Analytical Technologies v. Darden Restaurants: Dismissed With Prejudice
Analytical Technologies, LLC asserted three patents covering restaurant customer data management systems against Darden Restaurants, Inc. in the Eastern District of Texas. The parties jointly moved to dismiss with prejudice after just 145 days — before substantive merits litigation, with each side bearing its own costs.
Three-patent restaurant data dispute ends in early prejudicial dismissal
Analytical Technologies, LLC filed this infringement action on May 1, 2024, in the U.S. District Court for the Eastern District of Texas, asserting three patents — US8799083B1, US9911164B1, and US8224700B2 — against Darden Restaurants, Inc., the operator of brands including Olive Garden and LongHorn Steakhouse. The patents relate to systems and methods for managing restaurant customer data elements, a technology domain that encompasses loyalty programs, reservation platforms, and customer analytics infrastructure.
On September 23, 2024 — just 145 days after filing — the court granted a joint motion to dismiss member case No. 2:24-cv-00305 with prejudice. The dismissal with prejudice is a final adjudication on the merits as a matter of law, meaning Analytical Technologies cannot reassert these three patents against Darden on the same claims in any future proceeding. Notably, the court directed each party to bear its own costs, expenses, and attorneys’ fees, suggesting a negotiated resolution rather than a one-sided capitulation.
The 145-day resolution timeline is notably short and is consistent with an early-stage settlement or licensing agreement reached before significant discovery or claim construction activity. The public record is silent on the financial terms, if any, of the underlying resolution. The verdict notes that a lead case — No. 2:24-cv-00445 — remains open, suggesting Analytical Technologies’ broader litigation campaign against other defendants continues. This pattern is typical of non-practicing entity enforcement strategies in E.D. Texas.
Filing to Dismissed with Prejudice in 145 days
145 days — resolved well before the typical E.D. Texas patent trial schedule
Dismissed with prejudice: what the joint motion means for both parties
Dismissal with prejudice is a final, claim-ending order
A dismissal with prejudice under Rule 41 of the Federal Rules of Civil Procedure operates as a final adjudication on the merits. The court’s order — entered on the parties’ joint motion — permanently extinguishes Analytical Technologies’ right to reassert these three patents against Darden on the same claims. The court retains no ongoing jurisdiction over this member case.
Permanent bar to re-filingAnalytical Technologies gives up its claims against Darden permanently
By agreeing to dismissal with prejudice, Analytical Technologies has permanently relinquished its infringement claims against Darden under US8799083B1, US9911164B1, and US8224700B2. This is a meaningful concession. However, the joint filing and mutual cost-bearing order suggest the parties may have reached a separate licensing or settlement arrangement — the terms of which are not reflected in the public record.
Claims extinguished; terms undisclosedDarden secures permanent protection from these three patent claims
Darden Restaurants emerges from this member case with full protection: the three asserted patents cannot be used against it again in respect of the same claims. The mutual cost-bearing arrangement means Darden avoided a fee award against the plaintiff, which is consistent with a negotiated exit. Darden’s counsel of record is not listed, suggesting it may have resolved the matter efficiently without protracted defence.
Darden shielded from reassertionLead case remains open — broader restaurant sector exposure persists
The court’s order preserves lead case No. 2:24-cv-00445 as active. This signals that Analytical Technologies’ enforcement campaign across the restaurant and hospitality sector is ongoing. Other restaurant operators deploying customer data management, loyalty, or CRM systems should monitor the lead case and assess their exposure to the same three patents, particularly given E.D. Texas’s plaintiff-friendly venue reputation.
Sector-wide risk not resolvedFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Analytical Technologies, LLC | Company | Patent assertion entity — holder of US8799083B1, US9911164B1, and US8224700B2Search in Eureka ↗ |
| Defendant | Darden Restaurants, Inc. | Company | Darden Restaurants, Inc. — major U.S. casual dining operator (Olive Garden, LongHorn Steakhouse)Search in Eureka ↗ |
| Plaintiff counsel | Randall T. Garteiser | Attorney | Counsel for Analytical Technologies, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Garteiser Honea PLLC | Law Firm | Representing Analytical Technologies, LLCSearch in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Texas Eastern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s order tracks the joint motion language precisely: all claims and causes of action are dismissed with prejudice, with each party bearing its own costs. The ‘with prejudice’ designation is legally dispositive — it forecloses any future action by Analytical Technologies against Darden on these claims. The mutual cost-bearing instruction, rather than a Rule 54(d) cost award to either side, is consistent with a negotiated resolution and suggests neither party was deemed to have prevailed in adversarial litigation. The order’s preservation of lead case No. 2:24-cv-00445 confirms this was a targeted, member-case resolution within a broader multi-defendant campaign.
