A recently formed Delaware entity, CryptoPeak Security, LLC (CP Security), has begun litigating the patent (6,202,150) that Texas NPE CryptoPeak Solutions, LLC (CP Solutions) asserted against over 60 defendants in the Eastern District of Texas between July 2015 and this past April. The ‘150 patent is generally related to generating private keys in public-private keypair encryption, with infringement allegations focusing on the security systems used on the websites of new defendants 1-800 Contacts, Abercrombie & Fitch, Advance Auto Parts, Cabelas, First Citizens Bancshares, GameStop, Jack Henry & Associates, MGM Resorts, Papa John’s, Teladoc, Tractor Supply, and Wal-Mart (Jet.com), with each identified as a Delaware corporation. This move from Texas to Delaware appears to be part of a larger strategy by California attorney Brian Yates to transition ground zero for his litigation activities, perhaps more in light of a notable Texas sanctions ruling against him earlier this year than in response to the US Supreme Court’s TC Heartland decision.