InnoMemory v. Texas Bank And Trust: Memory Patent Suit Dismissed in 90 Days
InnoMemory, LLC filed a patent infringement action in the Eastern District of Texas against Texas Bank And Trust, asserting two integrated circuit memory patents. The case ended in a voluntary dismissal without prejudice in just 90 days — leaving all claims alive for potential re-filing.
A rapid voluntary exit — but the door stays open for InnoMemory
On March 1, 2024, InnoMemory, LLC filed a patent infringement complaint against Texas Bank And Trust in the Eastern District of Texas (Case No. 2:24-cv-00148). The suit asserted two United States patents — US7057960B1, covering an integrated circuit random access memory capable of reading one or more data words in a single clock cycle, and US6240046B1, covering a method and architecture for reducing power consumption during memory device refresh operations.
The case closed on May 30, 2024, just 90 days after filing. InnoMemory filed a Notice of Dismissal under Rule 41(a)(1)(A)(i), representing that the case was dismissed without prejudice. The court accepted and acknowledged the notice, formally dismissing all pending claims and denying all remaining relief as moot. Because the dismissal is without prejudice, InnoMemory retains the right to reassert the same patents against the same or other defendants in future proceedings.
A 90-day lifecycle is notably short and suggests the parties may have reached a private resolution, or that InnoMemory elected to withdraw before significant litigation costs accumulated. The public record does not disclose any settlement agreement, licensing terms, or payment. The absence of a with-prejudice stipulation is commercially significant: it leaves InnoMemory’s patent assertions fully intact, and Texas Bank And Trust cannot claim res judicata protection from this dismissal.
Filing to Dismissed without Prejudice in 90 days
Resolved in 90 days — well below the E.D. Texas median for patent cases.
Voluntarily dismissed without prejudice: what the ruling means for both parties
Rule 41(a)(1)(A)(i): plaintiff’s unilateral right to exit
Under Rule 41(a)(1)(A)(i), a plaintiff may voluntarily dismiss an action without a court order before the defendant serves an answer or a motion for summary judgment. This mechanism gives plaintiffs a clean, low-cost exit. The court’s role is purely ministerial — it accepts and acknowledges the notice. No merits determination is made, and no judicial findings on infringement or validity attach to the record.
No merits adjudicationWithout prejudice: the distinction that keeps the claims alive
A dismissal without prejudice means InnoMemory’s patent claims are not extinguished. The company may refile the same assertions against Texas Bank And Trust, or direct the same patents at other defendants, in the future. The public record does not disclose whether a settlement was reached. Practitioners should note: this is not a dismissal with prejudice, and no assumption of resolution should be drawn from the bare docket entry alone.
Claims survive — refiling possibleTexas Bank And Trust: no legal victory, no permanent shield
Texas Bank And Trust avoided a merits judgment but cannot claim res judicata or collateral estoppel protection. The dismissal without prejudice provides no binding precedent and no formal finding of non-infringement or invalidity. The bank remains exposed to reassertion of the same patents if InnoMemory — or a successor — chooses to refile. Monitoring InnoMemory’s litigation activity against other defendants is advisable.
No preclusive effectMemory IC patent assertions: early exits rarely signal the end
Cases dismissed voluntarily at this early stage — before substantive motions — often suggest private negotiation, licensing discussions, or strategic portfolio repositioning. The two patents at issue cover foundational memory read-cycle and power-management architectures. Any company operating or deploying systems reliant on DRAM or low-power memory solutions should note that these patents remain active and enforceable. The early dismissal does not diminish their claim scope.
Patents remain enforceableFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | InnoMemory, LLC | Company | Patent assertion entity — holder of US7057960B1 and US6240046B1 (memory IC patents)Search in Eureka ↗ |
| Defendant | Texas Bank And Trust | Company | Texas-based regional bank and financial services institution.Search in Eureka ↗ |
| Plaintiff counsel | D. Scott Hemingway | Attorney | Counsel for InnoMemory, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Isaac Phillip Rabicoff | Attorney | Counsel for InnoMemory, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Hemingway & Hansen LLP | Law Firm | Representing InnoMemory, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Rabicoff Law LLC | Law Firm | Representing InnoMemory, LLCSearch in Eureka ↗ |
| Defendant counsel | Eric Hugh Findlay | Attorney | Counsel for Texas Bank And TrustSearch in Eureka ↗ |
| Defendant counsel | James Elmore Hudson , III | Attorney | Counsel for Texas Bank And TrustSearch in Eureka ↗ |
| Defendant counsel | William Powell Jensen | Attorney | Counsel for Texas Bank And TrustSearch in Eureka ↗ |
| Defendant law firm | Crain Caton & James PC – Houston | Law Firm | Representing Texas Bank And TrustSearch in Eureka ↗ |
| Defendant law firm | Findlay Craft PC | Law Firm | Representing Texas Bank And TrustSearch in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Texas Eastern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s order is purely administrative: it accepts InnoMemory’s Rule 41(a)(1)(A)(i) notice and formally closes the docket. No findings on infringement, validity, or claim construction are made. The phrase ‘WITHOUT PREJUDICE’ is expressly stated in both the plaintiff’s notice and the court’s order, confirming that InnoMemory retains full rights to reassert US7057960B1 and US6240046B1 in future proceedings. Texas Bank And Trust acquires no preclusive benefit from this termination.
