InnoMemory v. Texas Capital Bancshares: Memory Patent Suit Dismissed Without Prejudice
InnoMemory, LLC filed suit against Texas Capital Bancshares, Inc. in the Eastern District of Texas asserting two patents covering integrated circuit RAM and low-power memory refresh architecture. The case closed in just 98 days when InnoMemory voluntarily dismissed without prejudice under Rule 41, leaving the door open for future action.
A Swift Exit: InnoMemory’s Memory Patent Claims Dropped Before Merits
InnoMemory, LLC filed Case No. 2:24-cv-00147 on March 1, 2024 in the Eastern District of Texas against Texas Capital Bancshares, Inc., asserting infringement of US7057960B1, directed to integrated circuit RAM capable of burst-mode multi-word reads in a single clock cycle, and US6240046B1, covering a method and architecture for reducing power consumption in memory refresh operations. The complaint framed the action as a standard infringement claim.
The case ended on June 7, 2024 when InnoMemory filed a Notice of Dismissal under Rule 41(a)(1)(A)(i), which permits a plaintiff to dismiss unilaterally before the defendant files an answer or motion for summary judgment. The court accepted the notice and closed the docket, dismissing all claims without prejudice and denying all pending relief as moot. No merits determination was reached and no costs were awarded.
At 98 days, the resolution is notably swift and suggests the dispute was resolved — or strategically paused — very early in proceedings. The without-prejudice designation means InnoMemory retains the right to refile on the same patents against the same or different defendants. Whether a confidential settlement, licensing agreement, or tactical repositioning drove the dismissal is not discernible from the public record.
Filing to Voluntary dismissal in 98 days
98 days — resolved well below the E.D. Texas median for patent cases
Voluntarily dismissed: what the without-prejudice ruling means for both parties
Rule 41(a)(1)(A)(i): plaintiff’s unilateral exit right
Under Rule 41(a)(1)(A)(i), a plaintiff may dismiss an action without court order — and without prejudice — before the defendant serves an answer or a motion for summary judgment. The court here accepted and acknowledged the notice, formally closing the case. This procedural mechanism requires no judicial approval and leaves no merits ruling on record.
No merits adjudicatedWithout prejudice: the right to refile remains intact
A dismissal without prejudice does not bar InnoMemory from reasserting the same patents — against Texas Capital Bancshares or any other party — in a future action. This contrasts sharply with a dismissal with prejudice, which would extinguish the claims permanently. The public record does not disclose whether a settlement or license underpins this exit, leaving refiling risk live for the defendant.
Refiling risk remainsTexas Capital Bancshares escapes judgment — but not exposure
Texas Capital Bancshares obtained no declaratory judgment of non-infringement or invalidity. While the immediate threat is lifted, the without-prejudice dismissal means the bank cannot treat this as a final resolution. No fee award under 35 U.S.C. § 285 was made, consistent with early-stage exits before substantial litigation costs accrue. Future exposure to the same patents persists.
No invalidity findingMemory patent portfolios retain assertive leverage post-dismissal
Early voluntary dismissals in E.D. Texas patent cases often signal behind-the-scenes licensing discussions or a strategic pivot to a different defendant or venue. For financial institutions and technology operators relying on RAM and memory management architectures, US7057960B1 and US6240046B1 remain active enforcement tools. Companies in adjacent sectors should monitor InnoMemory’s filing activity for signs of a broader campaign.
Portfolio remains liveFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | InnoMemory, LLC | Company | Memory patent assertion entity — holder of US7057960B1 and US6240046B1Search in Eureka ↗ |
| Defendant | Texas Capital Bancshares, Inc., | Company | Texas-based bank holding company and financial services groupSearch 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 ↗ |
| Defendant counsel | D. Scott Hemingway | Attorney | Counsel for Texas Capital Bancshares, Inc.,Search in Eureka ↗ |
| Defendant counsel | Eric Hugh Findlay | Attorney | Counsel for Texas Capital Bancshares, Inc.,Search in Eureka ↗ |
| Defendant counsel | Jordan Christine Strauss | Attorney | Counsel for Texas Capital Bancshares, Inc.,Search in Eureka ↗ |
| Defendant counsel | Michael Andrew McCabe | Attorney | Counsel for Texas Capital Bancshares, Inc.,Search in Eureka ↗ |
| Defendant law firm | Findlay Craft PC | Law Firm | Representing Texas Capital Bancshares, Inc.,Search in Eureka ↗ |
| Defendant law firm | Hemingway & Hansen LLP | Law Firm | Representing Texas Capital Bancshares, Inc.,Search in Eureka ↗ |
| Defendant law firm | Munck Wilson Mandala LLP (Dallas) | Law Firm | Representing Texas Capital Bancshares, Inc.,Search in Eureka ↗ |
| Defendant law firm | Munck Wilson Mandala LLP | Law Firm | Representing Texas Capital Bancshares, Inc.,Search in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Texas Eastern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s order tracks the precise language of the plaintiff’s notice, confirming a Rule 41(a)(1)(A)(i) dismissal without prejudice. Critically, the court neither evaluated the merits of the infringement allegations nor made any finding on validity or enforceability of US7057960B1 or US6240046B1. The denial of all pending relief as moot signals no substantive motions had been decided. Both patents survive the litigation legally unscathed and remain fully enforceable assets in InnoMemory’s portfolio.
