The Eastern District provides us with a side-by-side comparison of motions for amending contentions. Together, these decisions illustrate the important facts for both sides. Judge Gilstrap also provides us with a wonderful example of what it takes to win a 12(c) motion and strike down a patent under 101. Compare this outcome to Judge Albright's "uphill scrabble" to win a Rule 12 motion on 101. Finally, Judge Albright gives updated guidance on alternative service and about modifying his model protective orders.