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InnoMemory v. Fidelity Bank of Texas — RAM Patent Infringement | PatSnap
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Case ID1:24-cv-00229
FiledMar 2024
ClosedOct 2024
Patent Litigation

InnoMemory v. Fidelity Bank of Texas: RAM Patent Suit Dismissed Without Prejudice

InnoMemory, LLC asserted two integrated circuit RAM patents — US7057960B1 and US6240046B1 — against Fidelity Bank of Texas in the Western District of Texas. The plaintiff voluntarily dismissed all claims without prejudice after 232 days, before the defendant filed any answer or summary judgment motion.

Resolution time
232days
232 days — resolved well before the typical district court trial schedule
Patents asserted
2
US7057960B1 and 1 further patent asserted — RAM read cycles and memory refresh power reduction
Outcome
Voluntary dismissal
Voluntarily dismissed — basis of termination does not specify with or without prejudice
Cost ruling
No Fee Award
No costs or fee-shifting order recorded — case ended before merits adjudication
Published by PatSnap Insights Team · Verified by PatSnap Eureka Data
Case overview

RAM patent suit exits early via Rule 41 voluntary dismissal

InnoMemory, LLC filed suit against Fidelity Bank of Texas on March 4, 2024, in the Western District of Texas before Judge Robert Pitman. The complaint asserted two integrated circuit memory patents: US7057960B1, covering a RAM architecture capable of reading one or more data words in a single clock cycle, and US6240046B1, covering a method and architecture for reducing power consumption in memory devices during refresh operations. The filing targeted a regional bank rather than a semiconductor manufacturer, a pattern consistent with non-practising entity assertion strategies.

On October 21, 2024 — 232 days after filing — InnoMemory filed a notice of voluntary dismissal under Federal Rule of Civil Procedure 41(a)(1)(A)(i), dismissing all claims. Because Fidelity Bank of Texas had not yet served an answer or motion for summary judgment, the notice was self-effectuating and required no court order. The docket closed the following day, October 22, 2024. The public record does not disclose whether a settlement was reached; the dismissal instrument itself is silent on any financial terms.

The timing of dismissal — before any responsive pleading — is notable. It may suggest that the parties reached an informal resolution, or that InnoMemory elected to withdraw for strategic reasons such as claim scope reassessment or a decision to pursue different defendants. The ‘without prejudice’ qualification means InnoMemory retains the theoretical right to refile, though re-filing against the same defendant on the same patents would raise time-bar and estoppel considerations depending on the circumstances. What drove the withdrawal remains undisclosed on the public record.

Case at a glance
Case no.1:24-cv-00229
CourtTexas Western
JudgeRobert Pitman
FiledMarch 4, 2024
ClosedOctober 22, 2024
Duration232 days
OutcomeVoluntary dismissal
Verdict causeInfringement Action
BasisVoluntary dismissal
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Case data sourced from PACER / Texas Western District Court via PatSnap Eureka Litigation Intelligence Explore similar cases ↗
Case timeline

Filing to Voluntary dismissal in 232 days

232 days — resolved well before the typical district court trial schedule

Case timeline: Complaint filed MAR 4 2024, JUN–JUL — 232 days total Horizontal timeline showing the three key events in InnoMemory, LLC v Fidelity Bank of Texas from filing to resolution. Source: PACER, Texas Western District Court. MAR 4 2024 Complaint filed Pre-trial proceedings OCT 22 2024 Voluntary dismissal 232 DAYS TOTAL
Dismissal terms

Voluntarily dismissed: what the Rule 41 exit means for both parties

Legal mechanism

Rule 41(a)(1)(A)(i): dismissal as of right, no court order needed

Under FRCP 41(a)(1)(A)(i), a plaintiff may dismiss an action without a court order by filing a notice of dismissal before the defendant serves an answer or a motion for summary judgment. Because Fidelity Bank had not served either, InnoMemory’s notice was self-effectuating. The Fifth Circuit confirmed in In re Amerijet Int’l that no judicial action is required — the filing alone terminates the case.

Rule 41(a)(1)(A)(i) dismissal
With or without prejudice?

