RPX’s latest report on the patent ecosystem details how the Western District of Texas became the most popular patent venue in 2020, buoyed by efforts from District Judge Alan D. Albright of the Waco Division to attract such litigation. However, the past year also saw a rift develop between Judge Albright and the Federal Circuit over certain issues related to venue; specifically, his treatment of motions to transfer for convenience. After reversing Judge Albright’s denial of several such motions throughout 2020, the appellate court issued a split decision in November that granted Apple’s mandamus petition challenging one such ruling in litigation filed by Fortress Investment Group LLC subsidiary Uniloc 2017 LLC. The full Federal Circuit has now summarily rejected Uniloc’s petition for en banc review of that holding, known as In re: Apple, prompting Judge Albright to transfer the case to the Northern District of California. Uniloc, meanwhile, has indicated that it may seek further review from the US Supreme Court.