Western District of Texas Judge Alan D. Albright recently authorized inventor-controlled plaintiff Red Rock Analytics, LLC to file a fourth supplemental brief in opposition to a motion to transfer to the Northern District of California from defendants Apple and Qualcomm. The August 2021 motion itself was long ago briefed through sur-sur-reply, with three prior sets of supplementals going in. Red Rock filed the fourth supplemental because in its last update, it had represented that as of June 2023, “[o]ther than In re Google, no decision from the Fifth Circuit, the Federal Circuit, or any Federal court of appeals has ever held that ‘product competition’ should be considered under the court congestion factor”—a characterization of the convenience transfer landscape that is no longer true.