See, e.g., AFL Telecomms. LLC v. SurplusEQ.com Inc., No. CV11-1086 PHX DGC, 2012 WL 2590557, at *2 (D. Ariz. July 5, 2012) (relying on a Third Circuit case cited by the Ninth Circuit in In re Citric to adopt a more expansive definition of "control"); see also Thales Avionics Inc. v. Matsushita Avionics Sys. Corp., No. SACV 04-454-JVS(MLGx), 2006 WL 6534230, at *4-5 (C.D. Cal. Mar. 8, 2006) (relying on case law outside the Ninth Circuit to consider the "nature of the relationship" between a subsidiary and its parent corporation to determine "control"); Choice-Intersil Microsystems, Inc. v. Agere Sys., Inc., 224 F.R.D. 471, 472-73 (N.D. Cal. 2004) (same). However, as duly noted by district courts within the Ninth Circuit, the Ninth Circuit has not expanded the definition of "control" to include a practical ability to obtain documents.