Bataan Licensing v. Donaldson Company — Voluntarily Dismissed After 98 Days
Bataan Licensing LLC filed a patent infringement action against Donaldson Company Inc. in the Northern District of Illinois asserting US7423982B2, directed to adaptive communication modes. The case resolved in just 98 days when Bataan voluntarily dismissed — before Donaldson served an answer or summary judgment motion.
A rapid pre-answer dismissal in a patent assertion over adaptive communications
On 27 September 2022, Bataan Licensing LLC — a licensing entity holding US7423982B2 — filed an infringement action against Donaldson Company Inc. in the U.S. District Court for the Northern District of Illinois (Case No. 3:22-cv-50402). The asserted patent covers adaptive communication modes technology. Donaldson Company is a global filtration and industrial technology manufacturer.
The recorded basis of termination is Voluntary dismissal. The docket order reflects that Bataan Licensing filed a Notice of Voluntary Dismissal with Prejudice pursuant to Federal Rule of Civil Procedure 41(a)(1), citing that no answer or motion for summary judgment had yet been served by Donaldson. The case closed on 3 January 2023. The specific terms underlying the dismissal are not disclosed in the available record.
The 98-day duration from filing to closure is notably short, and the dismissal occurred before Donaldson filed any responsive pleading — the earliest procedural window available under Rule 41(a)(1). What drove Bataan to dismiss at this pre-answer stage, and whether any commercial arrangement was reached between the parties, is not disclosed in the available public record.
See Complete Case & Patent Analysis →Filing to Voluntary dismissal in 98 days
98 days — resolved before defendant's first responsive pleading
US7423982B2 — adaptive communication modes technology
Any organisation developing products that incorporate adaptive or dynamic communication mode selection — including industrial IoT devices, connected filtration systems, network-aware embedded hardware, or multi-protocol communication platforms — should assess their exposure to US7423982B2. This case produced no invalidity finding and no claim construction order, meaning the patent's enforceability is wholly intact from a litigation-outcome standpoint.
Official order — verbatim text
The docket records Bataan Licensing's invocation of Rule 41(a)(1) to unilaterally dismiss the action, citing that Donaldson had not yet served an answer or motion for summary judgment. No substantive ruling on infringement, claim scope, or patent validity was issued by the court. The dismissal reflects a plaintiff-controlled exit at the earliest available procedural juncture, leaving the merits entirely unadjudicated.
Voluntarily dismissed: what the Rule 41(a)(1) filing means for both parties
Rule 41(a)(1): plaintiff-initiated dismissal without court order
Under Federal Rule of Civil Procedure 41(a)(1), a plaintiff may dismiss an action as of right — without a court order — by filing a notice of dismissal before the defendant has served an answer or a motion for summary judgment. This is the earliest and most unilateral exit mechanism available in U.S. federal litigation. Bataan invoked this rule, meaning the court itself made no substantive ruling on the merits.
Pre-answer voluntary dismissalWith or without prejudice? The recorded basis is silent on the distinction
The basis of termination is recorded as 'Voluntary dismissal' without specifying with or without prejudice. The docket order text states the dismissal was filed 'with prejudice,' which would bar Bataan from re-filing the same infringement claims against Donaldson. However, the public record does not reconcile these two characterisations. Readers should treat the distinction as unresolved based on available data.
Prejudice status unconfirmedBataan exits before any validity or infringement ruling
By dismissing before Donaldson served a responsive pleading, Bataan avoided any court ruling on infringement, claim construction, or patent validity. US7423982B2 has received no adverse judicial finding from this litigation. Whether Bataan retains the ability to assert this patent against other defendants depends on terms not visible in the public record.
No merits adjudicationDonaldson escapes without filing a single pleading
Donaldson Company was never required to serve an answer, assert invalidity defences, or file dispositive motions. The case ended on the plaintiff's initiative before any substantive defence costs escalated. Donaldson faces no adverse judgment from this proceeding. Whether any commercial arrangement accompanied the dismissal is not disclosed in the available record.
