The Western District of Texas has become an ever more popular venue for patent plaintiffs over the past couple of years. Indeed, as RPX recently noted, in February, the district overtook the top spot for patent litigation, surpassing both the historical frontrunner, the Eastern District of Texas, and the more recent leader, the District of Delaware. As a theoretical matter, key to becoming a top venue for active patent cases would be a willingness to land on the “stickier” end of discretion when it comes to convenience transfers.