VirtaMove, Corp. (f/k/a Appzero) has brought a third “application encapsulation” patent into its containerization campaign by filing another Western District of Texas complaint against Microsoft (7:25-cv-00254). Begun in January 2024, this litigation has seen West Texas District Judges Alan D. Albright and David Counts override objections to orders from Magistrate Judge Derek T. Gilliland transferring separate cases against Amazon and Alphabet (Google), respectively, to the Northern District of California. There, District Judge P. Casey Pitts just dismissed, for lack of subject matter jurisdiction, a declaratory judgment complaint filed by IBM (Red Hat).