Litigation affiliated with IP Valuation Partners LLC shows no signs of abating in 2016. Two Texas NPEs with managing member Jonathan Szarzynski, a principal of IP Valuation, have filed suit over the past week. PositionTech LLC has turned its solo case against The Walt Disney Company into a campaign with a second filing asserting the same two information management patents. Meanwhile, eHierarchy LLC has filed a case against Microsoft (2:16-cv-00564) over data access and display patents that issued to their named inventor, an apparent, one-time Microsoft employee.