The rise of third-party funding for patent litigation has motivated defendants to file discovery motions seeking identification of and communications with funders, which often prefer to operate in the background. Earlier in October, RPX reported on two recent decisions on such motions, with an update just last week on a development in one of those cases, filed by San Diego-based advertising provider Impact Engine sued Alphabet (Google) in June 2019 in the Southern District of California. District Judge Cathy Bencivengo ruled in Google’s favor on the issue of relevance but nevertheless denied the motion.