Earlier this year, Northern District of California Judge Jon S. Tigar rejected an unusual argument from plaintiff Lauri Valjakka urging the court to apply Finnish common law concerning the appropriation of abandoned shipwrecks and piles of discarded leather scraps to save his case. Then, Eastern District of Texas Judge Rodney Gilstrap held that French law, which follows “the privity rule”, applies to the contract giving rise to a FRAND obligation; and that Samsung provided insufficient evidence under French law that plaintiff G+ Communications LLC could be considered the alter ego of ZTE. For the latest brush with foreign law in domestic patent cases it is back to Judge Gilstrap, who just denied a motion to dismiss on a license defense that brushed up against a ruling under German law.