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.

Theta IP, LLC has added a Western District of Texas suit against Apple (6:23-cv-00314) to the litigation campaign that it began back in May 2016 to “return value” to investors in Theta Microelectronics (“Theta Micro”). The new complaint asserts three patents, generally related to reducing power dissipation in wireless transceivers, already in suit in the Northern District of Illinois against Lenovo (Motorola Mobility), plus two additional members of the same family, both issuing to Theta IP this year. Targeted is the provision of cellular-enabled mobile devices, including models of iPhone, iPad, and Apple Watch, that allegedly include certain “dynamic power dissipation technology” used to “reduce cellular RF power consumption”. The complaint details certain exemplary iPhones’ use of transceivers and modems from Qualcomm or Intel and RF front-end components from Broadcom or Skyworks, noting that those companies have advertised the power-saving features of those components.

Roughly two weeks after its suit against Samsung was dismissed, on the verge of a Western District of Texas trial, Theta IP, LLC has sued Lenovo (Motorola Mobility) (1:22-cv-03441) in the Northern District of Illinois. The plaintiff asserts three of its patents, generally related to reducing power dissipation in wireless transceivers, touting the background and accomplishments of named inventor Yannis Tsividis, a professor of electrical engineering at Columbia University, and targeting the purported inclusion of “radios that employ these patented power-saving designs and methods across the entirety of its mobile phone and cellular-enabled tablet lineup offered in the United States”.

Theta IP, LLC has filed a second suit against Samsung (6:20-cv-00160) more than two years after the first one, filed in 2016, ended in both a dismissal with prejudice from the district court and a covenant not to sue filed with the USPTO. The newly asserted patents, from the same family as those previously asserted, generally relate to reducing power dissipation in wireless transceivers. In a sure sign of the times, where the 2016 suit against Samsung was filed in the Eastern District of Texas, Theta IP filed this past week’s case in the Western District of Texas.

Theta IP, LLC has kicked off its first litigation campaign with the filing of a single lawsuit against Samsung (2:16-cv-00527), accusing the company of infringing two patents (7,010,330; 9,331,728) generally related to power dissipation reduction techniques for electronic circuits. The accused products include smartphones that employ dynamic power dissipation.