Applications in Internet Time v. Salesforce: CRM Patent Dispute Dismissed After 11+ Year Battle
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📋 Case Summary
| Case Name | Applications in Internet Time, LLC v. Salesforce.com, Inc. |
| Case Number | 3:13-cv-00628 (Nev. Dist. Court) |
| Court | Nevada District Court |
| Duration | Nov 2013 – Aug 2025 11 years 9 months |
| Outcome | Dismissal Without Prejudice (Defendant Counterclaims) |
| Patents at Issue | |
| Accused Products | Salesforce’s Force.com platform |
Case Overview
The Parties
⚖️ Plaintiff
Nevada-based patent assertion entity focused on internet and software technology intellectual property, reflecting a targeted assertion strategy common among non-practicing entities (NPEs).
🛡️ Defendant
Global leader in cloud-based CRM software headquartered in San Francisco. Its Force.com platform (now Salesforce Platform) is a widely adopted enterprise application development environment.
Patents at Issue
Two U.S. patents formed the basis of AIT’s infringement claims, both addressing foundational internet software architecture concepts directly relevant to cloud platform delivery models:
- • US 8,484,111 B2 — covering internet-based software integration and update methodologies
- • US 7,356,482 B2 — covering systems and methods related to internet-time application management
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The Verdict & Legal Analysis
Outcome
The case concluded through a stipulated voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(1)(A)(ii), specifically dismissing all of Salesforce’s counterclaims against AIT without prejudice. This procedural mechanism requires agreement of all parties and results in termination of the identified claims without a determination on the merits. No damages award, injunctive relief, or judicial finding of infringement or validity is reported.
Key Legal Issues
The stipulated dismissal structure most commonly reflects a negotiated settlement. The eleven-plus-year duration itself is analytically significant, suggesting procedural complexity including potential USPTO IPR proceedings, complex claim construction disputes over software method and system claims, and extensive fact and expert discovery. This case likely navigated significant § 101 eligibility challenges following *Alice Corp. v. CLS Bank International* (2014), given the timing of its filing and extended duration.
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⚠️ Freedom to Operate (FTO) Analysis
This case highlights critical IP risks in cloud software. Choose your next step:
📋 Understand This Case’s Impact
Learn about the specific risks and implications from this litigation in internet-time application management.
- View all patents related to internet-time applications
- See which companies are most active in cloud software patents
- Understand software claim construction patterns
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High Risk Area
Internet-Time Application Management
2 Key Patents
Involved in this dispute
Design-Around Options
Possible with careful claim analysis
✅ Key Takeaways
For Patent Attorneys & Litigators
Stipulated dismissals under Rule 41(a)(1)(A)(ii) in long-duration NPE cases frequently signal confidential licensing resolutions.
Search related case law →Software patents covering internet application methodologies face compounded § 101, § 102, and § 103 challenges in multi-year litigation.
Explore precedents →Nevada remains a viable venue for patent assertion entities with jurisdictional connections.
Analyze venue trends →Quinn Emanuel’s defense posture in this case offers a model for high-stakes cloud platform patent defense strategy.
Research law firms →For R&D Leaders & IP Professionals
Force.com-adjacent platform architectures warrant targeted FTO clearance for application integration features.
Start FTO analysis for my product →Building comprehensive prior art documentation during product development reduces long-term litigation exposure.
Try AI patent drafting →Multi-front defense combining IPR petitions with district court litigation remains effective in managing NPE assertions.
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