Late last month, HTC score a small but important tactical win over Apple in a case brought by the iPad maker over infringement claims on six Apple patents when the judge there moved to separate the HTC case from a similar Motorola lawsuit and granted HTC's request to move the trial to Delaware. Today, a court in Eastern Virginia hearing a separate counterclaim from Apple regarding the FRAND status of two HTC patents was also moved to Delaware, resulting in a delay in both cases.