US7057960B1 & US6240046B1 — Integrated Circuit RAM and Memory Refresh Technology
US7057960B1 (application no. US10/629667) covers an integrated circuit random access memory capable of reading either one or more than one data word in a single clock cycle — a burst-mode read architecture that underpins high-throughput memory performance. US6240046B1 (application no. US09/502983) claims a method and architecture specifically designed to reduce power consumption in memory devices during refresh operations, a critical efficiency concern in both embedded and enterprise memory systems.
Both patents address foundational memory design challenges that remain commercially relevant in modern silicon. Low-power refresh and burst-mode read capability are core features in DRAM, SRAM, and embedded memory used across financial services infrastructure, networking equipment, and consumer electronics. Their assertion against a bank holding company — rather than a semiconductor manufacturer — is consistent with a downstream end-user enforcement strategy, which typically yields faster licensing resolutions and avoids validity attacks from technically sophisticated opponents.
Should your team run an FTO against US7057960B1 and US6240046B1?
Any organisation designing, sourcing, or deploying integrated circuits with burst-read RAM or power-optimised memory refresh should assess exposure to these two patents. The dismissal without prejudice means InnoMemory retains full enforcement rights. Financial institutions, cloud infrastructure providers, and embedded system vendors using third-party memory ICs may carry indirect infringement risk if their suppliers have not secured licences.
PatSnap Eureka’s FTO Search Agent can map the independent and dependent claims of US7057960B1 and US6240046B1 against your product architecture, identify prior art that might support an invalidity position, and surface related InnoMemory filings that indicate the scope and targets of an active enforcement campaign. Running this analysis now — before a notice letter arrives — puts your team in the strongest negotiating position.
Run a freedom-to-operate analysis on US7057960B1 to assess your product’s exposure
Run FTO in Eureka →Similar Memory Patent Infringement Cases in E.D. Texas
Cases involving RAM architecture and memory refresh patents in the Eastern District of Texas, including comparable early-stage voluntary dismissals and end-user enforcement patterns.
What this case signals for the memory patent IP landscape
Early exits in E.D. Texas patent suits often carry more strategic signal than they appear. Here is what practitioners should note.
Without-prejudice dismissals keep patent holders’ options fully open
InnoMemory’s Rule 41 exit preserves every enforcement option. Defendants who receive a without-prejudice dismissal should not treat it as a win — the same patents can be asserted again, potentially in a different venue or against a broader group of defendants. Monitoring the plaintiff’s future filings is essential due diligence.
Financial sector defendants face growing exposure to foundational memory patents
Banking infrastructure increasingly depends on high-performance RAM and power-efficient memory architectures. Patent assertion entities holding foundational memory patents like US7057960B1 and US6240046B1 may target financial institutions as end-users of infringing technology. In-house teams at banks should audit third-party hardware and software stacks for exposure.
InnoMemory v Texas — key questions answered
The dismissal without prejudice means InnoMemory chose to withdraw its claims under Rule 41(a)(1)(A)(i) before Texas Capital filed an answer. No merits ruling was made. InnoMemory retains the right to refile the same infringement claims based on US7057960B1 and US6240046B1 against Texas Capital or any other party in the future.
InnoMemory asserted 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 device refresh operations. Both patents remain active and enforceable following the dismissal.
The 98-day duration is consistent with early-stage resolution before any substantive litigation activity, such as an answer, claim construction, or discovery. This timeline typically suggests a licensing discussion, a decision to redirect the campaign, or a confidential settlement. The public record does not specify the reason for the early exit.
No. Because the court dismissed all claims as moot and made no merits ruling, there is no judicial determination on the validity, enforceability, or infringement scope of US7057960B1 or US6240046B1. Neither patent was found valid or invalid, and no claim construction was issued.
The Eastern District of Texas is a historically plaintiff-friendly patent venue known for efficient case management and a well-developed body of patent law. Filing there signals a deliberate enforcement strategy. However, following the Supreme Court’s TC Heartland ruling, venue options have narrowed. Texas Capital Bancshares has a significant Texas presence, making E.D. Texas a defensible venue choice for InnoMemory.
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