CheckWizard LLC v. JPMorgan Chase Bank: Dismissed With Prejudice in 6 Days
CheckWizard LLC filed a patent infringement action against JPMorgan Chase Bank in the Eastern District of Texas, asserting US10140514B1 covering mobile image capture and time-limited sharing. The case collapsed in just 6 days when CheckWizard voluntarily dismissed with prejudice under Rule 41(a)(1)(A)(i) — permanently surrendering its right to re-file the same claim.
A 6-Day Patent Assertion Against JPMorgan That Ended Permanently
On August 21, 2025, CheckWizard LLC filed a patent infringement complaint against JPMorgan Chase Bank, N.A. in the Eastern District of Texas (Case No. 2:25-cv-00829), before Judge Rodney Gilstrap. The asserted patent, US10140514B1, covers technology for capturing and sharing images with mobile device users, including for a limited duration of time — a functionality relevant to mobile banking and financial app ecosystems.
Just six days after filing, on August 27, 2025, CheckWizard filed a Notice of Voluntary Dismissal with Prejudice under Federal Rule of Civil Procedure 41(a)(1)(A)(i). Judge Gilstrap accepted the notice, formally dismissing all claims with prejudice. Crucially, JPMorgan had not yet filed an answer or a summary judgment motion, meaning CheckWizard was entitled to dismiss unilaterally — but chose to do so permanently, foreclosing any future assertion of the same claims against JPMorgan.
A dismissal with prejudice filed before the defendant has even responded is highly unusual and typically signals a pre-filing settlement, licensing agreement, or a rapid reassessment of case viability following defendant outreach. The public record is silent on any financial terms or licensing arrangements. The cost-bearing order — each side pays its own fees — is standard in Rule 41 voluntary dismissals and does not indicate any negotiated payment. What drove CheckWizard’s swift reversal remains unknown from publicly available filings.
Filing to Voluntary dismissal in 6 days
Case resolved in 6 days — well under the Eastern District of Texas median time-to-termination.
Dismissed with prejudice: what the Rule 41 order means for both parties
Rule 41(a)(1)(A)(i) dismissal with prejudice explained
Under FRCP 41(a)(1)(A)(i), a plaintiff may dismiss unilaterally before the defendant serves an answer or summary judgment motion. Choosing to do so ‘with prejudice’ is a permanent, self-imposed bar — it carries the same res judicata effect as an adverse judgment on the merits. CheckWizard cannot reassert the same claims under US10140514B1 against JPMorgan in any future federal action.
Permanent dismissal — no re-filingCheckWizard permanently forfeits claims against JPMorgan
By electing a with-prejudice dismissal, CheckWizard surrendered all future enforcement rights against JPMorgan on US10140514B1. This is a materially stronger concession than a without-prejudice dismissal, which would preserve the option to refile. The public record does not disclose whether a licensing payment or settlement consideration accompanied the dismissal — that distinction is commercially significant but cannot be confirmed from available filings.
Enforcement rights extinguished vs. JPMorganJPMorgan exits with a permanent shield on these claims
JPMorgan Chase Bank benefits from the with-prejudice designation without having filed a single responsive pleading. The res judicata bar means CheckWizard — and potentially its successors in interest regarding the same claims — cannot re-litigate this assertion. JPMorgan bears its own legal costs, but given the 6-day duration, exposure was minimal. The outcome is effectively a full defense win on the asserted claims.
Full res judicata protection securedSpeed of collapse raises questions about assertion strategy
A voluntary dismissal with prejudice filed 6 days after complaint and before any defendant response is consistent with either a swift confidential settlement or a plaintiff reassessment of claim strength. For financial institutions and fintech companies operating mobile image or document-capture features, this case suggests continued PAE-style assertion risk around mobile UX patents. The rapid resolution limits any claim construction or invalidity record from forming in this instance.
PAE assertion risk — mobile banking sectorFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | CheckWizard LLC | Company | Patent assertion entity — holder of US10140514B1, mobile image capture and sharing technologySearch in Eureka ↗ |
| Defendant | JPMorgan Chase Bank, N.A. | Company | JPMorgan Chase Bank, N.A. — major U.S. financial institution with broad mobile banking operationsSearch in Eureka ↗ |
| Plaintiff counsel | Isaac Phillip Rabicoff | Attorney | Counsel for CheckWizard LLCSearch in Eureka ↗ |
| Plaintiff law firm | Rabicoff Law LLC | Law Firm | Representing CheckWizard LLCSearch in Eureka ↗ |
| Presiding judge | Judge Rodney Gilstrap | Judge | Texas Eastern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s order accepts CheckWizard’s Rule 41(a)(1)(A)(i) notice and formally enters a with-prejudice dismissal — the strongest available termination under this procedural mechanism. The explicit notation that JPMorgan had not yet answered confirms the plaintiff’s unilateral right to dismiss, while the with-prejudice designation elevates the outcome beyond a mere procedural withdrawal. The denial of all pending relief as moot and the mutual cost-bearing order are standard, providing no further signal on the merits of the underlying infringement allegations.
