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”.

Eastern District of Virginia Judge M. Hannah Lauck ordered Patent Quality Assurance (PQA) to comply fully with a local rule requiring “non-publicly traded entities such as LLCs” to identify its “owners or members”. By the December 17 deadline, PQA filed an updated disclosure, unredacted for the court but with redactions occluding its “owners or members” from public view, filing a concurrent motion to seal its disclosure, not only keeping it permanently from the public, but also asking the court to deny VLSI Technology LLC, the Fortress Investment Group LLC plaintiff in the case, access to who is behind PQA.