WacoWatch

On September 18, 2024, Judge Albright found four Volvo dealerships do not constitute regular and established places of business for two Volvo defendants and transferred a patent infringement case against them to the District of New Jersey on the grounds that the Western District of Texas (W.D. Tex.) is an improper venue.

On March 17, 2023, Judge Fred Biery granted Google LLC’s (Google) motion to dismiss Plaintiff ALD Social, LLC’s (ALD Social) complaint with prejudice for failure to state a claim pursuant to Rule 12(b)(6).

On December 29, 2022, Judge Albright issued two orders applying the customer suit exception to Plaintiff Topia’s patent infringement claims against defendants Sailpoint, Vistra, and Clear Channel, all customers of defendant Box.

Earlier this spring in EcoFactor, Inc. v. Google LLC, 6:20-cv-00075 (ADA), a jury awarded EcoFactor approximately $20 million in damages for Google’s infringement of one of its patents. 

In orders ruling on two motions to transfer venue to the Northern District of California (N.D. Cal.) in related cases, Judge Albright granted transfer to Defendant Google LLC and denied transfer to Defendant Vivint, Inc.

On October 27, 2022, Judge Albright denied Defendant NCR Corporation’s (“NCR”) Rule 50(b) Motion for Judgment as a Matter of Law or, Alternatively, a New Trial.

On May 16, 2022, Judge Albright denied Defendants Samsung Electronics Co., Ltd. Inc’s and Samsung Electronics America, Inc’s (collectively, “Samsung” or “Defendants”) Motion to Transfer Venue from the Western District of Texas to the Northern District of California.

On May 17, 2022, a jury in the Western District of Texas, Waco division with Judge Albright presiding, found for defendant Redfin Corporation (“Redfin”) and held that U.S. Patent Nos. 9,836,885; 10,102,673; 10,510,111; and 10,592,373 were invalid.

On March 30, 2022, Judge Albright reconsidered Defendant Google LLC’s (“Google”) motion to sever and stay in Sonrai Memory Ltd. v. Google LLC.

On March 25, 2022, Judge Albright granted Defendant Meraki Integrated Circuit (Shenzhen) Technology, Ltd.’s (“Meraki”) opposed motion for reconsideration and severed Defendant Meraki and granted its transfer motion to the Northern District of California (“NDCA”).

Plaintiffs Monolithic Power Systems, Inc. and Chengdu Monolithic Power Systems Co., Ltd. (together, “MPS”) filed this action against Defendant Meraki, alleging patent infringement (“Patent Claims”) along with claims of trade secret misappropriation, tortious interference, and unfair competition (“Non-Patent Claims”). Also, MPS filed a lawsuit in the NDCA against Defendant Meraki’s founders in their individual capacities.

On June 25, 2021, IngenioShare, LLC (“IngenioShare”) sued Epic Games, Inc. (“Epic”) for direct and indirect patent infringement in the Western District of Texas (“WDTX”). Epic argued that the venue was improper. On March 18, 2022, in a nine-page Order, Judge Albright expressed his agreement and dismissed the case.

On March 9, 2022, several months after accessiBe Ltd. (“accessiBe”) was denied transfer in AudioEye, Inc. v. accessiBe Ltd., Judge Albright reversed his decision on reconsideration. The case will proceed in the Western District of New York (“WDNY”).

On March 1, 2022, Judge Albright denied Defendant Apple, Inc.’s (“Apple”) Motion to Transfer Venue to the Northern District of California (“NDCA”), “alleging that it is more convenient than this District.” Plaintiff BillJCo, LLC (“BillJCo”) did not contest that this action could have been brought in the NDCA.

On March 1, 2022, Judge Albright granted Defendant eClinicalWorks, LLC’s (“eClinical”) Motion to Transfer Venue to the District of Massachusetts. eClinical did not argue that the Western District of Texas, Waco Division (“WDTX”) was an improper venue, but rather that the District of Massachusetts “is simply a more convenient forum.”

Judge Albright recently issued a series of orders related to the customer-suit exception corresponding to patent infringement actions filed by patent plaintiff Sonrai Memory Limited (Sonrai).

On May 28, 2021, Monterey Research, LLC (“Monterey”) sued Broadcom Corporation (“Broadcom”) in the Waco Division, alleging infringements of seven patents. Broadcom and Monterey, however, are both headquartered and have their principal places of business in the Northern District of California. Therefore, on November 29, 2021, and before substantive proceedings occurred, Broadcom moved to transfer venue to N.D. Cal. Judge Albright denied the motion—less than a month after briefing concluded. In denying transferring the case, Judge Albright considered the 28 U.S.C. § 1404(a) transfer factors, focusing on the following six factors contested by the parties.

On January 7, 2022, Judge Albright entered a preliminary injunction against foreign Defendants Big Hippo LLC and EifBrissa in Qin v. Partnerships and Unincorporated Associations on Schedule “A.” They are now enjoined from manufacturing, importing, distributing, offering for sale, or selling unauthorized and unlicensed automotive seat covers that infringe Plaintiff’s patented design.

In Health Discovery Corp. v. Intel Corp., Judge Alan Albright granted, in part, Intel’s motion to dismiss infringement claims of AI machine-learning patents on § 101 grounds. 

On December 29, 2021, Judge Albright granted Lenovo USA and Motorola’s motion to dismiss for improper venue in Gesture Technology Partners LLC v. Lenovo Group. It remains to be seen whether Gesture Technology Partners (“Gesture”) will appeal or refile in another jurisdiction.

On January 3, 2022, Judge Albright issued multiple orders related to the award of potential damages in Integrity Worldwide, Inc. v. Rapid-EPS Ltd. et al. The below summarizes these orders.