Judge Robinson recently granted defendant Parallel Networks’ motion to sever and transfer third-party defendant Microsoft’s declaratory judgment action to the Eastern District of Texas. Judge Robinson cited the judicial vacancy in Delaware and the “undeniable” facts pointing to the Eastern District of Texas as an appropriate venue when holding that “[a]lthough I continue to be amazed by the energy and resources expended on motions to transfer and believe that the way this litigation has unfolded would warrant jurisdiction in Delaware . . . I conclude that Microsoft’s declaratory judgment action should be severed and transferred to the Eastern District of Texas.” Quinstreet, Inc. v. Parallel Networks, LLC, C.A. No. 06-495-SLR (D. Del. Nov. 3, 2009).