Helix Microinnovations v. Analog Devices: CoB Patent Dismissed in 46 Days
Helix Microinnovations LLC asserted US7238550B2 — a patent covering methods and apparatus for fabricating Chip-on-Board modules — against Analog Devices, Inc. in the Eastern District of Texas. The case closed just 46 days after filing when the plaintiff voluntarily dismissed all claims without prejudice, before the defendant had answered or moved for summary judgment.
A pre-answer exit: CoB patent case ends before Analog Devices responds
On 4 August 2024, Helix Microinnovations LLC filed a patent infringement action in the Eastern District of Texas — Case No. 2:24-cv-00629 — before Judge Rodney Gilstrap, asserting US7238550B2 against Analog Devices, Inc. The patent in suit covers methods and apparatus for fabricating Chip-on-Board (CoB) modules, a semiconductor packaging technology used widely in mixed-signal and embedded processing applications. Analog Devices, a major supplier of signal processing semiconductors, was the sole defendant.
On 19 September 2024 — just 46 days after filing — Helix filed a Notice of Voluntary Dismissal Without Prejudice under Federal Rule of Civil Procedure 41(a)(1)(A)(i). Because Analog Devices had not yet filed an answer or moved for summary judgment, the plaintiff was entitled to dismiss as of right. Judge Gilstrap accepted the notice, dismissed all claims without prejudice, and ordered each side to bear its own costs and attorneys’ fees. No substantive merits ruling was issued.
The 46-day lifespan is notably short even by EDTX standards and suggests the resolution likely preceded any formal engagement from the defence. A dismissal without prejudice preserves the plaintiff’s right to refile on the same patent, meaning the dispute may not be permanently resolved. The public record does not disclose whether a settlement, licensing negotiation, or a unilateral strategic reassessment drove the withdrawal — all three are plausible explanations consistent with this procedural posture.
Filing to Voluntary dismissal in 46 days
46 days — resolved before defendant’s answer was due, well under the district median
Voluntarily dismissed without prejudice: what the order means for both parties
Rule 41(a)(1)(A)(i) — dismissal as of right, no court permission needed
Under FRCP 41(a)(1)(A)(i), a plaintiff may dismiss a case without prejudice as of right at any time before the defendant serves an answer or a motion for summary judgment. Because Analog Devices had done neither, Helix’s notice was self-executing — the court’s order merely acknowledged and formalised what the rule already permitted. No merits determination was made.
Pre-answer voluntary exitWithout prejudice: the case is closed but the door is not locked
A dismissal without prejudice means the plaintiff retains the right to refile the same claims on US7238550B2 against Analog Devices in future. This is the legally significant distinction from a dismissal with prejudice, which would bar refiling. The court’s order is explicit on this point, but the public record does not reveal whether a private settlement or licence was reached alongside the dismissal — that remains unknown.
Refiling right preservedAnalog Devices exits without concession — but exposure persists
Analog Devices avoided any merits ruling and bears no admitted liability. The cost-neutrality order means no fee award was granted in either direction. However, the without-prejudice nature of the dismissal means Analog Devices cannot treat this as a final resolution. If Helix refiles — in EDTX or elsewhere — Analog Devices will need to mount a substantive defence to US7238550B2.
No merits concessionCoB module suppliers should not read this as clearance
A without-prejudice dismissal against one defendant does not affect the enforceability of US7238550B2 against other parties in the Chip-on-Board supply chain. Companies manufacturing or incorporating CoB modules — particularly in mixed-signal, sensor, and embedded IC applications where Analog Devices competes — should treat this patent as still active and enforceable. An FTO analysis against US7238550B2 remains advisable.
Patent remains enforceableFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Helix Microinnovations LLC | Company | IP assertion entity — holder of US7238550B2 covering Chip-on-Board fabrication methodsSearch in Eureka ↗ |
| Defendant | Analog Devices, Inc. | Company | Analog Devices, Inc. — global semiconductor company specialising in signal processing ICsSearch in Eureka ↗ |
| Plaintiff counsel | Isaac Phillip Rabicoff | Attorney | Counsel for Helix Microinnovations LLCSearch in Eureka ↗ |
| Plaintiff law firm | Rabicoff Law LLC | Law Firm | Representing Helix Microinnovations LLCSearch in Eureka ↗ |
| Presiding judge | Judge Rodney Gilstrap | Judge | Texas Eastern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s order accepts Helix’s Rule 41(a)(1)(A)(i) notice and formally dismisses all claims without prejudice. The phrasing ‘ACCEPTS AND ACKNOWLEDGES’ reflects the ministerial nature of this action — where the defendant has not yet answered, no judicial discretion is exercised and no merits analysis is conducted. The explicit without-prejudice designation and mutual cost-bearing instruction are the two operative terms: the first preserves Helix’s refiling rights; the second confirms no fee-shifting occurred in either direction.