No adverse judgmentFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Bataan Licensing, LLC | Company | Patent licensing entity — holder of US7423982B2 (adaptive communication modes)Search in Eureka ↗ |
| Defendant | Donaldson Company, Inc. | Company | Donaldson Company Inc. — global filtration and industrial technology manufacturerSearch in Eureka ↗ |
| Plaintiff counsel | David Randolph Bennett | Attorney | Counsel for Bataan Licensing, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Steven G. Kalberg | Attorney | Counsel for Bataan Licensing, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Direction IP law | Law Firm | Representing Bataan Licensing, LLCSearch in Eureka ↗ |
| Defendant counsel | Mackenzie Marie Martin | Attorney | Counsel for Donaldson Company, Inc.Search in Eureka ↗ |
| Defendant counsel | Shima S. Roy | Attorney | Counsel for Donaldson Company, Inc.Search in Eureka ↗ |
| Defendant law firm | Baker & McKenzie LLP (Chicago) | Law Firm | Representing Donaldson Company, Inc.Search in Eureka ↗ |
| Defendant law firm | Baker McKenzie LLP | Law Firm | Representing Donaldson Company, Inc.Search in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Illinois Northern District CourtSearch in Eureka ↗ |
R&D signals in adaptive communications and network protocol IP
Forward-looking patent and R&D intelligence derived from the Bataan Licensing v. Donaldson case — covering portfolio activity, technology filing trends, and white space in adaptive communications.
Bataan Licensing's assertion portfolio in communications technology
Bataan Licensing's assertion of US7423982B2 against Donaldson suggests active monetisation of communications IP. Mapping the full set of patents held or previously assigned to Bataan in the adaptive communications domain can reveal the breadth of their licensing campaign and which technology sub-areas remain under active enforcement pressure.
PAE portfolio mappingFiling trends in adaptive and dynamic communication mode selection
The adaptive communication modes space — covering context-aware protocol switching, multi-mode network selection, and dynamic connectivity management — has seen growing patent activity as industrial IoT and connected device markets expand. Tracking filing trends in this domain can identify which assignees are building defensive or offensive positions ahead of the next assertion wave.
Comms IP filing trendsDonaldson Company's connectivity and communications patent activity
Donaldson Company is primarily known for filtration technology, but its connected industrial product lines may intersect with communications protocol patents. Reviewing Donaldson's own patent filings in network communications and embedded connectivity can reveal whether the company is building defensive IP assets to insulate against future assertions in this domain.
Donaldson IP defence postureUnder-patented adjacent areas near US7423982B2's claim scope
Adjacent to adaptive communication mode selection lie innovation opportunities in AI-driven protocol optimisation, edge-device communication management, and energy-aware mode switching for industrial hardware. These sub-areas may carry lower prior art density relative to the core adaptive communications space, presenting white-space opportunities for R&D teams and IP strategists building defensive portfolios.
Adjacent IP white spaceSimilar patent cases: adaptive communications & N.D. Illinois assertions
Cases involving adaptive communication mode patents and patent assertion entity activity in the Northern District of Illinois — relevant for benchmarking litigation strategy and resolution timelines.
What this case signals for the adaptive communications IP landscape
A pre-answer voluntary dismissal by a licensing entity signals patterns worth monitoring for IP strategists in the communications technology sector.
Pre-answer dismissals by licensing entities often signal a portfolio-level strategy
When a patent assertion entity dismisses before the defendant files any pleading, it typically suggests the litigation served a different commercial purpose — or that early-stage diligence shifted the calculus. Companies operating in adaptive communications and network protocol technology should monitor Bataan Licensing's broader portfolio activity for further assertion signals.
US7423982B2 received no invalidity or non-infringement ruling here
Because the case closed without any substantive court order, the enforceability of US7423982B2 is unchanged by this proceeding. Organisations whose products involve adaptive communication modes should assess their exposure independently — this dismissal provides no safe harbour against future assertion of the patent.
Bataan v Donaldson — key questions answered
Bataan Licensing LLC asserted US7423982B2 (application number US10/237299), a patent covering adaptive communication modes technology. This was the sole patent-in-suit in the Northern District of Illinois infringement action against Donaldson Company Inc.
The recorded basis of termination is Voluntary dismissal. The docket order states that Bataan Licensing filed a Notice of Voluntary Dismissal with Prejudice under Federal Rule of Civil Procedure 41(a)(1), before Donaldson had served an answer or motion for summary judgment. The case closed on 3 January 2023, 98 days after filing. The specific terms are not disclosed in the available record.
A Rule 41(a)(1) dismissal is a plaintiff-initiated procedural exit that produces no court ruling on patent validity, claim scope, or infringement. US7423982B2 received no adverse judicial finding in this case. The patent's enforceability is unchanged by this proceeding, and it remains a live asset for future assertion by its holder.
The case closed 98 days after filing, before Donaldson served any responsive pleading. The public record does not disclose the reason for the early dismissal. Whether a commercial arrangement was reached between the parties, or whether Bataan made a strategic decision to exit, is not stated in any available docket entry.
Because this case produced no invalidity finding or claim construction order, US7423982B2 remains enforceable on its face. Organisations developing products involving adaptive or dynamic communication mode selection — including industrial IoT hardware, multi-protocol connectivity systems, or connected industrial equipment — should consider conducting a freedom-to-operate analysis against this patent's claims.
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