As I previously reported, on August 19, the Supreme Court gave itself more time—until September 23—to grant or deny review in Cohen v. Health Net of California, Inc., no. S135104. Last week, on August 31, the Court issued a "grant and hold" order, granting review but deferring all further activity in the case until Mervyn's and Branick are resolved. So, we now know that it was, indeed, the Prop. 64 retroactivity issue that piqued the court's interest. This is the second case that the Supreme Court has taken up in which the Court of Appeal's Prop. 64 retroactivity discussion was unpublished.