Judge Gilstrap Was Still on Top in 2025, but Judge Albright Stayed in the News

The top district judge for patent litigation in 2025 was Eastern District of Texas Judge Rodney Gilstrap, who oversaw 19% of all new patent litigation this past year. Notably, Judge Gilstrap also presided over trials that led to five of the year’s ten highest patent damage awards, out of six that fell in his district.

Western District of Texas Judge Alan D. Albright tied for third place with Eastern District of Texas Judge Robert W. Schroeder III this past year. In Q4, Judge Albright fell just short of the top five.

Judge Albright, a former patent litigator who took the bench in the Waco Division in 2018, drew scrutiny and criticism for openly seeking to attract patent litigation to his courtroom—both through outreach and through a series of rule changes designed to streamline patent cases. Those efforts were enabled by permissive divisional filing rules that allowed plaintiffs to file cases in specific divisions within a district—thus guaranteeing that plaintiffs would get Judge Albright by filing in Waco, where he is the only district judge. As a result, Judge Albright became the nation’s top patent judge by an increasingly large margin and held that status for years.

However, Judge Albright was then knocked out of first place by rule changes made by his district’s chief judge in 2022 that explicitly targeted the concentration of patent litigation in his court—requiring that all Waco patent cases be randomly assigned among a larger group of judges, including Judge Albright. Though Judge Albright continued to be assigned a disproportionate share of cases in existing campaigns in the wake of the order, his patent docket nonetheless dwindled.

While Judge Albright may no longer play as large of a role in terms of litigation volume, headline-grabbing developments have nonetheless continued to play out in his courtroom.

One of the most notable examples came as the year approached its end, when Judge Albright also played a role in an unprecedented dispute triggered by a significant ruling that greatly expanded the reach of European courts. In early 2025, the Court of Justice of the European Union (CJEU) gave EU courts the power to decide claims of infringement arising outside the EU through its decision in BSH Hausgeräte v. Electrolux. That same October, US plaintiff Onesta IP LLC leveraged BSH to file what appears to be the first-ever case to assert US patents in a German court, here targeting BMW in the Munich I Regional Court. The automaker then sought the intervention of the Western District of Texas, where on January 13, Judge Albright orally granted BMW an anti-suit injunction ordering Onesta IP to terminate its German litigation. A frantic back-and-forth ensued as the NPE pursued an emergency appeal, including a dispute over when Judge Albright’s order took effect and how that outcome was being represented to the Federal Circuit. After initially denying Onesta IP’s request for a stay, the Federal Circuit then temporarily barred the ASI from taking effect.

More on that dispute can be found here. See RPX’s fourth-quarter review for further details on the impact of BSH and other key patent litigation trends from Q4 and 2025 overall.