Justice Eileen Bransten

Galen Technology Solutions moved to appoint a receiver to take possession of and sell various assets of VectorMax in satisfaction of Galen’s judgment against it. Nonparty Torres moved to intervene to protect his interests as a prior judgment creditor. Galen sued VectorMax alleging it had an outstanding balance from a judgment Galen obtained in 2009. The court found Galen failed to demonstrate a special reason to appoint a receiver, noting it failed to show the receivership would increase the likelihood of satisifaction. Instead, it noted VectorMax reasonably claimed it was less likely to pay Galen’s judgment if a receiver was appointed as a sale of some patents may lead to VectorMax’s insolvency. VectorMax claimed that selling four of its patents would severely impede its ability to conduct its business, and the court noted Galen did not refute such assertions. Galen also failed to show a receivership was necessary for recovery of the remainder of its judgment award. Therefore, the court denied Galen’s motion. Also, while Torres met the standards for permissive intervention, as the court denied Galen’s motion to appoint a receiver, the reason for Torres’ proposed intervention was moot and thus denied.