Linfo IP v. The Knot WorldWide: Voluntary Dismissal Without Prejudice in 50 Days
Linfo IP, LLC asserted US9430131B1 against wedding marketplace platform The Knot WorldWide, Inc. in the Southern District of New York, targeting review platform functionality on theknot.com. The plaintiff voluntarily dismissed all claims without prejudice just 50 days after filing, before the defendant filed any responsive pleading.
A Pre-Answer Voluntary Dismissal Leaves the Door Open for Linfo IP
On February 26, 2025, Linfo IP, LLC filed an infringement action in the U.S. District Court for the Southern District of New York against The Knot WorldWide, Inc., the operator of theknot.com, a leading wedding vendor marketplace. The complaint asserted US9430131B1 (application no. US14/225422), a patent directed to systems for instructing customers on the use of review platforms. The accused product was The Knot’s vendor review functionality, specifically the marketplace listing and review guidance features accessible via its website and product instruction materials.
The case closed on April 17, 2025, just 50 days after filing, when Linfo IP filed a notice of voluntary dismissal under Federal Rule of Civil Procedure 41(a)(1)(A)(i). Because The Knot WorldWide had not yet answered the complaint or filed a motion for summary judgment, Linfo IP was entitled to dismiss as of right — without court approval. Crucially, the dismissal was expressly stated to be without prejudice as to the asserted patent, meaning the claims are not extinguished. Each party was directed to bear its own costs, expenses, and attorneys’ fees.
A 50-day pre-answer resolution is consistent with either early settlement negotiations, a licensing discussion, or a tactical reassessment by the plaintiff. The public record does not disclose whether any licensing agreement was reached. The without-prejudice designation is commercially significant: Linfo IP retains the ability to refile the same infringement claims against The Knot WorldWide or assert the same patent against other targets. What drove the dismissal — a deal, a demand letter fulfilled, or a decision to pursue other defendants first — remains unknown from the docket.
Filing to Voluntary dismissal in 50 days
50 days — resolved before defendant’s first responsive pleading was due
Voluntarily dismissed: what Rule 41 without prejudice means for both parties
Rule 41(a)(1)(A)(i): dismissal as of right, no court approval needed
Federal Rule 41(a)(1)(A)(i) permits a plaintiff to voluntarily dismiss an action without court order at any time before the opposing party serves an answer or a motion for summary judgment. Linfo IP exercised this right after 50 days. Because The Knot WorldWide had not yet responded, the dismissal took effect automatically upon filing. This is the most procedurally straightforward exit available to a plaintiff in federal litigation.
Pre-answer dismissal as of rightWithout prejudice: the critical qualifier in this dismissal
A dismissal without prejudice does not resolve the merits — it leaves the plaintiff free to refile the same claims. The notice here expressly states the dismissal is without prejudice as to the asserted patent. This distinguishes it from a with-prejudice dismissal, which would bar refiling. The public record is silent on whether the parties reached any agreement; the docket alone does not allow a conclusion either way.
Claims survive dismissalLinfo IP retains full optionality on US9430131B1
By dismissing without prejudice, Linfo IP preserves the right to reassert US9430131B1 against The Knot WorldWide in a future action, subject to applicable statutes of limitations and any tolling considerations. It also retains the ability to assert the patent against other parties in the review platform or wedding marketplace technology space. No cost liability was imposed, limiting the financial exposure from this filing.
Patent enforcement preservedThe Knot exits this action but faces potential refiling risk
The Knot WorldWide avoided the cost and burden of answering the complaint and bears no court-ordered fee exposure from this action. However, the without-prejudice dismissal means the threat has not been extinguished. If no licensing resolution was reached, The Knot may face a refiled action. Companies in this position typically conduct FTO analysis on the asserted patent and assess design-around options before any refiling materialises.
Exposure not fully resolvedFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Linfo IP, LLC | Company | Patent assertion entity — holder of US9430131B1 covering web-based review platform instruction systemsSearch in Eureka ↗ |
| Defendant | The Knot WorldWide, Inc. | Company | The Knot WorldWide, Inc. — operator of theknot.com, a leading online wedding vendor marketplace platformSearch in Eureka ↗ |
| Plaintiff counsel | David John Hoffman | Attorney | Counsel for Linfo IP, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Law Office David J. Hoffman | Law Firm | Representing Linfo IP, LLCSearch in Eureka ↗ |
| Defendant counsel | Andrew Bennett Kratenstein | Attorney | Counsel for The Knot WorldWide, Inc.Search in Eureka ↗ |
| Defendant counsel | Kevin J. Meek | Attorney | Counsel for The Knot WorldWide, Inc.Search in Eureka ↗ |
| Defendant counsel | Kyle S. Sorenson | Attorney | Counsel for The Knot WorldWide, Inc.Search in Eureka ↗ |
| Defendant law firm | McDermott Will & Emery LLP | Law Firm | Representing The Knot WorldWide, Inc.Search in Eureka ↗ |
| Presiding judge | Judge Gregory H. Woods | Judge | New York Southern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The voluntary dismissal notice invokes Rule 41(a)(1)(A)(i) and expressly designates the dismissal as without prejudice to the asserted patent, US9430131B1. This phrasing is deliberate: it preserves Linfo IP’s right to refile and signals that no final adjudication on the merits occurred. The cost-neutrality clause — each party bears its own fees — is standard for pre-answer dismissals of this type. The absence of any settlement or licensing disclosure means the commercial resolution, if any, remains confidential.
