You are correct that (per what I read as well) the SEC does not specify court rulings and such as mandatory reportable events.
However, I doubt any reasonable person would regard the milestone event that occurred last Wednesday as "Not Material" to the status and future of this investment.
Also, note that the 7/24/12 PR which announced the MH "victory" in NorCal was followed up by an 8-K - though it was more about ITC actions initiated, with the MH info thrown in.
FWIW,
SGE