Western District of Texas Judge Alan D. Albright has become well known for his restrictive posture toward certain defensive motions in patent litigation, including convenience transfer motions, requests to stay litigation pending the outcome of America Invents Act (AIA) reviews, and patent eligibility challenges. While Judge Albright has granted such motions to transfer or stay on occasion, he had previously never invalidated a patent under Section 101—but that changed just as 2021 drew to a close. The invalidations capped off a year in which Judge Albright again had more patent litigation fall in his courtroom than any other judge, as noted in RPX’s fourth-quarter review.

USC IP Partnership, LP has filed its first patent infringement lawsuit, accusing Facebook (6:20-cv-00555) of infringing a single patent generally related to predicting the intent of a webpage visitor through a data processing engine. The plaintiff targets the Facebook News Feed, with features for personalizing that service by using “signals”, “reactions”, and “stories” to “infer[] the intent of visitors”.  USC IP Partnership pleads that it is an affiliate of Usability Sciences Corporation, “the revolutionary usability and user experience research firm founded three decades ago by IBM alumnus Jeff Schueler”.