The Federal Circuit recently issued yet another writ of mandamus against Western District of Texas Judge Alan D. Albright over his handling of a convenience transfer motion. On May 26, the court held that Judge Albright erred by denying Apple’s motion to transfer a case filed against it by BillJCo LLC, concluding that despite his revised arguments citing prior mandamus rulings against him, he had made a similar set of legal errors in his application of the relevant factors (2022-0137). That case has now been transferred to the Northern District of California (5:22-cv-03201) in the wake of that ruling. This is just the latest such decision by the Federal Circuit, which last year reversed Judge Albright on convenience transfers a total of 18 times, including nine in the fourth quarter alone. While that wave has slowed to a steady trickle, this most recent opinion—the second such reversal by the Federal Circuit this year—suggests that Judge Albright’s approach is still not to the court’s liking.

Texas plaintiff BillJCo LLC has filed separate suits against Apple (6:21-cv-00528), Cisco (2:21-cv-00181), and HP Enterprise (HPE) (Aruba Networks) (2:21-cv-00183) over the provision of products implementing Bluetooth LE beacon technology. Six patents are asserted against Apple, the same subset of three at issue in the other two complaints, all of them generally related to triggering the sending and presentation of data from a sending “data processing system” to a receiving “data processing system” based on their physical proximity to one another.