US8799083B1, US9911164B1 & US8224700B2 — restaurant customer data systems
The three patents at issue — US8799083B1 (App. No. 13/534195), US9911164B1 (App. No. 14/316472), and US8224700B2 (App. No. 10/642841) — cover systems and methods for managing customer data in restaurant environments. The technology domain encompasses how dining operators collect, store, analyse, and act upon customer information — including preferences, visit history, loyalty data, and reservation details. US8224700B2, with its earlier application number, likely represents foundational IP in this family, with the later patents suggesting continuation or improvement filings built on the same inventive core.
For large restaurant groups operating loyalty programmes, CRM platforms, mobile ordering, or data-driven personalisation systems, these patents represent a material assertion risk. Darden Restaurants operates at significant scale with sophisticated customer data infrastructure — making it a commercially logical target. Any restaurant operator running comparable data management architecture should assess claim scope against current platform implementations, particularly given Analytical Technologies’ apparent multi-defendant strategy as evidenced by the open lead case.
Should you run an FTO against US8799083B1, US9911164B1, and US8224700B2?
Restaurant chains, hospitality technology vendors, and loyalty platform providers operating customer data management systems face direct exposure to the three patents asserted in this case. If your product collects, stores, or processes restaurant customer data elements — including CRM systems, loyalty engines, reservation platforms, or customer analytics tools — these patent claims are commercially relevant to your freedom to operate. The open lead case means active enforcement continues.
PatSnap Eureka’s FTO Search Agent enables R&D and IP teams to map claim language from US8799083B1, US9911164B1, and US8224700B2 against your specific product architecture, identify prior art that may narrow enforceability, and benchmark against litigation outcomes in analogous restaurant and hospitality tech cases. Early FTO analysis is substantially cheaper than responding to an E.D. Texas complaint.
Run a freedom-to-operate analysis on US8799083B1 to assess your product’s exposure
Run FTO in Eureka →Similar restaurant customer data patent cases in E.D. Texas
Cases involving restaurant customer data management patents in the Eastern District of Texas — especially NPE-driven multi-defendant campaigns asserting CRM and loyalty system IP.
What this case signals for the restaurant tech IP landscape
A 145-day resolution and open lead case suggest a targeted, multi-defendant campaign in restaurant customer data IP.
E.D. Texas remains a high-priority venue for restaurant tech patent assertions
The Eastern District of Texas continues to attract patent assertion entities targeting technology-dependent industries. Restaurant operators running proprietary customer data, loyalty, or reservation systems should treat this filing as a signal to audit their platforms against US8799083B1, US9911164B1, and US8224700B2 before receiving a complaint.
Joint dismissal with mutual cost-bearing strongly suggests settlement
When both parties agree to dismiss with prejudice and each bears its own fees, the pattern is consistent with a confidential licensing arrangement. The absence of any fee motion or litigation record of substantive filings reinforces this reading. Companies facing similar assertions should assess licensing economics early, before claim construction imposes significant legal spend.
Analytical v Darden — key questions answered
The dismissal with prejudice in case No. 2:24-cv-00305 permanently extinguishes Analytical Technologies’ infringement claims against Darden under US8799083B1, US9911164B1, and US8224700B2. Analytical Technologies cannot re-file the same claims against Darden in any future proceeding. The order was entered on the parties’ joint motion on September 23, 2024.
Analytical Technologies asserted three patents: US8799083B1 (App. No. 13/534195), US9911164B1 (App. No. 14/316472), and US8224700B2 (App. No. 10/642841). All three relate to systems and methods for managing restaurant customer data elements — a domain covering loyalty programmes, CRM platforms, and customer analytics infrastructure used by large dining operators.
The case resolved in 145 days — well before typical E.D. Texas claim construction or trial scheduling. The joint motion, mutual cost-bearing order, and absence of any substantive litigation record are consistent with an early-stage settlement or licensing arrangement. The public record does not disclose financial terms. This pattern is common in multi-defendant NPE campaigns where defendants assess licensing economics against projected litigation costs.
No. The court’s order explicitly directs the Clerk to close member case No. 2:24-cv-00305 while maintaining lead case No. 2:24-cv-00445 as open. Analytical Technologies’ broader enforcement campaign against other defendants continues. Any rulings in the lead case — including claim construction or merits decisions — could materially affect the remaining defendants’ exposure.
Analytical Technologies was represented by Randall T. Garteiser of Garteiser Honea PLLC, a Texas-based law firm known for patent enforcement work. No defendant counsel of record is listed in the available case data, which may indicate Darden resolved the matter through direct negotiation or early-stage representation not reflected in the public docket.
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