According to GI.biz, it was delayed after San Francisco district court judge Susan Illston questioned if it was appropriate to hold the case in California as Hotz's breaching of PS3 security was carried out in New Jersey.
The move is a blow to Sony, whose lawyers argued that Hotz revealed the hack via California-hosted services Twitter and YouTube. It has also been alleged that Hotz received fan donations from California-based site PayPal.
But judge Illston said: "If having a PayPal account were enough, then there would be personal jurisdiction in this court over everybody, and that just can't be right. That would mean the entire universe is subject to my jurisdiction, and that's a really hard concept for me to accept."
Sony stepped up its fight over recent PS3 exploits by filing for a restraining order against Hotz, the hacking group fail0verflow and numerous other individuals last week.
Alleging that those involved had violated the US Digital Millennium Copyright Act and the Computer Fraud and Abuse Act, the firm sought a restraining order asking that all PS3 circumvention tools be taken offline and related computers be impounded.
Responding to the charges, Hotz told BBC News: "I am a firm believer in digital rights. I would expect a company that prides itself on intellectual property to be well versed in the provisions of the law, so I am disappointed in Sony's current action."
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