A federal judge in the Eastern District of Pennsylvania defined the parameters of what is protected by the "Community of Interest" privilege (sometimes referred to as the "Joint Defense" privilege). On July 5, 2011, in King Drug v. Cephalon, Judge Mitchell S. Goldberg found that parties must be engaged in an "ongoing, joint, coordinated defense strategy" in order to avail themselves of the privilege. Although a joint defense agreement had been entered into, the judge found that there were no "actual concrete, tangible steps" taken to implement that joint defense and that the sharing of legal expenses indicated a business or commercial interest rather than a common legal interest. While this analysis was tied closely to the facts presented, the court's relatively narrow conception of the privilege provides guidance for parties seeking to establish the privilege under particular circumstances. Specifically, the King Drug decision demonstrates the importance of not just invoking the privilege at the outset of coordinated multiparty activity, but thereafter effectuating this intent by creating an ongoing "context" indicative of a genuine, coordinated legal defense.