US10140514B1 — Mobile image capture and time-limited sharing technology
US10140514B1, filed under application number US15/182992, protects methods and systems for capturing and sharing images via mobile devices, specifically including a time-limited sharing component — functionality analogous to ephemeral media features seen across consumer and enterprise mobile platforms. The patent’s focus on the temporal dimension of image sharing distinguishes it from basic image-transfer art and positions it at the intersection of mobile UX design and social/financial application features.
For financial institutions, the commercial relevance lies in mobile check deposit, document capture, and in-app image-sharing workflows — core features of modern retail banking apps. A patent covering time-limited image sharing could be read against session-based document submission or temporary preview features in banking interfaces. CheckWizard’s decision to assert this patent against one of the largest U.S. banks suggests the portfolio holder views major financial services platforms as within the patent’s claim scope, signalling ongoing risk for similarly positioned institutions and fintech developers.
Should you run an FTO against US10140514B1?
Any company building or maintaining mobile features that involve image capture, document scanning, or time-limited media sharing — particularly in financial services, insurtech, or enterprise SaaS — should consider a freedom-to-operate review against US10140514B1 and its patent family. The CheckWizard v. JPMorgan filing demonstrates active enforcement intent. The with-prejudice dismissal protects only JPMorgan; all other potential defendants remain exposed to assertion.
PatSnap Eureka’s FTO Search Agent can map US10140514B1’s claim scope against your product’s image capture and sharing workflows, identify continuation and divisional family members that may carry similar claim language, and surface prior art that could support an IPR or ex parte reexamination petition. For in-house teams at banks and fintech platforms, proactive FTO analysis now is materially cheaper than responding to a complaint in E.D. Texas.
Run a freedom-to-operate analysis on US10140514B1 to assess your product’s exposure
Run FTO in Eureka →Similar mobile image patent cases in E.D. Texas federal courts
Explore comparable patent assertion entity cases asserting mobile image capture and sharing patents against financial institutions and technology companies in the Eastern District of Texas.
What this case signals for the mobile banking and fintech IP landscape
A 6-day lifecycle and with-prejudice exit in E.D. Texas raises pointed questions about assertion strategy and PAE risk for financial technology.
With-prejudice dismissal creates a permanent enforcement bar against JPMorgan
CheckWizard cannot reassert US10140514B1 claims against JPMorgan in any future action. Financial institutions facing similar early-stage PAE filings should evaluate whether negotiating a with-prejudice dismissal — even without payment — provides durable protection against serial assertion from the same plaintiff or its assignees.
E.D. Texas PAE filings continue to target financial services mobile features
The Eastern District of Texas remains a preferred venue for patent assertion entities targeting large financial institutions. Cases asserting mobile UX, image capture, and document-sharing patents against banks and fintech platforms have increased. In-house IP teams at financial institutions should maintain active monitoring of continuation applications from portfolios like CheckWizard’s.
CheckWizard v JPMorgan — key questions answered
The dismissal with prejudice means CheckWizard LLC permanently forfeited its right to assert the same US10140514B1 claims against JPMorgan Chase Bank in any future federal action. It carries the same res judicata effect as a final judgment on the merits, even though JPMorgan never filed a responsive pleading.
US10140514B1 (App. No. US15/182992) covers capturing and sharing images with mobile device users, including for a limited duration of time. CheckWizard alleged JPMorgan’s mobile banking platform infringed this patent, likely targeting mobile check deposit, document capture, or in-app image-sharing features common to retail banking applications.
The public record does not disclose the reason. A voluntary dismissal with prejudice filed before the defendant answers is consistent with a confidential settlement or licensing payment, though it may also reflect a rapid reassessment of claim viability. No financial terms are publicly available from the court record in Case No. 2:25-cv-00829.
No. The with-prejudice dismissal protects only JPMorgan Chase Bank, N.A. against claims under US10140514B1. Other financial institutions, fintech companies, or mobile app developers remain potential targets. CheckWizard retains the patent and may assert it against other parties. A freedom-to-operate analysis is advisable for any company with similar mobile image features.
Judge Gilstrap’s order specifies that each party bears its own costs, expenses, and attorneys’ fees. This is the standard outcome under Rule 41(a)(1)(A)(i) voluntary dismissals where no fee-shifting agreement or exceptional case finding is made. It does not indicate any payment was made by either side.
PatSnap Eureka searches patents and litigation data to answer instantly.