AutoScribe Corp. v. PCI Booking Limited — Dismissed Without Prejudice in 68 Days
AutoScribe Corp. filed a patent infringement action against PCI Booking Limited in the Southern District of Texas, asserting US11620621B2 against PCI Booking’s Orchestra and PCI Shield products. The plaintiff voluntarily dismissed all claims without prejudice just 68 days after filing, leaving the door open to refile.
Swift voluntary dismissal in a payment security patent dispute
On March 22, 2024, AutoScribe Corp. filed a patent infringement action against PCI Booking Limited in the United States District Court for the Southern District of Texas (Case No. 3:24-cv-00081), before Chief Judge Jeffrey V. Brown. The complaint asserted US11620621B2, a patent in the payment data security space, against PCI Booking’s Orchestra and PCI Shield product lines.
On May 28, 2024, AutoScribe filed a notice of voluntary dismissal pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i), before any defendant answer or motion for summary judgment had been served. The court ordered all claims dismissed without prejudice on May 29, 2024, with each party directed to bear its own attorneys’ fees and costs. No substantive rulings on the merits were issued.
The resolution in just 68 days suggests the dispute may have reached an early commercial agreement, or that AutoScribe reassessed litigation strategy before significant procedural milestones were reached. Because the dismissal is without prejudice, the public record is silent on whether any licensing terms were agreed — the possibility of refiling formally remains open.
Filing to resolution in 68 days
Case resolved in 68 days — well below median district court patent case duration
Voluntary dismissal without prejudice — what this means for both parties
Rule 41(a)(1)(A)(i) — plaintiff’s right to dismiss before answer
Federal Rule of Civil Procedure 41(a)(1)(A)(i) allows a plaintiff to dismiss its own case without a court order, provided the defendant has not yet served an answer or a motion for summary judgment. AutoScribe exercised this right on day 67, indicating PCI Booking had not yet formally responded to the complaint at that point.
No court order requiredWithout prejudice — the refiling option formally remains open
A dismissal without prejudice means AutoScribe is not barred from reasserting US11620621B2 against PCI Booking in a future action. This contrasts with a dismissal with prejudice, which would extinguish the claims entirely. Whether the parties reached a private settlement or licensing arrangement is not disclosed in the public record — the without-prejudice designation alone does not confirm or deny any commercial resolution.
Refiling remains possibleEach party bears its own costs — no fee-shifting applied
The court’s order directed each party to bear its own attorneys’ fees and costs. Under U.S. patent litigation norms, fee-shifting to the opposing party typically requires a finding of an ‘exceptional case’ under 35 U.S.C. § 285. The absence of any such ruling here is consistent with the early, pre-answer stage of proceedings and does not reflect a merits assessment by the court.
No § 285 fee awardEarly exit signals: settlement, licence, or reassessed strategy
Cases dismissed this quickly — before any substantive filings from the defendant — typically suggest one of three scenarios: a private licensing or settlement agreement reached outside court, a strategic decision by the plaintiff to refile in a different venue, or a reassessment of claim strength following initial research. The public record does not disclose which of these applies here.
Pre-answer resolutionFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | AutoScribe Corp. | Company | Payment data security IP holder — asserting US11620621B2 against hospitality payment productsSearch in Eureka ↗ |
| Defendant | PCI Booking Limited | Company | PCI Booking Limited — provider of Orchestra and PCI Shield payment security solutionsSearch in Eureka ↗ |
| Plaintiff counsel | Angela Marie Peterson | Attorney | Counsel for AutoScribe Corp.Search in Eureka ↗ |
| Plaintiff counsel | Chun Deng | Attorney | Counsel for AutoScribe Corp.Search in Eureka ↗ |
| Plaintiff counsel | Colin Baker Phillips | Attorney | Counsel for AutoScribe Corp.Search in Eureka ↗ |
| Plaintiff counsel | Jason S. Mcmanis | Attorney | Counsel for AutoScribe Corp.Search in Eureka ↗ |
| Presiding judge | Judge Jeffrey V Brown | Chief Judge | Texas Southern District Court — Chief JudgeSearch in Eureka ↗ |
Stipulation of dismissal — official text
The court’s order reflects a ministerial confirmation of AutoScribe’s Rule 41(a)(1)(A)(i) notice rather than any substantive merits adjudication. The ‘dismissed without prejudice’ language preserves AutoScribe’s full rights to refile, while the mutual cost-bearing instruction is standard for pre-answer voluntary dismissals. No findings on validity, infringement, or claim construction were made, meaning the patent’s legal strength is entirely unaffected by this outcome.
