Earlier this month, RPX noted two recent decisions issued in patent cases and related to discoverability of litigation funding agreements and communications with third-party funders. This week saw a notable development in one of those cases, with a California judge ruling that while Impact Engine, Inc.’s agreement and communications with its third-party funder are relevant to the company’s patent infringement suit against Alphabet (Google) (3:19-cv-01301), they are also protected from discovery by the work product doctrine.