Last week, Western District of Texas Judge Alan D. Albright posted a couple of orders resolving Apple motions to transfer to the Northern District of California. One, docketed but sealed, denied a transfer of a case filed by Theta IP, LLC, while the other transferred a suit brought by inventor-controlled S.M.R Innovations Ltd and Y.M.R Tech Ltd in July 2023. Reporting in this second opinion, filed publicly, has focused on the plaintiffs’ attempt to hinge the “local interest” factor of a convenience transfer analysis on local tax breaks for Apple, but language elsewhere in the order continues to suggest a dissatisfaction with how the Federal Circuit has mandated that “court congestion” should be weighed, at least in certain cases.