AIT v. Salesforce: Federal Circuit Reverses-in-Part, Vacates-in-Part
Applications in Internet Time LLC challenged Salesforce over two CRM-related patents covering its Force.com and Salesforce1 platforms. After 337 days before the Federal Circuit, the court issued a split ruling — reversing in part, vacating in part, and remanding — signalling that the lower tribunal’s analysis did not fully survive appellate scrutiny.
Federal Circuit splits the ruling — victory for AIT on at least some claims
Applications in Internet Time LLC (AIT) appealed against Salesforce, Inc. in case 24-1133 before the United States Court of Appeals for the Federal Circuit, filed 8 November 2023 and closed 10 October 2024. The dispute centres on two patents — US8484111B2 and US7356482B2 — asserted against Salesforce’s Force.com platform and the Salesforce1 mobile platform, both core to Salesforce’s cloud-based CRM product stack.
The Federal Circuit issued a REVERSED-IN-PART, VACATED-IN-PART, AND REMANDED decision, with the appeal also dismissed in part on procedural grounds. This compound outcome means: portions of the lower ruling were found to contain reversible legal error (reversed), other portions were nullified without a final merits determination and sent back for reconsideration (vacated), and at least one aspect of the appeal was dismissed outright without reaching the merits.
The 337-day resolution is consistent with a moderately contested Federal Circuit appeal. The split nature of the ruling suggests the lower tribunal — likely the Patent Trial and Appeal Board in an IPR context, given AIT’s prior litigation history with Salesforce — reached conclusions that were legally sound on some claims but deficient on others. The public record does not disclose the precise claims affected by each disposition, leaving the scope of remand analytically uncertain.
Filing to Appeal Dismissed in Part in 337 days
337-day appeal — typical Federal Circuit patent appeals run 12–18 months
Federal Circuit reverses and vacates: what the split ruling means for both parties
What ‘Reversed-in-Part, Vacated-in-Part’ means at the Federal Circuit
A reversal means the appellate court found reversible legal error in that portion of the lower decision — the outcome on those issues is changed in AIT’s favour. A vacatur means the lower ruling is nullified on those points but without a final merits ruling; the matter is sent back for fresh analysis. A partial dismissal means certain appeal grounds were not considered on the merits. Together, the ruling substantially destabilises Salesforce’s prior win.
Multi-limb appellate dispositionAIT partially prevails — reversed claims revive enforcement leverage
For Applications in Internet Time, the reversal on at least some issues represents a meaningful appellate win. Claims or grounds on which the lower tribunal ruled against AIT and which the Federal Circuit has now reversed are effectively decided in AIT’s favour. The vacated portions keep other issues alive through remand. AIT retains the ability to press its patent rights over Force.com and Salesforce1 on remand, consistent with the Federal Circuit’s guidance.
Partial reversal favours patent holderSalesforce loses its prior protection on reversed and vacated grounds
Salesforce’s position is weakened on the reversed portions — the Federal Circuit found the lower ruling in its favour to have been legally erroneous on those issues. On vacated portions, Salesforce must re-litigate before the lower tribunal without the benefit of its prior ruling. Only the dismissed portions of the appeal leave Salesforce with any clean win. The Quinn Emanuel team will need to mount a fresh defence strategy on remand covering both US8484111B2 and US7356482B2.
Remand exposure on two patentsForce.com and Salesforce1 face renewed validity and infringement risk
The Federal Circuit’s willingness to reverse and vacate — rather than simply affirm — suggests the asserted patents carry more weight than the lower proceeding credited. For enterprise software vendors building CRM, workflow automation, or platform-as-a-service products that overlap with Salesforce’s architecture, this ruling suggests US8484111B2 and US7356482B2 remain live threats. Competitors and customers relying on Force.com-adjacent technologies should treat FTO clearance as unresolved until remand concludes.
