The Western District of Texas has seen a surge in patent litigation since the September 2018 confirmation of District Judge Alan D. Albright, who has taken active steps to attract patent litigants to his district—in part through a standing order implementing rules designed to appeal to both plaintiffs and defendants. However, Judge Albright has taken a markedly restrictive approach with certain types of dispositive motions, including patent eligibility challenges and motions to transfer for convenience. Apple has now challenged Judge Albright’s handling of the latter in litigation brought by Fortress Investment Group LLC subsidiary Uniloc 2017 LLC, arguing in a June 16 mandamus petition filed with the Federal Circuit that the manner in which Judge Albright balances the applicable factors make convenience transfers “[e]ffectively [u]navailable” in the Western District. This case, Apple asserts, is “part of a trend”, as “[i]n his nearly two years on the bench, Judge Albright has never granted” a transfer out of his district on convenience grounds.