US9430131B1 — web-based review platform customer instruction systems
US9430131B1, filed under application number US14/225422, is directed to systems and methods for instructing customers and others on the use of review platforms delivered via web interfaces. The patent sits within the broader domain of online user experience guidance and review solicitation technology — a functional layer present in virtually any marketplace or local services platform that prompts users to leave or manage reviews. The granted patent number indicates it reached issuance, and the B1 designation confirms it issued without prior publication.
From a competitive intelligence standpoint, US9430131B1 is potentially relevant to any online marketplace that provides instructional content — whether via website UI, product manuals, or guided workflows — to help vendors or customers navigate review submission. The wedding marketplace vertical is one application, but the claim scope may extend to hospitality, home services, or any platform with a structured review guidance feature. Linfo IP’s willingness to assert this patent in federal court, and its express preservation of rights on dismissal, suggests it views the patent as commercially viable for continued enforcement.
Should your platform run an FTO analysis against US9430131B1?
Any company operating an online marketplace with customer-facing review guidance features — instructional copy, onboarding flows, vendor review prompts, or help documentation — should assess whether US9430131B1’s claims read on their product. The Knot case demonstrates that this patent has already been asserted against a major marketplace operator. The without-prejudice dismissal means further assertions are possible, making proactive FTO analysis a prudent step for product and IP teams in adjacent verticals.
PatSnap Eureka’s FTO Search Agent enables product teams to map the independent claims of US9430131B1 against their specific product architecture and documentation flows. By surfacing the full claim language, prosecution history, and prior art landscape in one workflow, Eureka helps IP and R&D teams identify design-around options and quantify exposure — before a demand letter arrives.
Run a freedom-to-operate analysis on US9430131B1 to assess your product’s exposure
Run FTO in Eureka →Similar patent infringement cases involving web platform and review system patents
Cases asserting web-based review platform and user instruction patents in the Southern District of New York and related federal courts, involving online marketplace operators.
What this case signals for the online marketplace and review platform IP landscape
A 50-day pre-answer dismissal without prejudice is a pattern worth monitoring in patent assertion campaigns targeting web platform operators.
Pre-answer dismissals can signal demand-letter strategy or portfolio sequencing
When a plaintiff dismisses before the defendant answers, it frequently suggests either a quick licensing resolution or a decision to pursue other targets first. Online marketplace operators receiving infringement notices on review platform patents should treat a without-prejudice dismissal as a pause, not a resolution — and prepare accordingly.
US9430131B1 remains active and assertable after this dismissal
The express without-prejudice language preserves Linfo IP’s enforcement rights. Any company operating web-based customer review guidance systems — particularly in the wedding, hospitality, or local services marketplace space — should assess whether their product falls within the claims of US9430131B1 before assuming the risk has passed.
Linfo v Knot — key questions answered
Linfo IP, LLC filed a patent infringement action against The Knot WorldWide, Inc. in the Southern District of New York on February 26, 2025, asserting US9430131B1. The plaintiff voluntarily dismissed all claims without prejudice on April 17, 2025, after 50 days, before the defendant filed any responsive pleading. Each party bore its own costs and fees.
A without-prejudice dismissal under Rule 41(a)(1)(A)(i) does not extinguish the underlying patent claims. Linfo IP retains the right to refile infringement claims based on US9430131B1 against The Knot WorldWide or assert the patent against other defendants. The dismissal resolves only this specific action, not the patent’s enforceability.
US9430131B1 (application US14/225422) covers systems for instructing customers and others on the use of review platforms via web-based interfaces. In the Linfo IP action, the accused product was The Knot’s vendor marketplace review guidance functionality accessible at theknot.com and through associated product instruction materials.
The public record does not disclose the reason. Common drivers for pre-answer voluntary dismissals include early licensing resolution, strategic reassessment of claim scope, a decision to refile with a stronger complaint, or sequencing within a broader assertion campaign. The without-prejudice designation suggests Linfo IP intends to preserve its options rather than abandon enforcement.
Linfo IP, LLC was represented by the Law Office of David J. Hoffman, with attorney David John Hoffman on record. The Knot WorldWide, Inc. was represented by McDermott Will & Emery LLP, with Andrew Bennett Kratenstein, Kevin J. Meek, and Kyle S. Sorenson appearing as counsel for the defendant.
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