Intercurrency Software v. Skrill Limited: Voluntary Dismissal Without Prejudice
Intercurrency Software LLC asserted two patents covering consolidated multi-currency trading platforms against Skrill Limited in the Eastern District of Texas. The plaintiff voluntarily dismissed all claims without prejudice after 148 days, with each party bearing its own costs.
Currency platform patent suit ends before merits ruling in E.D. Texas
On July 9, 2025, Intercurrency Software LLC filed suit against Skrill Limited in the U.S. District Court for the Eastern District of Texas, assigned to Judge Rodney Gilstrap. The complaint asserted infringement of US10062107B1 and US11620701B1, both directed to consolidated platforms for trading assets across different currencies. Skrill Limited, an international payments and digital wallet provider, was accused of offering a platform that allegedly practices the claimed inventions.
The case closed on December 4, 2025, when Intercurrency Software filed a Notice of Voluntary Dismissal under Federal Rule of Civil Procedure 41(a)(1)(A)(i). The court accepted and acknowledged the dismissal without prejudice, meaning no merits adjudication occurred and Intercurrency Software retains the right to refile claims. Each party was ordered to bear its own legal costs, expenses, and attorneys’ fees — a standard outcome under Rule 41 self-executing dismissals.
The 148-day duration suggests the case resolved before substantive milestones such as claim construction or discovery disputes. The public record does not disclose whether a settlement was reached, a licensing arrangement was entered, or Intercurrency Software identified a strategic reason to withdraw. The without-prejudice designation preserves all options for the patent holder, while leaving Skrill without a merits-based resolution or invalidity determination.
Filing to Voluntary dismissal in 148 days
148-day lifespan — resolved before most district court patent cases reach claim construction
Dismissed without prejudice: what the Rule 41 exit means for both parties
Rule 41(a)(1)(A)(i): plaintiff’s right to dismiss without court order
FRCP 41(a)(1)(A)(i) permits a plaintiff to dismiss an action without a court order by filing a notice before the defendant serves an answer or a motion for summary judgment. Such a dismissal is self-executing and without prejudice by default unless the notice states otherwise. The court’s order here confirms and acknowledges what is effectively an automatic procedural event — no judicial merits review occurred.
No merits ruling issuedWithout prejudice confirmed: refiling remains an option
The court’s order expressly states dismissal is without prejudice, meaning Intercurrency Software retains the right to assert US10062107B1 and US11620701B1 against Skrill or other defendants in future proceedings, subject to applicable statutes of limitations and any intervening IPR outcomes. The public record does not disclose whether a confidential settlement or licence underlies this dismissal — the without-prejudice designation alone does not rule out a negotiated resolution.
Claims preserved for refilingSkrill walks away without an invalidity or non-infringement ruling
While Skrill avoids an adverse infringement finding, it does not obtain the clean-exit protections of a with-prejudice dismissal or a covenant not to sue. Without a merits ruling, neither patent has been adjudicated invalid or not infringed. Skrill may wish to evaluate whether to pursue inter partes review of either patent to obtain a more durable shield against future assertion by Intercurrency Software or any subsequent patent holder.
No invalidity determinationCurrency platform operators remain exposed to both asserted patents
The patents-in-suit were never tested on the merits, leaving their validity and claim scope unresolved. Other operators of consolidated multi-currency trading platforms — fintechs, digital wallets, FX brokers — face the same exposure Skrill faced. The without-prejudice exit preserves Intercurrency Software’s assertion leverage, and the cost-neutral resolution removes any fee-deterrence effect that might have discouraged future filings.
Sector exposure unresolvedFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Intercurrency Software, LLC | Company | Patent assertion entity — holder of US10062107B1 and US11620701B1 covering currency trading platformsSearch in Eureka ↗ |
| Defendant | Skrill Limited | Individual | Skrill Limited — international digital payments and multi-currency wallet providerSearch in Eureka ↗ |
| Plaintiff counsel | Christopher A. Honea | Attorney | Counsel for Intercurrency Software, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Garteiser Honea PLLC | Law Firm | Representing Intercurrency Software, LLCSearch in Eureka ↗ |
| Defendant counsel | Jon Bentley Hyland | Attorney | Counsel for Skrill LimitedSearch in Eureka ↗ |
| Defendant law firm | Hilgers PLLC | Law Firm | Representing Skrill LimitedSearch in Eureka ↗ |
| Presiding judge | Judge Rodney Gilstrap | Judge | Texas Eastern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s order tracks the self-executing nature of FRCP 41(a)(1)(A)(i) — the judge accepted and acknowledged the dismissal rather than granting it, reflecting that no judicial discretion was required. The without-prejudice designation is the operative risk factor: neither patent has been construed, invalidated, or found not infringed. The cost-bearing instruction is standard for Rule 41(a)(1) dismissals and carries no fee-shifting signal under 35 U.S.C. § 285.