The public record is silent on prejudice status — a critical distinction

A dismissal ‘without prejudice’ permits the plaintiff to refile; a dismissal ‘with prejudice’ is a final adjudication on the merits that bars re-litigation. The Basis of Termination recorded here is ‘Voluntary dismissal’ without specifying either qualifier. The Verdict text states the dismissal was without prejudice, but practitioners should independently verify the filed notice (Dkt. 18) to confirm the exact terms before advising on refiling risk.

Prejudice status — verify Dkt. 18
Patent holder outcome

InnoMemory exits without a merits ruling — patents remain in play

No court has ruled on the validity or infringement scope of US7057960B1 or US6240046B1. InnoMemory’s patents are not invalidated or limited by this proceeding. If the dismissal was without prejudice, InnoMemory retains the option to assert these patents again — against Fidelity Bank or other defendants — subject to applicable statutes of limitations and any separate agreements that may exist outside the public record.

No merits adjudication
Defendant outcome

Fidelity Bank escapes without prejudice — but exposure persists

Fidelity Bank of Texas obtained no invalidity ruling and no covenant not to sue from this proceeding. If the dismissal was without prejudice, the bank’s patent exposure from these two RAM patents is not formally extinguished. End-user defendants in this position typically seek a covenant not to sue or monitor the plaintiff’s subsequent assertion activity closely to assess ongoing risk to their technology operations.

No covenant not to sue on record
Legal analysis based on PACER docket records for case 1:24-cv-00229 and PatSnap Eureka litigation intelligence Search PatSnap Eureka ↗
Parties and representation

Full party and counsel information

RoleNameTypeDetail
PlaintiffInnoMemory, LLCCompanyNon-practising entity — holder of US7057960B1 and US6240046B1, RAM architecture patentsSearch in Eureka ↗
DefendantFidelity Bank of TexasCompanyRegional bank headquartered in Texas, named as an end-user defendant in a RAM patent suitSearch in Eureka ↗
Plaintiff counselIsaac RabicoffAttorneyCounsel for InnoMemory, LLCSearch in Eureka ↗
Plaintiff law firmRabicoff Law LLCLaw FirmRepresenting InnoMemory, LLCSearch in Eureka ↗
Defendant counselD. Scott HemingwayAttorneyCounsel for Fidelity Bank of TexasSearch in Eureka ↗
Defendant counselVictoria HarrisonAttorneyCounsel for Fidelity Bank of TexasSearch in Eureka ↗
Defendant counselWilliam S. RheaAttorneyCounsel for Fidelity Bank of TexasSearch in Eureka ↗
Defendant law firmDuBois, Bryant & Campbell, LLPLaw FirmRepresenting Fidelity Bank of TexasSearch in Eureka ↗
Defendant law firmHemingway & Hansen LLPLaw FirmRepresenting Fidelity Bank of TexasSearch in Eureka ↗
Presiding judgeJudge Robert PitmanJudgeTexas Western District CourtSearch in Eureka ↗
Official verdict

Official order — verbatim text

“On October 21, 2024, Plaintiff dismissed all claims in this case without prejudice. (Dkt. 18). Rule 41(a)(1)(A)(i) allows a plaintiff to voluntarily dismiss an action without a court order by filing a notice of dismissal before the opposing party serves an answer or a motion for summary judgment. Fed. R. Civ. P. 41(a)(1)(A)(i). Defendant has not served an answer or motion for summary judgment. Plaintiff’s notice is therefore “self-effectuating and terminates the case in and of itself; no order or other action of the district court is required.” In re Amerijet Int’l, Inc., 785 F.3d 967, 973 (5th Cir. 2015), as revised (May 15, 2015).”
Source: PACER Docket, Case 1:24-cv-00229, Texas Western District Court

The verdict text confirms dismissal under FRCP 41(a)(1)(A)(i) and cites Fifth Circuit authority establishing that such a notice is self-effectuating. The language ‘dismissed all claims in this case without prejudice’ is significant: it preserves InnoMemory’s right to refile. No merits ruling was reached, no claim construction was conducted, and the validity of either patent was never adjudicated. For Fidelity Bank, this outcome provides procedural closure but no legal certainty against future assertion of the same patents.

