Less than two weeks ago, a jury in the Eastern District of Texas awarded Realtime Data LLC $4.32M in damages for infringement by Riverbed Technology of one (8,643,513) of two patents taken to trial in that case. The jury found the asserted claims of the other patent (7,415,530) invalid for obviousness in light of certain prior art. The case was filed in May 2015 as part of Realtime Data’s sprawling campaign, which includes a second case against Riverbed, filed just this past April. In light of the TC Heartland decision, Riverbed Technologies has taken steps to litigate the two patents at issue there (8,717,204; 8,719,438) in the Northern District of California instead, filing a complaint seeking declaratory judgments of non-infringement. In the new complaint, Riverbed pleads that because it is not incorporated in Texas and does not have a “regular and established place of business” in the Eastern District of Texas, venue is not proper there. Meanwhile, Realtime Data faces reinvigorated venue challenges in other cases in its Texas campaign.