US7057960B1 & US6240046B1 — IC Memory Read-Cycle and Refresh Power Reduction
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 relevant to high-throughput memory systems where burst-mode or wide-bus access is commercially significant. US6240046B1 covers a method and architecture for reducing power consumption during refresh operations in memory devices, a critical concern in mobile, embedded, and always-on systems where DRAM refresh cycles impose measurable energy overhead.
Together, these patents span two persistent commercial pressures in the memory semiconductor space: bandwidth efficiency and power minimisation. Any product line incorporating DRAM, low-power DRAM (LPDDR), or embedded memory with refresh cycles could fall within their scope. The fact that both patents survived this case without IPR challenge, claim construction, or invalidity analysis means their enforceability posture is unchanged — and their assertion value to InnoMemory remains intact for future campaigns.
Should your product team run an FTO against US7057960B1 and US6240046B1?
If your organisation designs, deploys, or integrates systems that rely on DRAM or LPDDR memory — including banking infrastructure, embedded computing, IoT devices, or data storage platforms — both patents warrant FTO assessment. US7057960B1’s multi-word single-cycle read claims and US6240046B1’s refresh power-reduction architecture are broad enough to implicate commodity and custom memory implementations alike. The E.D. Texas filing and rapid exit pattern suggests these patents are being actively wielded.
PatSnap Eureka’s FTO Search Agent lets you map the claim language of US7057960B1 and US6240046B1 against your product architecture in minutes. Upload your technical specifications or describe your memory subsystem in plain English, and Eureka will surface relevant prior art, identify claim overlap, and flag co-pending applications in InnoMemory’s portfolio — giving your legal and engineering teams a defensible, documented FTO position before litigation risk materialises.
Run a freedom-to-operate analysis on US7057960B1 to assess your product’s exposure
Run FTO in Eureka →Similar memory IC patent infringement cases in E.D. Texas
Explore patent infringement actions asserting IC memory and DRAM architecture patents in the Eastern District of Texas, including comparable PAE-driven enforcement campaigns.
What this case signals for the memory IC patent enforcement landscape
A 90-day voluntary dismissal without prejudice in E.D. Texas is rarely the end of the story for an assertive patent holder.
Early voluntary dismissals in E.D. Texas often precede licensing deals
When a patent assertion entity exits before the defendant has even answered, it typically signals one of two things: a quiet licensing resolution, or a tactical repositioning. Neither outcome benefits the defendant in the long run. Texas Bank And Trust has no preclusive shield, and the patents remain fully available for reassertion against the same or similar targets.
US7057960B1 and US6240046B1 remain live enforcement tools
Both patents survived this case without any validity challenge, claim construction ruling, or IPR filing entering the record. That clean slate makes them more — not less — dangerous for future defendants. Any company deploying DRAM-based or low-power memory architectures should treat these patents as active risk factors and conduct FTO analysis before dismissal signals fade from view.
InnoMemory v Texas — key questions answered
InnoMemory, LLC filed a patent infringement suit against Texas Bank And Trust in the Eastern District of Texas on March 1, 2024, asserting US7057960B1 and US6240046B1. The case was voluntarily dismissed without prejudice by InnoMemory under Rule 41(a)(1)(A)(i) on May 30, 2024, just 90 days after filing. No merits determination was made.
US7057960B1 covers an integrated circuit random access memory capable of reading either one or more than one data word in a single clock cycle. US6240046B1 covers a method and architecture for reducing power consumption in memory devices during refresh operations. Both patents relate to DRAM and low-power memory architectures with broad potential applicability.
A dismissal without prejudice means the case was terminated without any finding on the merits of infringement or validity. Texas Bank And Trust cannot rely on this dismissal as a preclusive shield — InnoMemory retains the right to refile the same patent claims against the same defendant or others at any future time. The bank acquires no res judicata or collateral estoppel protection.
Yes. Because the dismissal is without prejudice, InnoMemory is not barred from reasserting US7057960B1 and US6240046B1 against Texas Bank And Trust in a future action, subject to applicable statutes of limitations. The court’s order expressly confirms the without-prejudice nature of the termination.
Early voluntary dismissals in patent cases — particularly in E.D. Texas — can suggest several scenarios: a private licensing agreement was reached, settlement negotiations are ongoing, the plaintiff is repositioning its enforcement strategy, or the plaintiff determined the specific defendant was not the optimal target. The public record in this case does not disclose the reason, and no settlement terms are publicly available.
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