Western District of Texas District Judge Alan D. Albright frequently found himself at odds with the Federal Circuit over his handling of transfer motions just a few years ago, peaking in a wave of mandamus rulings against him in 2021. That June, Judge Albright—at that point still swimming against the tide on transfers—issued an expansive pair of rulings that found venue to be proper against Hyundai and Volkswagen based on the presence of third-party car dealerships in his district. This prompted a sharp rebuke and reversal by the Federal Circuit, which in March 2022 precedentially held that he was wrong to find an agency relationship between the automakers and those dealerships. Now, with his conflict with the Federal Circuit largely in the rear-view mirror, Judge Albright has heeded the court’s prior warning, rejecting another dealership-based venue argument in transferring a case filed by two Intellectual Ventures LLC (IV) plaintiffs against Zhejiang Geely (Volvo) to the District of New Jersey.