US7238550B2 — methods and apparatus for fabricating Chip-on-Board modules
US7238550B2, filed under application number US10/371800, protects methods and apparatus for fabricating Chip-on-Board (CoB) modules — a semiconductor packaging technique in which bare die are directly mounted and wire-bonded to a printed circuit board substrate, eliminating an intermediate package layer. This approach reduces assembly height and cost while improving thermal and electrical performance. The patent’s technical claims address fabrication processes central to producing reliable CoB assemblies at scale.
Chip-on-Board technology is foundational to a wide range of applications including LED lighting, mixed-signal processing, imaging sensors, and embedded electronics — all areas in which Analog Devices and its peers are active. As the semiconductor industry increasingly competes on advanced packaging, CoB-related IP is gaining strategic value. US7238550B2’s continued enforceability — confirmed by the absence of any invalidity ruling in this case — means it presents a credible risk to any manufacturer operating in the CoB space without a licence or design-around strategy.
Should your team run an FTO against US7238550B2?
Any company that designs or procures products involving Chip-on-Board module fabrication should evaluate its exposure to US7238550B2. This case confirms the patent is being actively asserted against a tier-one semiconductor company. The without-prejudice dismissal means no invalidity or non-infringement finding protects third parties. CoB module manufacturers, PCB assembly houses, and IC suppliers whose products may involve CoB fabrication processes are the most directly at risk.
PatSnap Eureka’s FTO Search Agent enables R&D and IP teams to map claim scope against current product architectures, identify prior art that could support an invalidity position, and benchmark the patent’s remaining term. Running a targeted FTO on US7238550B2 now — before a demand letter arrives — is materially cheaper and faster than mounting a reactive defence in the Eastern District of Texas.
Run a freedom-to-operate analysis on US7238550B2 to assess your product’s exposure
Run FTO in Eureka →Similar Chip-on-Board and semiconductor packaging patent cases in EDTX
Cases involving semiconductor packaging patents — including CoB and related fabrication methods — filed in the Eastern District of Texas before Judge Gilstrap.
What this case signals for the Chip-on-Board semiconductor IP landscape
A 46-day pre-answer dismissal in EDTX is rarely accidental — it typically signals a rapid off-ramp negotiation or a litigation strategy pivot.
Pre-answer dismissals in EDTX often precede private licensing resolutions
When a plaintiff files in Judge Gilstrap’s court and dismisses within weeks — before the defendant even answers — the most commercially common explanation is a licence or settlement reached under the threat of litigation. The cost-neutrality order is consistent with a negotiated exit rather than a unilateral withdrawal.
US7238550B2 remains fully enforceable against the broader CoB supply chain
This dismissal creates no estoppel, no invalidity finding, and no claim construction record. Any company that designs, manufactures, or sources Chip-on-Board modules should independently assess freedom to operate against this patent — particularly given that Helix retains the right to refile against Analog Devices or assert against new defendants.
Helix v Analog — key questions answered
Helix Microinnovations LLC filed a patent infringement action against Analog Devices, Inc. in the Eastern District of Texas on 4 August 2024, asserting US7238550B2. The case was voluntarily dismissed without prejudice by the plaintiff on 19 September 2024 — 46 days after filing — before Analog Devices had answered or moved for summary judgment. Each party was ordered to bear its own costs.
A dismissal without prejudice means all claims are terminated but the plaintiff retains the right to refile the same patent infringement claims in future. No merits ruling is made, no invalidity finding is issued, and the patent remains fully enforceable. It differs critically from a dismissal with prejudice, which would permanently bar the plaintiff from reasserting the same claims against the same defendant.
US7238550B2 is a US patent covering methods and apparatus for fabricating Chip-on-Board (CoB) modules — a semiconductor packaging technique where bare die are mounted directly onto a PCB substrate. The patent was asserted by Helix Microinnovations against Analog Devices. It remains enforceable following the without-prejudice dismissal of this case, as no invalidity or non-infringement finding was made.
The case closed just 46 days after filing, before Analog Devices filed any response. The public record does not disclose the reason for the early dismissal. In EDTX patent litigation, pre-answer voluntary dismissals are consistent with a rapid private settlement or licence agreement, though a unilateral strategic withdrawal is also possible. No settlement terms were made public.
No. A voluntary dismissal without prejudice in one case creates no binding precedent, no invalidity finding, and no claim construction record that third parties could rely on. Companies manufacturing or sourcing Chip-on-Board modules remain exposed to US7238550B2 and should conduct independent freedom-to-operate analysis. Helix Microinnovations retains the right to assert the patent against any party, including Analog Devices, in future proceedings.
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