DatRec LLC v. UKG Inc: Patent Suit Dismissed With Prejudice in 96 Days
DatRec, LLC asserted US8381309B2 against UKG Inc, targeting its OrangeHRM Mobile App and related instruction systems in the Texas Northern District Court. The plaintiff stipulated to dismissal with prejudice under Rule 41(a)(1)(A)(ii) just 96 days after filing — foreclosing any future re-filing of the same claims.
A swift exit: DatRec’s HR tech patent claim ends at plaintiff’s own hand
On 18 July 2025, DatRec, LLC filed suit against UKG Inc in the United States District Court for the Northern District of Texas before Judge Jane J. Boyle, asserting infringement of US8381309B2. The accused product was UKG’s OrangeHRM Mobile App and associated customer-facing instructional materials, including its website and product manuals. DatRec was represented by Kirby Drake Law PLLC and Ramey LLP — a firm with a notable volume of patent assertion activity in Texas federal courts.
The case closed on 22 October 2025 when DatRec filed a stipulation of dismissal under Federal Rule of Civil Procedure 41(a)(1)(A)(ii), terminating all of its claims with prejudice. Dismissal with prejudice is a final adjudication on the merits as a matter of law, meaning DatRec cannot re-assert the same claims against UKG on the basis of US8381309B2. No defendant law firm appears on the public record, suggesting UKG may not have entered a formal appearance before the dismissal was filed.
The 96-day lifespan of this case is notably short, and the with-prejudice designation makes it consequential despite its brevity. The public record does not disclose whether a settlement was reached, licensing terms were negotiated, or whether UKG mounted early pressure — such as an IPR threat or invalidity analysis — that prompted the withdrawal. The combination of plaintiff-side dismissal and Ramey LLP’s involvement is consistent with a pattern seen in cases where early defendant pushback or fee-shifting risk discourages continued litigation.
Filing to Case Dismissed in 96 days
96 days — well below the median time-to-termination for patent cases in the Northern District of Texas
Dismissed with prejudice: what DatRec’s stipulation means for both sides
Rule 41(a)(1)(A)(ii) — stipulated dismissal, permanently binding
A dismissal under Rule 41(a)(1)(A)(ii) requires a signed stipulation from all parties who have appeared, or — where no defendant has appeared — by the plaintiff alone. Filed with prejudice, it functions as a final judgment on the merits. Unlike a court-ordered dismissal, it originates with the plaintiff, but its with-prejudice designation removes the right to re-file. The claims are extinguished.
Final — no re-filing permittedDatRec permanently surrenders its infringement claims against UKG
By stipulating to dismissal with prejudice, DatRec has voluntarily and permanently relinquished its infringement claims against UKG Inc based on US8381309B2. This is a materially adverse result for the patent holder: it cannot re-assert these claims against UKG, cannot seek damages for the same accused conduct, and the dismissal may affect the credibility of future assertion campaigns against other defendants on the same patent.
Claims extinguished against UKGUKG exits without a merits ruling — and with full protection on these claims
UKG Inc obtains the practical benefit of full case termination without a formal invalidity or non-infringement finding. The with-prejudice dismissal means UKG faces no future exposure from DatRec on these specific claims. However, because no court ruled on the merits of infringement or validity, UKG holds no declaratory judgment it could use offensively. The patent US8381309B2 technically remains in force against other potential targets.
Protected — no future DatRec claimOrangeHRM mobile technology clears this assertion — but the patent persists
UKG’s OrangeHRM Mobile App and its associated instructional content are insulated from DatRec’s claims. Other HR software vendors or mobile app developers operating in the same space, however, should note that US8381309B2 remains an active asset — the dismissal provides no invalidity precedent they can rely on. Competitors in the mobile HR and workforce management sector should treat this patent as live until a validity ruling or expiry is confirmed.
Patent US8381309B2 remains liveFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | DatRec, LLC | Company | Patent assertion entity — holder of US8381309B2 covering mobile HR application technologySearch in Eureka ↗ |
| Defendant | UKG Inc | Company | UKG Inc — enterprise human capital management software provider, developer of OrangeHRM platformSearch in Eureka ↗ |
| Plaintiff counsel | Kirby Blair Drake | Attorney | Counsel for DatRec, LLCSearch in Eureka ↗ |
| Plaintiff counsel | William P. Ramey , III | Attorney | Counsel for DatRec, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Kirby Drake Law PLLC | Law Firm | Representing DatRec, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Ramey LLP | Law Firm | Representing DatRec, LLCSearch in Eureka ↗ |
| Presiding judge | Judge Jane J Boyle | Judge | Texas Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The stipulation recites dismissal ‘with prejudice’ of ‘all of Plaintiff’s claims’ — language that is unambiguous in scope and effect. Under controlling Fifth Circuit precedent, a with-prejudice dismissal operates as a final adjudication on the merits, triggering res judicata as to the dismissed claims. The all-claims formulation leaves no carve-outs and forecloses any argument that a subset of asserted theories survived. The joint stipulation format under Rule 41(a)(1)(A)(ii) also signals bilateral agreement, though no settlement terms are publicly disclosed.
