California, United States of America
The following excerpt is from Ludwig v. Superior Court, 37 Cal.App.4th 8, 43 Cal.Rptr.2d 350 (Cal. App. 1995):
This principle was recognized at least sub silentio in Wilcox v. Superior Court, supra, 27 Cal.App.4th 809, in which the cross-defendant was not an actual party to the original unfair-competition action, but had apparently confined her activities to soliciting funds and providing support for the litigation and its aims. 10
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