Not So Fast: Judge Albright Demands a “Fulsome Record”

Western District of Texas Judge Alan D. Albright has denied a motion to reconsider his vacatur of a recommendation by Magistrate Judge Mark Lane that an AMD (Pensando Systems) motion to transfer a case for convenience be granted. That case—filed by XtreamEdge, Inc. (as patent owner) and Concurrent Ventures, LLC (as exclusive licensee) in March 2024—was “assigned to the placeholder-DII docket” because District Judge Robert Pitman had been the only judge in West Texas’s Austin Division since May 2023. Judge Lane recommended that the defendants’ motion to transfer be granted, doing so without the period of venue-specific discovery typically authorized by Judge Albright, to whose docket the case was assigned on February 3, 2025, four days after Judge Lane’s recommendation. The plaintiffs filed objections to that recommendation, which Judge Albright then vacated—imposing a stay to let roughly six weeks of venue-related discovery unfold.