East Texas Stayed on Top in Q3 Amid Notable Verdict Activity

The Eastern District of Texas was the top patent district for overall litigation (i.e., with no filter for plaintiff type) and NPE litigation in Q3 2025, also holding the number-four spot for operating company litigation. In second for overall litigation was the District of Delaware, which also held third place for NPE litigation but was the most popular district for operating company litigation. Meanwhile, the Western District of Texas trailed behind Delaware in third place for overall litigation and was in second for NPE litigation, again failing to break the top five for operating company filings.

The Eastern District, long a patent hotspot, saw the two largest patent damage awards of the third quarter—a jury awarding $175M to Headwater Research LLC in July and another awarding $78.5M to Anonymous Media Research Holdings LLC in September. The latter is notable in part because of the starkly different results between that case and another parallel Anonymous Media suit that was transferred from the Western District of Texas to the Northern District of California. While the East Texas case saw District Judge Rodney Gilstrap deny a motion to stay pending the outcome of certain inter partes review proceedings (IPR), issue a claim construction order, and grant summary judgment of no invalidity under Alice prior to the verdict, the California case was stayed pending IPR, with District Judge Vince Chhabria invalidating the asserted patents under Alice—eleven days after the conflicting ruling by Judge Gilstrap.

The third quarter was also notable for posttrial activity that led to the fall of two other large damage awards. In September, the Federal Circuit overturned a $166.3M verdict issued in January 2023 for inventor-controlled Finesse Wireless, LLC against AT&T, finding that it had been based on flawed testimony from the plaintiff’s infringement expert—including some the court found to be “contradictory”, “confusing”, and “unclear”—and thus could not stand. Also in September, District Judge Robert W. Schroeder, III toppled a $112M verdict returned against Samsung in May 2025 in litigation from Maxell, granting judgment as a matter of law of noninfringement for all three tried patents and for invalidity as to two of those patents.

See RPX’s third-quarter review for more on district court trends and other key developments shaping patent litigation so far this year.