Live patent risk — remand pendingFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Applications in Internet Time LLC | Company | Internet Time-based CRM technology licensor — holder of US8484111B2 and US7356482B2Search in Eureka ↗ |
| Defendant | SALESFORCE, INC. | Company | Salesforce, Inc. — global cloud CRM provider, developer of Force.com and Salesforce1Search in Eureka ↗ |
| Plaintiff counsel | Andrea Pacelli | Attorney | Counsel for Applications in Internet Time LLCSearch in Eureka ↗ |
| Plaintiff counsel | Charles Wizenfeld | Attorney | Counsel for Applications in Internet Time LLCSearch in Eureka ↗ |
| Plaintiff counsel | Michael DeVincenzo | Attorney | Counsel for Applications in Internet Time LLCSearch in Eureka ↗ |
| Plaintiff counsel | Steven C. Sereboff | Attorney | Counsel for Applications in Internet Time LLCSearch in Eureka ↗ |
| Plaintiff law firm | King & Wood Mallesons LLP | Law Firm | Representing Applications in Internet Time LLCSearch in Eureka ↗ |
| Plaintiff law firm | SoCal IP Law Group LLP | Law Firm | Representing Applications in Internet Time LLCSearch in Eureka ↗ |
| Defendant counsel | Brian C. Cannon | Attorney | Counsel for SALESFORCE, INC.Search in Eureka ↗ |
| Defendant counsel | Gavin Snyder | Attorney | Counsel for SALESFORCE, INC.Search in Eureka ↗ |
| Defendant counsel | Kevin P. B. Johnson | Attorney | Counsel for SALESFORCE, INC.Search in Eureka ↗ |
| Defendant counsel | Ognjen Zivojnovic | Attorney | Counsel for SALESFORCE, INC.Search in Eureka ↗ |
| Defendant counsel | Ray Robert Zado | Attorney | Counsel for SALESFORCE, INC.Search in Eureka ↗ |
| Defendant counsel | Sam Stephen Stake | Attorney | Counsel for SALESFORCE, INC.Search in Eureka ↗ |
| Defendant law firm | Quinn Emanuel Urquhart & Sullivan, LLP | Law Firm | Representing SALESFORCE, INC.Search in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Court of Appeals for the Federal CircuitSearch in Eureka ↗ |
Official order — verbatim text
The Federal Circuit’s compound disposition — reversed-in-part, vacated-in-part, and remanded, with partial dismissal — is analytically significant. Under Federal Circuit review, reversal requires the court to identify a specific legal error that compels a different outcome; vacatur without reversal typically indicates procedural or evidentiary deficiency requiring fresh analysis below. The partial dismissal suggests at least one appeal ground was jurisdictionally or procedurally barred. Together, this ruling substantially unsettles the lower proceeding’s findings on US8484111B2 and US7356482B2, and the scope of the remand will determine the ultimate commercial and legal exposure for Salesforce’s platform products.
US8484111B2 & US7356482B2 — CRM platform integration and data synchronisation
US8484111B2 (application no. US12/912375) and US7356482B2 (application no. US09/797488) both sit within the technical domain of internet-based application integration — specifically, methods and systems for synchronising, managing, and updating data across CRM and enterprise software platforms in real time. US7356482B2’s earlier application number suggests it is the foundational patent in this family, with US8484111B2 representing a later continuation or related filing that extends or refines the claimed technology.
These patents are strategically significant because they sit at the architectural core of cloud CRM platform design — precisely the space Salesforce dominates with Force.com and Salesforce1. The fact that AIT successfully obtained a partial reversal at the Federal Circuit suggests the patents retain meaningful claim scope that the lower tribunal undervalued. For any enterprise software vendor, systems integrator, or SaaS platform developer working within Salesforce-adjacent CRM architectures, these patents represent a non-trivial infringement vector that remains live pending remand.
Should your team run an FTO against US8484111B2 and US7356482B2?
