibly drawn to an abstract idea under Alice. However, recent decisions, in Fortress-Uniloc suits and elsewhere, may have provided the plaintiff additional motivation to clear a path, however rocky, for that embattled patent to survive in the end.