Eastern District of Virginia Judge M. Hannah Lauck has remanded back to state court a case filed there by VLSI Technology LLC, a Fortress Investment Group LLC plaintiff, against Patent Quality Assurance (PQA). PQA had removed the suit to federal court, but Judge Lauck has agreed with VLSI Technology that none of its claims raise a federal question, much less a substantial federal question. The remand back to state court moots several pending motions before Judge Lauck, including a PQA motion to file under seal its corporate disclosure, a document that would have (finally) identified its “owners or members”.