It appears that Taction Technology, Inc.’s litigation funders—i.e., Burford Capital and two special purpose vehicles associated with the litigation finance firm—have avoided sanctions threatened by a California magistrate judge, who last month queried whether the investors had violated their duty of candor to the court. However, the funders also appear less likely to see a return on their investment in Taction’s litigation against Apple, because this week, District Judge Todd W. Robinson of the Southern District of California granted Apple summary judgment of noninfringement.