InnoMemory v. Panasonic: RAM Patent Suit Dismissed Without Prejudice in 134 Days
InnoMemory, LLC asserted two integrated circuit memory patents against Panasonic, Corp. in the Eastern District of Texas, targeting RAM architectures capable of multi-word reads and low-power refresh operations. The plaintiff voluntarily dismissed the case without prejudice after just 134 days, leaving both patents fully actionable for future enforcement.
Memory patent dispute exits E.D. Tex. without a merits ruling
On 20 July 2023, InnoMemory, LLC filed an infringement action against Panasonic, Corp. in the United States District Court for the Eastern District of Texas (Case No. 2:23-cv-00339), asserting two integrated circuit memory patents: US7057960B1, directed to a RAM architecture capable of reading one or more data words in a single clock cycle, and US6240046B1, directed to a method and architecture for reducing power consumption in memory devices during refresh operations. Panasonic was the sole defendant.
The case closed on 1 December 2023 after InnoMemory filed a Notice of Voluntary Dismissal. The Court accepted and acknowledged the notice pursuant to Rule 41(a)(1)(A)(i) and dismissed all pending claims and causes of action without prejudice. The recorded Basis of Termination is 'Dismissed without Prejudice'; the docket order states the case is voluntarily dismissed without prejudice under Rule 41(a)(1)(A)(i). The specific terms driving the dismissal are not disclosed in the available record.
Resolution after only 134 days — before any substantive motion practice or claim construction — is consistent with early-stage resolution, though what specifically prompted InnoMemory's withdrawal is not disclosed in the public record. Because the dismissal is without prejudice, InnoMemory retains the right to refile substantially similar claims against Panasonic or any other party, subject to applicable statutes of limitations. No costs, fees, or other relief were awarded.
See Complete Case & Patent Analysis →Filing to Dismissed without Prejudice in 134 days
134 days from filing to dismissal — resolved before any substantive merits ruling
US7057960B1 & US6240046B1 — Integrated Circuit RAM and Low-Power Memory Refresh
Any R&D or product team working on integrated circuit RAM — including SRAM, DRAM, LPDDR, embedded NVM, or memory IP cores — should consider a freedom-to-operate review against both asserted patents. US7057960B1 is relevant to architectures that read multiple data words per clock cycle; US6240046B1 is relevant to any design that modifies or optimises refresh power draw. Both patents remain enforceable following the without-prejudice dismissal.
Official order — verbatim text
The court's order is procedural in scope: it accepts InnoMemory's Rule 41(a)(1)(A)(i) notice and dismisses all claims and causes of action without prejudice, denying all other pending relief as moot. No ruling on infringement, validity, or claim construction was issued, meaning neither patent received substantive judicial scrutiny. The without-prejudice designation is the operative legal fact — both patents remain available for future assertion.
Dismissed without prejudice: what the voluntary exit means for both parties
Rule 41(a)(1)(A)(i): plaintiff's right to exit before answer
Under Rule 41(a)(1)(A)(i), a plaintiff may voluntarily dismiss an action without a court order before the defendant has served an answer or a motion for summary judgment. The dismissal is without prejudice by default unless otherwise stated. Here, InnoMemory exercised that right, and the court accepted the notice. No merits determination was made on either asserted patent.
No merits adjudicationDismissal without prejudice keeps both patents fully live
A dismissal without prejudice does not extinguish InnoMemory's infringement claims. InnoMemory may refile against Panasonic or assert these patents — US7057960B1 and US6240046B1 — against other parties in memory-related markets, subject to applicable statutes of limitations. Defendants and potential new targets in the RAM and DRAM supply chain should treat these patents as still enforceable. Whether any conditions govern refiling is not disclosed in the available record.
Patents remain enforceablePanasonic exits with no adverse ruling — but exposure persists
Panasonic faces no injunction, damages award, or finding of infringement. However, because the dismissal is without prejudice, Panasonic has not secured a declaratory judgment of non-infringement or invalidity. Should InnoMemory refile, Panasonic would need to re-engage. No record of Panasonic filing counterclaims or seeking a fee award is present in the available docket.
No adverse finding; residual riskRAM and memory IC makers should monitor InnoMemory's next moves
The unresolved status of US7057960B1 and US6240046B1 means competitors and supply-chain participants in integrated circuit memory — including DRAM, SRAM, and embedded memory — face continued exposure. Voluntary early dismissals in E.D. Texas patent cases sometimes precede refiling in a different venue or against a different defendant. Companies commercialising multi-word RAM read architectures or low-power refresh techniques should consider FTO analysis against both asserted patents.
