In the wake of last week’s TC Heartland decision from the US Supreme Court, Iron Oak Technologies LLC has voluntarily dismissed and refiled two of the cases in the litigation campaign that it began last November. The NPE prefaces both of its notices of dismissal without prejudice in the Northern District of Texas by acknowledging that the TC Heartland decision “overturned decades old controlling law from the Court of Appeals for the Federal Circuit”, noting that it is “unaware” of either Acer (incorporated in California) or Lenovo (incorporated in Delaware) “having a regular and established place of business” in that district. Iron Oak then filed new actions in the Western District of Texas against Acer (6:17-cv-00143) and Lenovo (1:17-cv-00525), asserting the same two patents against Acer while dropping one of the five patents previously asserted against Lenovo.