Data Resonance v. Relx: Infringement Suit Dismissed With Prejudice After 173 Days
Data Resonance, LLC filed suit against Relx, Inc. in the Southern District of New York asserting US6934714B2, a patent covering methods for identifying and maintaining families of data records. The plaintiff voluntarily dismissed the action with prejudice before Relx filed any responsive pleading — a notably swift end to a case involving a data management technology patent.
Patent assertion ends pre-answer: data management claim extinguished
On 22 December 2023, Data Resonance, LLC filed a patent infringement action against Relx, Inc. in the U.S. District Court for the Southern District of New York (Case No. 1:23-cv-11136), before Judge John P. Cronan. The asserted patent, US6934714B2, covers a method and system for the identification and maintenance of families of data records — technology relevant to enterprise data management and record-linkage platforms of the kind Relx operates.
The case closed on 12 June 2024, just 173 days after filing, when Data Resonance filed a notice of voluntary dismissal with prejudice pursuant to Rule 41(a)(1)(A)(i). Because Relx had not yet answered the complaint or moved for summary judgment, the dismissal was effective upon filing without requiring court approval. The with-prejudice designation permanently bars Data Resonance from reasserting the same claims against Relx on this patent. Each party was left to bear its own costs, expenses, and attorneys’ fees.
The pre-answer timeline — fewer than six months from filing to dismissal — suggests the matter resolved before substantive litigation costs escalated, consistent with early-stage licensing discussions, a licensing agreement, or strategic reassessment by plaintiff’s counsel. The public record does not disclose any settlement terms, licensing payment, or the specific trigger for the dismissal decision, leaving the commercial resolution, if any, unknown.
Filing to Voluntary dismissal in 173 days
173 days — faster than the median SDNY patent case disposition
Dismissed with prejudice: what Rule 41(a)(1)(A)(i) means for each party
Rule 41(a)(1)(A)(i) — self-executing dismissal, no court order needed
Under Federal Rule of Civil Procedure 41(a)(1)(A)(i), a plaintiff may dismiss an action without a court order by filing a notice of dismissal before the opposing party has served an answer or motion for summary judgment. The dismissal is effective the moment the notice is filed. The with-prejudice designation here converts what would be a typically leave-open exit into a permanent bar — an unusual and consequential choice when the defendant has not yet responded.
Pre-answer dismissal — self-executingWith-prejudice bar: Data Resonance forecloses future claims on this patent against Relx
By voluntarily dismissing with prejudice, Data Resonance permanently surrendered its right to assert US6934714B2 against Relx in any future action. This outcome is atypical for a plaintiff-initiated pre-answer dismissal, where without-prejudice exits are more common. The choice of with-prejudice language, combined with no cost award, is consistent with the parties reaching a private resolution — though no such agreement appears in the public record.
Claims extinguished against RelxRelx exits without responding — and without any fee award
Relx, Inc. achieved dismissal before incurring the cost of drafting an answer, invalidity contentions, or claim construction briefing. However, Relx received no fee-shifting award despite the case ending in its favour procedurally. The each-party-bears-own-costs provision is standard in early dismissals and does not imply misconduct by either party. Relx now carries permanent protection from this plaintiff asserting this specific patent again.
Protected from re-assertionEarly exit leaves patent enforceability questions unanswered for the sector
Because the case ended before any substantive ruling — no Markman hearing, no validity determination — US6934714B2 has not been judicially tested. Companies in the data analytics, record-linkage, and enterprise data management space that were monitoring this litigation should note that the patent’s claims remain untested and theoretically enforceable against other defendants. A pre-answer with-prejudice dismissal does not constitute a finding on validity or infringement scope.
Patent validity unresolvedFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Data Resonance, LLC | Company | Patent assertion entity — holder of US6934714B2, data record management technologySearch in Eureka ↗ |
| Defendant | Relx, Inc. | Company | Relx, Inc. — global information analytics and publishing services providerSearch in Eureka ↗ |
| Plaintiff counsel | Isaac Rabicoff | Attorney | Counsel for Data Resonance, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Rabicoff Law LLC | Law Firm | Representing Data Resonance, LLCSearch in Eureka ↗ |
| Presiding judge | Judge John P. Cronan | Judge | New York Southern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal notice invokes Rule 41(a)(1)(A)(i) explicitly and specifies both the with-prejudice designation and the mutual cost-bearing arrangement. The with-prejudice language is the operative clause: it converts a procedural exit into a final adjudication on the plaintiff’s right to bring these specific claims against this defendant. No merits finding on infringement or validity was made, and the court issued no order — the dismissal is self-executing. The cost provision, while standard, confirms neither party sought to characterise the other’s conduct as exceptional under 35 U.S.C. § 285.