Monitor for refilingFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | InnoMemory, LLC | Company | /Search in Eureka ↗ |
| Defendant | Panasonic, Corp. | Company | /Search in Eureka ↗ |
| Plaintiff counsel | Isaac Phillip Rabicoff | Attorney | Counsel for InnoMemory, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Rabicoff Law LLC | Law Firm | Representing InnoMemory, LLCSearch in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Texas Eastern District CourtSearch in Eureka ↗ |
R&D signals in integrated circuit memory patent space
Forward-looking patent and innovation intelligence derived from InnoMemory's assertion of RAM read-cycle and low-power refresh patents against Panasonic in E.D. Texas.
InnoMemory's RAM patent holdings: is this the full picture?
InnoMemory asserted two technically distinct memory patents in a single action, suggesting a targeted portfolio rather than broad assertion. Mapping InnoMemory's full patent holdings — including continuation applications, reissues, and related family members — can reveal whether further claims covering read-cycle bandwidth or refresh-power optimisation are pending or unasserted.
Portfolio breadth unknownFiling trends in multi-word RAM read and low-power refresh architectures
Single-cycle multi-word RAM reads and adaptive refresh power reduction are active innovation areas driven by LPDDR5, HBM, and embedded DRAM demand. Tracking recent patent filings in these sub-domains — particularly by memory IP licensors and fabless semiconductor firms — can identify who is building defensive and offensive positions in the same technical space covered by US7057960B1 and US6240046B1.
Active filing spacePanasonic's semiconductor memory patent position
Panasonic holds a substantial semiconductor patent portfolio spanning imaging, sensors, and components. Assessing Panasonic's own filings in integrated circuit memory — including DRAM, SRAM, and embedded memory architectures — can reveal whether they hold defensive assets relevant to the asserted claims and what their IP strategy in memory IC looks like post-dismissal.
Panasonic memory IPAdjacent innovation space: refresh-free and near-zero-power memory
US6240046B1's refresh-power focus points to an adjacent white space: memory architectures that eliminate or dramatically reduce refresh requirements, such as gain-cell eDRAM, STT-MRAM, and ReRAM. Patent activity in these adjacent non-volatile and near-zero-refresh memory domains is rising and may represent differentiated filing opportunities for R&D teams seeking to avoid the asserted claim scope.
Emerging memory white spaceSimilar RAM and memory IC patent infringement cases in E.D. Texas
Explore related integrated circuit memory patent infringement actions filed in the Eastern District of Texas, including comparable early-exit voluntary dismissals and RAM architecture assertions.
What this case signals for the integrated circuit memory IP landscape
An early voluntary dismissal without prejudice in E.D. Texas leaves two RAM patents unresolved and the broader memory IC market exposed.
Without-prejudice dismissal: treat both patents as live enforcement threats
US7057960B1 and US6240046B1 have not been adjudicated invalid or not-infringed. Any party in the integrated circuit RAM supply chain — fabless chipmakers, DRAM manufacturers, embedded memory IP licensors — should run updated FTO analysis before assuming these patents are commercially inert.
E.D. Texas early exits often signal strategic repositioning, not abandonment
Rule 41(a)(1)(A)(i) dismissals filed before an answer are cost-free for the plaintiff. The 134-day window is consistent with pre-answer settlement discussions, venue reassessment, or portfolio consolidation. Practitioners should monitor InnoMemory's docket activity and any new filings asserting either patent.
InnoMemory v Panasonic — key questions answered
InnoMemory asserted two patents: US7057960B1, covering an integrated circuit RAM 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. Both patents remain unajudicated following the voluntary dismissal.
InnoMemory filed a Notice of Voluntary Dismissal under Rule 41(a)(1)(A)(i), which allows a plaintiff to dismiss an action without a court order before the defendant has served an answer. The court accepted the notice and dismissed all claims without prejudice. The specific reasons driving the dismissal are not disclosed in the available public record.
Yes. A dismissal without prejudice does not bar InnoMemory from refiling the same or substantially similar claims against Panasonic, subject to applicable statutes of limitations. Neither US7057960B1 nor US6240046B1 was found invalid or not-infringed, so both patents remain enforceable. Whether any conditions or agreements govern any potential refiling are not disclosed in the available record.
Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure permits 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. The dismissal is without prejudice unless the notice states otherwise. This is a purely procedural exit — no merits were adjudicated in InnoMemory v. Panasonic.
The case was filed in the United States District Court for the Eastern District of Texas (Case No. 2:23-cv-00339). E.D. Texas is a frequently chosen venue for patent infringement actions due to its established patent litigation docket. Because the case was dismissed without prejudice, InnoMemory could potentially refile in E.D. Texas or a different venue in any future action.
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