After TC Heartland tightened up patent venue, Judge Albright’s local patent rules drew plaintiffs wanting a quick courtroom shootout. According to Lex Machina and IP Law360, Judge Albright, by himself, picked up 793 patent litigations last year in the Western District of Texas (WDTex). In just a year, Judge Albright accumulated 20 percent of newly-filed patent litigations nationwide. A recent case shows, though, that not every plaintiff who wants to litigate in West Texas is entitled to stay there. Pleading key venue facts “on information and belief” will weaken an attempt to hold venue. Bootstrapping via pendent non-patent claims is also insufficient. Defendants who apply exacting