US6934714B2 — Method and system for data record family identification
US6934714B2 covers a method and system for identifying and maintaining families — or clusters — of related data records within large databases. The patent addresses the technical problem of deduplication, record linkage, and entity resolution: determining when multiple records across disparate data sources refer to the same real-world entity and maintaining the integrity of those groupings over time. This sits at the core of enterprise data management, master data management (MDM), and information services platforms.
For a company like Relx — which operates across legal, scientific, and risk data platforms — record-linkage and entity-resolution technologies are foundational infrastructure. The assertion of this patent against Relx suggests plaintiff’s counsel viewed Relx’s data management architecture as potentially practising the claimed methods. With no court ruling on claim construction, the patent’s coverage boundaries remain commercially uncertain, making it a continued monitoring priority for any vendor offering data identity or record-matching services.
Should you run an FTO analysis against US6934714B2?
Any company building or selling data record linkage, entity resolution, master data management, or deduplication platforms should treat US6934714B2 as an active FTO consideration. The patent has never been substantively challenged in court — no Markman ruling, no IPR on the public record — meaning its claim scope has not been narrowed by judicial construction. Information services providers, legal tech platforms, and enterprise data vendors operating in the SDNY and beyond face residual assertion risk.
PatSnap Eureka’s FTO Search Agent can map the independent and dependent claims of US6934714B2 against your product architecture, surface relevant prior art that could inform an IPR strategy, and identify any continuation or family patents that may extend coverage beyond this grant. For R&D and product teams integrating record-linkage logic into SaaS or analytics platforms, a proactive FTO review now is significantly cheaper than defending a complaint later.
Run a freedom-to-operate analysis on US6934714B2 to assess your product’s exposure
Run FTO in Eureka →Similar data management patent infringement cases in SDNY
Cases involving data record management and entity resolution patents in the Southern District of New York, with comparable pre-answer dismissal outcomes.
What this case signals for the data management IP landscape
A swift pre-answer dismissal with prejudice rarely tells the whole story — for IP teams in data analytics, the subtext matters.
Pre-answer with-prejudice exits often mask private licensing outcomes
When a plaintiff files a Rule 41(a)(1)(A)(i) notice with prejudice before the defendant has even answered, it frequently — though not always — signals a private resolution. The absence of fee-shifting, combined with a permanent claim bar, is consistent with a lump-sum payment or covenant not to sue. IP teams monitoring assertion campaigns should treat this pattern as a signal, not confirmation.
US6934714B2 remains unlitigated — exposure persists for other data record platform vendors
No court has ruled on the validity or claim scope of US6934714B2. Companies operating data record identification, entity resolution, or data maintenance platforms similar to Relx’s offerings should assess whether their products fall within the patent’s method claims. The absence of a merits ruling means assertion risk to third parties remains live.
Data v Relx — key questions answered
It means Data Resonance permanently waived its right to sue Relx again on US6934714B2. Rule 41(a)(1)(A)(i) permits a plaintiff to dismiss without court approval before the defendant answers. The with-prejudice designation — plaintiff’s own choice — extinguishes the claim permanently. Relx cannot be sued again by this plaintiff on this patent.
No. The case ended before any substantive ruling. No claim construction, invalidity determination, or infringement finding was issued. US6934714B2 remains unlitigated on the merits and its validity has not been tested in federal court based on the public record of this case.
The public record does not disclose any settlement payment or licensing agreement. The dismissal notice specifies that each party bears its own costs. A private resolution is possible and consistent with the facts, but cannot be confirmed from available court filings.
The case closed before Relx filed any response to the complaint, suggesting early-stage resolution. Pre-answer dismissals in patent cases typically reflect one of three scenarios: a private licensing or settlement agreement, plaintiff’s reassessment of litigation economics, or a strategic decision not to proceed against a well-resourced defendant. The public record does not specify which applied here.
No. A with-prejudice dismissal only bars Data Resonance from suing Relx again. Any other entity — including other data management or information services companies — remains exposed to assertion of US6934714B2 by the patent holder. The patent’s claims were never construed or invalidated, so third-party risk remains unchanged.
PatSnap Eureka searches patents and litigation data to answer instantly.