Adaptive Classification Technologies v. KLDiscovery Ontrack: Dismissed With Prejudice in 45 Days
Adaptive Classification Technologies LLC filed a patent infringement suit against e-discovery specialist KLDiscovery Ontrack LLC in the Western District of Texas, asserting US10445374B2 covering technology-assisted review systems. The plaintiff voluntarily dismissed all claims with prejudice just 45 days after filing — before the defendant had served any answer.
A 45-Day Patent Dispute Over e-Discovery AI Ends Before It Begins
On November 7, 2025, Adaptive Classification Technologies LLC filed a patent infringement action against KLDiscovery Ontrack LLC in the Western District of Texas before Judge Robert Pitman. The asserted patent, US10445374B2 (application no. US15/186360), covers systems and methods for conducting and terminating a technology-assisted review — a core workflow in modern e-discovery platforms. KLDiscovery Ontrack is a well-known provider of data recovery, e-discovery, and legal technology services, making it a commercially logical litigation target for a patent of this nature.
On December 19, 2025, just 42 days after filing, the plaintiff filed a notice of dismissal with prejudice under Federal Rule of Civil Procedure 41(a)(1)(A)(i). Because KLDiscovery Ontrack had not yet served an answer or motion for summary judgment, the notice was self-effectuating — no court order was required to end the case. The court formally closed the docket on December 22, 2025. A dismissal with prejudice is a final judgment on the merits, meaning Adaptive Classification Technologies is permanently barred from reasserting the same claims against KLDiscovery Ontrack on the same patent.
The 45-day duration is unusually short even for cases that settle pre-answer, and the with-prejudice designation — voluntarily chosen by the plaintiff — is notable. Without a settlement agreement in the public record, the precise driver of the dismissal remains unknown. The outcome is consistent with a confidential licence or settlement reached shortly after service, though it may equally reflect a strategic reassessment. The with-prejudice election forecloses any future assertion of US10445374B2 against KLDiscovery Ontrack, which typically signals that something of value was exchanged or that the plaintiff concluded further litigation was not commercially viable.
Filing to Voluntary dismissal in 45 days
45-day lifespan — well below the median district court patent case duration of 2+ years
Dismissed with prejudice: what the Rule 41 filing means for both parties
Rule 41(a)(1)(A)(i): self-effectuating dismissal, no court order needed
Under FRCP 41(a)(1)(A)(i), a plaintiff may dismiss an action by filing a notice before the opposing party serves an answer or motion for summary judgment. The dismissal is automatic — no judicial approval is required. Here, KLDiscovery had not yet responded, so Adaptive Classification Technologies’ notice immediately terminated the case. The court’s December 22 closure order was administrative confirmation, not a substantive ruling.
Pre-answer voluntary dismissalPlaintiff chose with-prejudice — a permanent bar on re-filing against this defendant
A Rule 41 pre-answer dismissal defaults to without prejudice unless the plaintiff specifies otherwise. Here, Adaptive Classification Technologies expressly dismissed with prejudice, converting the filing into a final judgment on the merits. This permanently bars the plaintiff from reasserting US10445374B2 against KLDiscovery Ontrack on the same claims. That deliberate election strongly suggests either a settlement with a licence grant, or a strategic decision that further enforcement against this defendant was not viable.
Final judgment on meritsKLDiscovery Ontrack exits with permanent protection from this patent claim
KLDiscovery Ontrack never filed an answer, incurred no adjudicated liability, and now holds a permanent bar against Adaptive Classification Technologies reasserting US10445374B2 on these claims. Whether that protection was secured via a licence or simply through the plaintiff’s withdrawal, the practical outcome is the same: KLDiscovery faces no further exposure from this plaintiff on this patent. The case closed with no public ruling on infringement or validity.
No liability, no merits rulingUS10445374B2 remains active — other e-discovery players should take note
The dismissal with prejudice resolves only the KLDiscovery Ontrack dispute. US10445374B2 remains in force and could be asserted against other technology-assisted review platform providers or e-discovery vendors. The short case duration and with-prejudice election suggest Adaptive Classification Technologies may be pursuing a systematic licensing strategy. Companies offering TAR or predictive coding workflows should assess their exposure to this patent’s claims independently.
Patent remains enforceableFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Adaptive Classification Technologies LLC | Company | Legal technology patent assertion entity — holder of US10445374B2 covering technology-assisted reviewSearch in Eureka ↗ |
| Defendant | KLDiscovery Ontrack, LLC | Company | KLDiscovery Ontrack, LLC — global e-discovery, data recovery, and legal technology services providerSearch in Eureka ↗ |
| Plaintiff counsel | Bradford J. Black | Attorney | Counsel for Adaptive Classification Technologies LLCSearch in Eureka ↗ |
| Plaintiff law firm | Bradford Black PC | Law Firm | Representing Adaptive Classification Technologies LLCSearch in Eureka ↗ |
| Presiding judge | Judge Robert Pitman | Judge | Texas Western District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s closure order confirms that Adaptive Classification Technologies filed a Rule 41(a)(1)(A)(i) notice of dismissal with prejudice on December 19, 2025, before KLDiscovery Ontrack served any responsive pleading. The with-prejudice designation is plaintiff-elected and operates as a final judgment on the merits, permanently barring re-assertion of the same claims against this defendant. No infringement or validity determination was made — the public record is silent on the substantive merits of the dispute.
