A variety of NPEs have reacted to the US Supreme Court’s decision in TC Heartland v. Kraft Foods Group Brands (2016-0341) by either dismissing and re-filing their cases in other districts or simply conceding venue challenges. In contrast, Australian NPE Uniloc Corporation Pty. Limited has further dug its heels into the Eastern District of Texas. Shortly after Uniloc filed a series of new and amended complaints against Google, designed to establish proper venue in the Eastern District, defendants in some of the NPE’s other Texas litigation filed a host of venue motions against it. On June 2, Ubisoft (2:16-cv-00745, 2:16-cv-00781) filed two motions both seeking transfer to the Northern District of California or dismissal for improper venue in litigation targeting its software licensing and notification systems, joined by a similar motion filed by Piriform on June 7 (in a consolidated action against AVG, 2:16-cv-00393) seeking dismissal or transfer to Delaware. Ubisoft filed another such motion in Uniloc’s software update campaign on June 2 (2:17-cv-00175), also seeking transfer to the Northern District of California or dismissal for improper venue, joined by another Northern District transfer/dismissal motion brought by Box (2:17-cv-00173), with campaign co-defendant Zendesk (2:17-cv-00176) filing its own motion to dismiss due to improper venue that same day.