Inventor-controlled Red Rock Analytics, LLC sued Apple for the second time in April 2021, naming Qualcomm as a codefendant in its Western District of Texas complaint. The defendants filed a motion to transfer the case for convenience to the Northern District of California in August 2021. This past week, Red Rock filed its third supplemental brief in opposition to that still-pending motion, the plaintiff urging District Judge Alan D. Albright to ignore the Federal Circuit’s holding from In re Google, characterizing that decision as contradicting controlling Fifth Circuit law concerning convenience transfers, and to credit Red Rock’s expert testimony, which purports to assign a specific dollar amount on the “economic opportunity cost” of a seven-month delay in time-to-trial between the two districts. That delay is now significantly dwarfed by the roughly 24 months that the motion to transfer has sat fully briefed through sur-sur-reply.