US10445374B2 — Systems and methods for technology-assisted review
US10445374B2 (application US15/186360) protects systems and methods for conducting and terminating a technology-assisted review — a workflow central to e-discovery platforms that use machine learning or algorithmic classification to prioritise and categorise large document sets. The patent addresses both the execution of the review process and, notably, the conditions and logic by which such a review is concluded, which is a technically distinct and commercially significant aspect of TAR workflows. The application number suggests a mid-2010s filing, placing it squarely in the early commercial adoption period for predictive coding in legal practice.
Technology-assisted review has become a standard practice in large-scale litigation and regulatory investigation response. Major e-discovery platforms — including those offered by KLDiscovery, Relativity, Nuix, and others — rely on classification and review-termination logic that could overlap with the claims of this patent. For a patent covering TAR methodology to be asserted against a company of KLDiscovery Ontrack’s scale, and to resolve within 45 days, suggests the claim scope is commercially credible. Any vendor whose platform automates document review workflows should treat this patent as a live enforcement risk.
Should you run an FTO against US10445374B2?
If your organisation builds, licences, or deploys technology-assisted review tools — including predictive coding engines, continuous active learning platforms, or AI-driven document classification systems — US10445374B2 is directly relevant to your freedom to operate. The patent’s coverage of both the conduct and termination of TAR workflows means that standard e-discovery review pipelines may fall within its claims. Legal technology vendors, enterprise software providers integrating TAR into contract or compliance review, and law firms deploying in-house review platforms should all consider a formal FTO assessment before expanding their TAR product offerings.
PatSnap Eureka’s FTO Search Agent can map your product’s technical workflow against the independent and dependent claims of US10445374B2, identify prior art that may narrow the claims, surface any post-grant proceedings or reexamination history, and flag related continuation or family patents that could extend the assertion risk. An Eureka FTO analysis gives your R&D and legal teams a structured, evidence-based picture of where your TAR implementation stands relative to this patent’s scope — before a demand letter arrives.
Run a freedom-to-operate analysis on US10445374B2 to assess your product’s exposure
Run FTO in Eureka →Similar patent cases in e-discovery and technology-assisted review
Cases involving technology-assisted review and e-discovery software patents in the Western District of Texas and comparable federal venues.
What this case signals for the e-discovery and legal technology IP landscape
A 45-day lifecycle and a voluntary with-prejudice dismissal together suggest calculated licensing activity rather than contested litigation.
Pre-answer dismissals with prejudice often signal a rapid settlement or licence
When a plaintiff voluntarily dismisses with prejudice before the defendant even answers, the most commercially logical explanation is that the parties reached a confidential agreement quickly. The with-prejudice designation — which the plaintiff chooses deliberately — confirms finality and is consistent with a licence grant that the patent holder did not wish to litigate publicly.
US10445374B2 is still live: other TAR platform providers remain at risk
This dismissal does not extinguish the patent. Technology-assisted review is a crowded space — vendors offering predictive coding, continuous active learning, or AI-driven document review workflows should conduct a freedom-to-operate analysis against US10445374B2. The Western District of Texas remains an active venue for patent enforcement in software and legal tech.
Adaptive v KLDiscovery — key questions answered
The plaintiff filed a notice of voluntary dismissal with prejudice under FRCP 41(a)(1)(A)(i) before KLDiscovery served any answer. A with-prejudice dismissal operates as a final judgment on the merits, permanently barring Adaptive Classification Technologies from reasserting the same patent claims against KLDiscovery Ontrack. No infringement or validity ruling was issued.
US10445374B2 (application US15/186360) covers systems and methods for conducting and terminating a technology-assisted review — referring to algorithmic or machine-learning-driven document classification workflows used in e-discovery. The termination methodology aspect is a technically distinct feature that distinguishes it from broader document review patents.
The public record does not disclose the reason. However, a voluntary dismissal with prejudice filed before the defendant answers — just 45 days after the complaint — is consistent with a confidential settlement or licence agreement. The plaintiff’s deliberate election of the with-prejudice designation suggests something of value was likely exchanged, though this cannot be confirmed from the docket.
No. The dismissal only resolves claims between Adaptive Classification Technologies and KLDiscovery Ontrack. US10445374B2 remains in force and can be asserted against other parties in the e-discovery and technology-assisted review space. Other vendors should conduct independent freedom-to-operate analysis against this patent.
The case (1:25-cv-01802) was filed in the Western District of Texas and assigned to Judge Robert Pitman. The Western District of Texas is a frequently selected venue for patent infringement actions, particularly in technology-related disputes. The case closed on December 22, 2025 after the plaintiff’s self-effectuating Rule 41 notice.
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