US11620621B2 — Payment Data Security and Tokenisation Technology
US11620621B2 (application number US16/535424) is a granted US patent in the payment data security domain, asserted by AutoScribe Corp. against PCI Booking Limited’s Orchestra and PCI Shield products. The patent likely addresses methods or systems for securing payment card data — a technically active area encompassing tokenisation, PCI-DSS compliance workflows, and gateway-level data handling. The application number series suggests a filing trajectory consistent with late-2010s payment security innovation cycles.
In the hospitality and travel technology sector, PCI-compliant payment orchestration is a high-value infrastructure layer. Patents covering novel approaches to isolating or transforming cardholder data attract enforcement interest precisely because the addressable market — hotels, OTAs, booking platforms — is large and the switching cost of core payment infrastructure is high. AutoScribe’s decision to assert this patent against PCI Booking’s flagship products suggests the claims are considered commercially relevant to current product architectures.
Should your product team run an FTO against US11620621B2?
If your organisation develops or sells payment tokenisation, PCI-scoped gateway orchestration, or hotel payment security infrastructure, US11620621B2 warrants a formal freedom-to-operate assessment. AutoScribe has demonstrated willingness to litigate, and the without-prejudice dismissal in this case does not extinguish the patent’s enforceability. Product teams building Orchestra-adjacent or PCI Shield-comparable functionality are the clearest risk population.
PatSnap Eureka’s FTO Search Agent can map the independent claims of US11620621B2 against your product’s technical specification, surface relevant prior art that could support an invalidity argument, and flag any continuation or family member patents that may extend the claim scope. Ongoing claim monitoring will alert your team if AutoScribe prosecutes continuation applications that could broaden coverage further.
Run a freedom-to-operate analysis on US11620621B2 to assess your product’s exposure
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What this case signals for the payment security IP landscape
A fast dismissal without prejudice in a payment security patent case carries distinct signals for competitors, licensees, and FTO analysts.
US11620621B2 remains fully enforceable — AutoScribe can refile
The without-prejudice dismissal leaves US11620621B2 legally intact and available for reassertion. Companies offering payment tokenisation, PCI-compliance, or hotel payment gateway products should treat this patent as an active enforcement risk, not a resolved matter. AutoScribe’s willingness to initiate litigation signals a broader enforcement posture.
Pre-answer dismissals often mask private commercial outcomes
When plaintiffs dismiss under Rule 41(a)(1)(A)(i) before the defendant has even answered, it frequently reflects a resolution reached privately — whether a licence, co-existence agreement, or settlement. Competitors in the hospitality payment technology sector should monitor whether AutoScribe pursues similar actions against other Orchestra or PCI Shield-adjacent products.
AutoScribe v PCI — key questions answered
AutoScribe Corp. voluntarily dismissed all claims against PCI Booking Limited without prejudice on May 28, 2024, just 68 days after filing. The dismissal was filed under Fed. R. Civ. P. 41(a)(1)(A)(i), before PCI Booking had served an answer. Each party was ordered to bear its own attorneys’ fees and costs. No merits rulings were issued.
AutoScribe asserted US11620621B2 (application number US16/535424), a payment data security patent, against PCI Booking’s Orchestra and PCI Shield products. The case was filed in the Southern District of Texas on March 22, 2024.
Dismissed without prejudice means AutoScribe Corp. retains the legal right to refile the same infringement claims against PCI Booking in the future. It does not bar the action on the merits. This contrasts with dismissal with prejudice, which would permanently extinguish the claims. Whether any private settlement or licence was reached is not disclosed in the public record.
The case closed in 68 days, before PCI Booking filed any answer or substantive response. Early voluntary dismissals under Rule 41(a)(1)(A)(i) typically suggest a private resolution — such as a licensing agreement or commercial settlement — or a strategic decision by the plaintiff to reassess the litigation approach. The public record does not confirm which factor applied here.
No. Because the case was dismissed before any substantive court rulings, there are no findings on validity, infringement, or claim construction. US11620621B2 remains a granted, enforceable US patent. The dismissal without prejudice has no bearing on the patent’s legal strength or AutoScribe’s ability to assert it against other parties.
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