Only to a minor extent and usually only when the client has a large number of low equity properties. We still suggest separate LLCs rather than a Series LLC because the Series LLC has not been fully tested as to whether the courts will isolate liabilities between cells. The bigger practical problem is that most lawyers, banks and title companies are unfamiliar with the Series LLC. This adds to the complexity of completing real estate transactions. Still, given time, we believe the Series LLC will grow in popularity.