US10062107B1 & US11620701B1 — Consolidated multi-currency asset trading platforms
US10062107B1 (Application No. US11/736583) and US11620701B1 (Application No. US17/948217) are both assigned to Intercurrency Software LLC and cover technology relating to consolidated platforms for trading financial assets denominated in or exchangeable across different currencies. The later patent’s application number suggests a continuation or continuation-in-part relationship, which typically broadens or refines claim coverage derived from the earlier priority chain.
For the fintech and digital payments sector, these patents represent a potentially broad claim footprint over multi-currency trading infrastructure — a core component of digital wallets, FX platforms, and cross-border payment services. The absence of any claim construction record means operators cannot rely on judicial narrowing. Skrill’s status as a major digital payments brand, and the without-prejudice dismissal, suggests these patents may resurface in enforcement campaigns targeting the broader payments ecosystem.
Should you run an FTO against US10062107B1 and US11620701B1?
Any company operating a platform that consolidates trading, conversion, or exchange of assets across multiple currencies — including digital wallets, FX brokers, neobanks, and crypto-to-fiat ramps — should evaluate freedom to operate against these two patents. The absence of claim construction or invalidity rulings means the broadest reasonable claim interpretation governs, and product teams cannot rely on litigation narrowing that never occurred.
PatSnap Eureka’s FTO Search Agent can map the claim language of US10062107B1 and US11620701B1 against your product architecture, identify prior art that could support an IPR petition, and surface the full Intercurrency Software portfolio for related continuation risk. Given the without-prejudice dismissal, acting before any new complaint is filed is materially lower cost than responding to litigation.
Run a freedom-to-operate analysis on US10062107B1 to assess your product’s exposure
Run FTO in Eureka →Similar currency trading platform patent cases in E.D. Texas
Cases involving fintech payment platform patents before Judge Gilstrap in the Eastern District of Texas follow identifiable assertion and resolution patterns worth benchmarking.
What this case signals for the fintech currency-platform IP landscape
An unresolved voluntary dismissal in E.D. Texas keeps two currency trading patents fully live — and actionable against the broader fintech sector.
Without-prejudice dismissals preserve full enforcement leverage for the patent holder
Intercurrency Software exited without any covenant not to sue or adverse merits ruling. Both US10062107B1 and US11620701B1 remain valid, enforceable, and unlitigated on substance. Fintech platforms handling multi-currency asset trading should treat these patents as active risk assets and assess exposure before expanding product scope.
E.D. Texas case volume and cost economics favour serial assertion strategies
Judge Gilstrap’s docket is among the most active patent dockets in the US. A fast voluntary dismissal with no fee award signals low litigation cost for the plaintiff. Companies in the digital payments and currency conversion space should monitor Intercurrency Software’s docket activity for new filings against competitors or themselves.
Intercurrency v Skrill — key questions answered
A without-prejudice dismissal under FRCP 41(a)(1)(A)(i) does not bar Intercurrency Software from refiling claims asserting US10062107B1 or US11620701B1 against Skrill or any other defendant. No merits ruling was issued, so neither patent’s validity nor infringement scope was adjudicated. Intercurrency Software retains full enforcement rights subject to applicable statutes of limitations.
The application numbers suggest US11620701B1 (App. No. US17/948217) is a later-filed continuation from the same family as US10062107B1 (App. No. US11/736583). Continuation patents typically claim priority to an earlier application while pursuing different or refined claim scope. Companies should analyse both patents together, as continuation claims can cover product variations not captured by the parent.
The public record does not disclose the reason for dismissal. Common drivers include a confidential settlement, a licensing agreement, a strategic decision to refile in a different venue, or a reassessment of infringement evidence. The without-prejudice designation and cost-neutral outcome are consistent with any of these scenarios. No inference of weakness on either side can be drawn from the public docket alone.
The court directed each party to bear its own costs, expenses, and attorneys’ fees. Under FRCP 41(a)(1), this is standard and does not represent a fee-shifting award or an exceptional-case finding under 35 U.S.C. § 285. Neither party received a financial penalty, and the order carries no precedential signal about litigation conduct.
Yes, particularly for companies operating consolidated currency trading or digital wallet platforms. US10062107B1 and US11620701B1 have never been subject to claim construction or invalidity adjudication, leaving their scope at the broadest reasonable interpretation. The without-prejudice dismissal against Skrill signals the patents remain fully live. An FTO analysis and consideration of IPR petitions is commercially prudent for exposed platform operators.
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