PACER case 1:24-cv-00229 · Public docket record Explore in Eureka ↗
Patent at issue

US7057960B1 & US6240046B1 — Integrated Circuit RAM Architecture Patents

Publication No.US7057960B1
Application No.US10/629667
Patent details
ProductIntegrated circuit RAM capable of reading one or more data words per single clock cycle
Cited in actionMarch 4, 2024

Publication No.US6240046B1
Application No.US09/502983
Patent details
ProductMethod and architecture for reducing power consumption in memory devices during refresh operations
Cited in actionMarch 4, 2024

US7057960B1 protects an integrated circuit random access memory architecture capable of reading either one or more than one data word in a single clock cycle — a design feature relevant to performance-critical memory subsystems. US6240046B1 covers a method and architecture for reducing power consumption in memory devices during refresh operations, addressing energy efficiency in DRAM-type components. Both patents originate from application filings predating widespread deployment of DDR memory standards, giving them broad potential reach over contemporary memory implementations.

The strategic significance of these patents lies in their foundational character: memory read performance and refresh power reduction are design objectives present across virtually all modern computing systems — from enterprise servers to embedded banking infrastructure. NPEs holding patents at this layer of the memory stack can assert against end-users across diverse industry sectors. For technology vendors supplying financial institutions or other end-user markets, the enforceability of these patents after an inconclusive dismissal should be factored into product and indemnification strategies.

Patent data sourced from USPTO via PatSnap Eureka patent database Search patent records in Eureka ↗
Freedom to operate

Should your product team run an FTO against US7057960B1 and US6240046B1?

Any organisation deploying systems that incorporate integrated circuit RAM — including financial services firms, enterprise IT operators, cloud infrastructure providers, and embedded systems manufacturers — should assess their exposure to US7057960B1 and US6240046B1. The absence of any invalidity ruling in this case means both patents remain fully enforceable. End-user defendants are particularly vulnerable where vendor indemnification agreements are silent or limited on foundational memory patents.

PatSnap Eureka’s FTO Search Agent can map the claim scope of US7057960B1 and US6240046B1 against your specific memory architecture, flag relevant prior art that could support an invalidity argument, and surface any related continuation or family patents that may extend InnoMemory’s assertion reach. Running a targeted FTO now — before any demand letter arrives — provides the most defensible position and the broadest options for design-around or licensing negotiation.

PatSnap Eureka FTO Search

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Related litigation

Similar RAM and memory patent infringement cases in U.S. district courts

Cases involving foundational RAM and memory architecture patents asserted against end-user defendants in the Western District of Texas and related U.S. district courts.

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Strategic implications

What this case signals for the RAM patent assertion landscape

Early voluntary dismissals before any responsive pleading are a recurring pattern in NPE RAM patent campaigns — and the signal is rarely simple.

Pre-answer dismissals often mask settlement — not defeat

When an NPE voluntarily dismisses before the defendant answers, the most commercially common explanation is a licensing resolution reached outside the docket. InnoMemory’s rapid exit — 232 days in, no responsive pleading filed — is consistent with a negotiated outcome, though the public record does not confirm this. IP teams monitoring similar campaigns should treat early dismissals as potential settlement signals.

End-user defendants face recurring RAM patent risk from NPE campaigns

Fidelity Bank of Texas is a regional bank, not a chip maker — its exposure arose from using memory technology in its IT infrastructure. This end-user targeting pattern is common in RAM patent assertion. Financial institutions and other downstream technology users should assess their exposure to foundational memory patents and consider whether their vendors provide indemnification cover.

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Frequently asked questions

InnoMemory v Fidelity — key questions answered

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Assess your RAM patent exposure before the next demand letter

US7057960B1 and US6240046B1 remain unadjudicated and fully enforceable after this voluntary dismissal. Run a targeted FTO and monitor InnoMemory’s assertion activity in PatSnap Eureka to stay ahead of RAM patent risk.

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