Multiple Delaware NPEs under the same apparent control have each taken over the litigation of patents—earlier passed to a Texas entity for assertion—after the patents have boomeranged back. Most recently, Circuit Ventures LLC assigned a family of circuit monitoring patents to Texas entity Wireless Monitoring Systems LLC, which asserted them in litigation from November 2016 to January 2019 before assigning the family back. Circuit Ventures has sued NXP Semiconductors (6:19-cv-00275) and Pepprl + Fuchs (4:19-cv-01515) in April 2019 and Honeywell (1:19-cv-00857), Link Interactive (1:19-cv-00856), and Scout Security (1:19-cv-00858) so far in May. Likewise, Universal Cipher LLC assigned a single patent generally related to “dynamic” text generation to Cumberland Systems, LLC, which asserted it in litigation from May 2017 to May 2018 before returning the patent to Universal Cipher, which has now sued Best Buy (2:19-cv-00160), Target (2:19-cv-00163), and Wal-Mart (2:19-cv-00164) over it. These reversals, as well as other assignment activity, suggest a return to Delaware for these and other NPEs affiliated with the same patent attorney, perhaps motivated by a recent Federal Circuit opinion clarifying that targets of letter-writing campaigns can seek declaratory judgments in their home districts, rather than risk being sued elsewhere.

Recently created Texas NPE Spider Search Analytics LLC has launched its first litigation campaign, asserting a single patent (7,454,430) in new cases against Restocks (6:17-cv-00161), Sears (6:17-cv-00162), and Tuva Labs (6:17-cv-00163). The ‘430 patent generally relates to web crawling, reciting the rare claim that can be economically quoted in its entirety: “1. A method for crawling the internet to locate pages relevant to an application and thus building a Web Crawler comprising: starting from a base set of application-dependent web pages or crystallization points; and applying breadth-first recursive crawling”. Spider Search’s complaints accuse each defendant of infringement through the use of web crawler development products supplied by other companies (not themselves named as defendants): Restocks as a customer of Apifier; Sears, of Diffbot; and Tuva Labs, of Scrapy. The complaints refer to the web sites of each of these supplier companies, which identify many other customers of their services.