If your product or platform involves CRM data synchronisation, workflow automation, or integration layers that interact with cloud-based enterprise applications in a manner architecturally similar to Salesforce Force.com or Salesforce1, these patents are directly relevant to your FTO scope. The Federal Circuit’s partial reversal means claim validity and enforceability are not settled — but the patents are alive, and the remand outcome could broaden their practical reach.
PatSnap Eureka’s FTO Search Agent allows R&D and IP teams to map the full claim landscape of US8484111B2 and US7356482B2 against your product architecture, identify freedom-to-operate gaps, and monitor the remand docket for new claim construction rulings. Given the live proceedings, setting up a real-time patent watch on both numbers and the AIT portfolio is strongly advisable before any new product launch in the CRM platform integration space.
Run a freedom-to-operate analysis on US8484111B2 to assess your product’s exposure
Run FTO in Eureka →Similar Federal Circuit appeals in CRM and cloud platform patent disputes
Explore comparable Federal Circuit appeal decisions involving CRM platform patents, PTAB reversals in enterprise software, and cloud integration IP disputes analogous to AIT v. Salesforce.
What this case signals for the enterprise CRM and cloud platform IP landscape
A Federal Circuit split ruling against Salesforce on foundational CRM platform patents has implications well beyond this single dispute.
Split Federal Circuit rulings signal claim-level vulnerability in platform patents
When the Federal Circuit reverses in part and vacates in part, it typically signals that the lower tribunal applied inconsistent or legally deficient standards across different claim groups. For patent holders in the enterprise software space, this outcome is a reminder that claim-by-claim analysis at the IPR or PTAB level is worth contesting vigorously on appeal.
Salesforce’s Force.com and Salesforce1 carry unresolved FTO exposure
Until the remand proceedings conclude, both US8484111B2 and US7356482B2 must be treated as potentially enforceable against Salesforce’s core platform architecture. Companies building integrations, ISV products, or competitive offerings on similar CRM platform paradigms should refresh FTO analyses to account for the revived claim scope these patents may carry post-reversal.
Applications v SALESFORCE — key questions answered
The Federal Circuit issued a reversed-in-part, vacated-in-part, and remanded decision on 10 October 2024, with the appeal also dismissed in part. This means some lower tribunal findings in Salesforce’s favour were overturned, others were nullified and sent back for re-analysis, and at least one ground was dismissed without a merits ruling. The case concerns US8484111B2 and US7356482B2 asserted against Salesforce’s Force.com and Salesforce1 platforms.
AIT asserts two patents: US8484111B2 (application US12/912375) and US7356482B2 (application US09/797488). Both relate to internet-based CRM data integration and synchronisation technology. They are asserted against Salesforce’s Force.com development platform and the Salesforce1 mobile platform.
Salesforce loses the protection of the lower tribunal’s prior ruling on both the reversed and vacated portions. On reversed issues, the Federal Circuit has found legal error and the outcome changes against Salesforce. On vacated issues, the matter returns to the lower forum for fresh analysis without the benefit of the prior ruling. Salesforce retains a clean outcome only on the portions of the appeal that were dismissed without merits consideration.
The case returns to the lower tribunal — consistent with AIT’s prior PTAB history, likely the Patent Trial and Appeal Board — for proceedings consistent with the Federal Circuit’s guidance. The remand tribunal must re-examine the vacated issues under the correct legal standard and give effect to the reversals. The scope of those proceedings will determine whether Salesforce faces renewed invalidity risk on US8484111B2 and US7356482B2, or whether AIT secures confirmed enforceability.
The Federal Circuit’s reversal and vacatur — rather than an affirmance — suggests US8484111B2 and US7356482B2 retain live enforceability potential. The lower ruling against AIT has been at least partially undone. However, the precise claim scope and final enforceability determination will depend on remand proceedings. Companies with products architecturally similar to Force.com should not treat the patents as cleared until remand concludes.
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