Consider: Over time, it is possible judges in other jurisdictions did not like this. (Why?)
Question: Can anyone assume that these other judges not in, e.g., ED Tx, will not also be "plaintiff-friendly"?
Consider: Being "plaintiff-friendly" can have the effect of more patent cases being filed in the judge's jurisdiction. Further consider that some judges may want more patent cases filed in their jurisdiction.
As such, the headline may be prematurely drawing conclusions. Or not. Will patent litigation continue to rise, will it remain steady, or will it begin to fall?