FORTUNE — U.S. Magistrate Judge Paul S. Grewal, who has been handling some of the case load created by the multiple patent infringement suits filed in California by Apple (AAPL) and Samsung, has a judicial metabolism better fit for the 19th century than 21st.
He’s the judge who was assigned the task last year of scheduling Apple’s second big federal patent suit against Samsung — not the one that Apple won 10 months ago with a $1.05 billion award (of which not a nickel has been paid), but the one Apple filed to capture some of smartphones Samsung released in the interim.
Apple filed the second case in February 2012. Judge Grewal scheduled the trial for March 2014 — 13 months and several Samsung smartphone generations later.
On Wednesday, faced with a request from Apple to replace one of the rapidly aging phones in the second suit with Samsung’s current flagship, the Galaxy S4, Grewel issued a curt denial:
Grewel’s ruling followed one issued in March by U.S. District Judge Lucy Koh that asked both sides to narrow their claims to 25 products and 25 infringement claims, the first of several steps by which she intended to reduce those numbers even further.
Given that Samsung has dozens of products on the market and Apple only a handful, this streamlining hurts Apple and, like every procedural delay, plays to Samsung’s strength.
As FOSS Patents‘ Florian Mueller wrote in March: