At a scheduling conference held on May 31, 2017 before District Judge Rodney S. Gilstrap in the Eastern District of Texas, plaintiff Hypermedia Navigation LLC, an affiliate of monetization firm IP Valuation Partners LLC, and defendant Yahoo, nearing acquisition by Verizon, indicated that a joint motion to transfer their case to the Northern District of California had been filed. Judge Gilstrap had that same day issued an order requiring the parties to address the effect, if any, of the US Supreme Court’s TC Heartland decision on Yahoo’s April motion to dismiss for improper venue, itself already premised on a TC Heartland theory—that is, on a reading of the venue statutes that restricts corporate residence to the state of incorporation (Delaware for California-based Yahoo). On June 1, the court granted the joint motion, and four days later, the case (3:17-cv-03188) was opened in the Northern District.

RPX took notice, among the USPTO assignment records made available during the latter half of April, of the transfer of patents to a number of frequent plaintiffs in patent litigation, including BlackBird Tech LLC; Intellectual Ventures LLC; IP Valuation Partners LLC; Unwired Planet International Limited, and Wi-LAN Inc. Assignors included Cypress Semiconductor, NXP Semiconductors, Panasonic, ROY-G-BIV, Samsung, and Sharp.