A California magistrate judge has denied Netflix’s motion to compel discovery regarding third-party litigation funding (TPLF) provided to NPE plaintiff GoTV Streaming, LLC. Notably, by the time Netflix’s motion had been fully briefed, GoTV had disclosed the identity of its funder (which according to Magistrate Judge Shashi H. Kewalramani, the plaintiff “probably should have done sooner”) and also produced to the court, in camera, certain TPLF-related documents. In doing so, the NPE effectively rendered moot (per Judge Kewalramani) most of the arguments Netflix made in support of its discovery requests.

After a receiving over two dozen patents from Intellectual Discovery Co., Ltd. in mid-September, Carrum Technologies, LLC has asserted two of them in its first litigation campaign. The NPE sued BMW (1:18-cv-01645), Fiat Chrysler (1:18-cv-01646), and Ford (1:18-cv-01647) over the provision of vehicles with adaptive cruise control features that adjust automated driving behavior when the vehicle drives along a curved road. The two patents-in-suit, generally related to automated vehicle operation, are among nine originally issuing to Delphi that are now held by Carrum; the others in its new portfolio originally issued to Alcatel-Lucent, Agere Systems, Electronics and Telecommunications Research Institute (ETRI), or IBM.