US8381309B2 — mobile HR application access and instruction technology
US8381309B2, filed under application number US12/518212, protects technology in the domain of mobile human resources application delivery and user instruction. The patent’s claims are directed to methods and systems relevant to how HR software is accessed, operated, and taught to end-users via mobile platforms. Its assertion against OrangeHRM — a widely-deployed open-source HR management system now integrated into the UKG product ecosystem — suggests DatRec considered the app’s mobile interface and instructional content to fall within the patent’s claim scope.
The mobile HR software segment is commercially significant: enterprise platforms such as UKG, Workday, SAP SuccessFactors, and BambooHR all maintain mobile-first user experiences. A patent capable of covering mobile HR app instruction or access methodology represents a potential horizontal assertion risk across the sector. With no invalidity finding on the record, US8381309B2 retains legal presumption of validity under 35 U.S.C. § 282 and could be deployed against other vendors. Competitors in workforce management software should treat this patent as an active monitoring priority.
Should your HR mobile platform team run an FTO against US8381309B2?
Any company developing or distributing a mobile HR application — including employee self-service apps, workforce management tools, or digital onboarding platforms — should assess its exposure to US8381309B2. The claims at issue in this case targeted not only app functionality but also customer instruction materials and product manuals, suggesting a broader scope than core software code. Product teams shipping mobile HR or HCM applications, and legal teams evaluating third-party app integrations, should prioritise this patent in any FTO workstream.
PatSnap Eureka’s FTO Search Agent allows you to map your mobile HR application’s feature set against the claim language of US8381309B2 in minutes. Eureka surfaces the full prosecution history, claim scope analysis, and prior art landscape — enabling your IP team to identify design-around options or build an invalidity argument before a demand letter arrives. Given this patent’s demonstrated assertion activity, a proactive FTO review is a lower-cost alternative to reactive litigation.
Run a freedom-to-operate analysis on US8381309B2 to assess your product’s exposure
Run FTO in Eureka →Similar mobile HR and workforce software patent cases in Texas courts
Cases involving mobile HR application patents asserted in the Northern District of Texas by assertion entities represented by high-volume litigation firms.
What this case signals for the HR software patent IP landscape
A rapid with-prejudice exit by a Ramey LLP-represented plaintiff warrants close attention from any HR tech vendor facing similar assertions.
With-prejudice dismissal at day 96 suggests early resistance from UKG proved decisive
Cases that terminate this quickly — and with prejudice — typically reflect a significant shift in plaintiff’s litigation calculus. This may include a credible invalidity challenge, IPR filing risk, or a fee-shifting argument under 35 U.S.C. § 285. HR software vendors facing similar early-stage assertions should consider aggressive early responses as a viable defensive strategy.
Ramey LLP’s involvement is a known litigation signal for targeted defendants
Ramey LLP has been among the more active patent assertion firms in Texas federal courts. Defendants sued by Ramey-represented plaintiffs frequently face standardised claim sets. Identifying whether US8381309B2 has been asserted against other HR or mobile application companies can help map the broader assertion campaign and inform a coordinated defensive response.
DatRec v UKG — key questions answered
The with-prejudice dismissal means DatRec, LLC is permanently barred from re-asserting the same infringement claims against UKG Inc based on US8381309B2. Under res judicata principles, the stipulated dismissal with prejudice functions as a final adjudication on the merits. DatRec retains ownership of the patent and could theoretically assert it against other defendants, but its claims against UKG are extinguished.
US8381309B2 is a United States patent filed under application number US12/518212. In this case it was asserted against UKG’s OrangeHRM Mobile App and related customer instruction systems. The patent relates to methods and systems in the domain of mobile HR application access and user instruction. It retains a presumption of validity under 35 U.S.C. § 282 as no court has issued an invalidity ruling.
The public record does not disclose the reason for the 96-day dismissal. However, a with-prejudice voluntary dismissal this early is typically consistent with a settlement or licensing resolution, a credible invalidity or IPR threat from the defendant, or an assessment that fee-shifting risk under 35 U.S.C. § 285 made continued litigation commercially unattractive. No defendant counsel appeared on record, which may suggest resolution was reached before formal engagement.
No. The dismissal is party-specific and creates no invalidity finding or claim construction record that third parties can rely on. US8381309B2 remains active and enforceable. Other HR software vendors, mobile application developers, and HCM platform providers whose products involve mobile app access or user instruction systems should conduct independent FTO analysis against this patent.
Ramey LLP is a Texas-based patent litigation firm with a high volume of patent assertion filings in federal courts, particularly in Texas. Its involvement is consistent with a systematic assertion campaign approach. Defendants facing Ramey-represented plaintiffs have successfully deployed early invalidity challenges, IPR petitions, and § 285 exceptional case arguments. Tracking Ramey LLP’s filing patterns across similar technology domains can help identify coordinated assertion activity.
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