Realtime Tracker v. Relx — Federal Circuit Affirms Billable Timekeeper Patent
Realtime Tracker, Inc. brought an infringement action against Relx, Inc. asserting US8229810B2, covering a realtime billable timekeeper method, system and apparatus. After 575 days of appellate proceedings at the Federal Circuit, the court issued a single-word mandate: AFFIRMED.
Federal Circuit closes Realtime Tracker’s appeal against Relx with a full affirmance
Realtime Tracker, Inc. filed this infringement appeal at the U.S. Court of Appeals for the Federal Circuit on 17 April 2023, targeting Relx, Inc. The underlying action centred on US8229810B2, a patent covering a realtime billable timekeeper method, system and apparatus — technology relevant to automated time-capture and billing workflow systems. Relx, a global information analytics and legal research services company, was the named appellee throughout the 575-day proceeding.
On 12 November 2024 the Federal Circuit issued its judgment — a clean AFFIRMED. That disposition means the court found no reversible legal or factual error in the decision reached by the tribunal below. The affirmance leaves the lower ruling fully intact, and Realtime Tracker’s appellate challenge to that outcome is now exhausted at the Federal Circuit level. The basis of termination is recorded as ‘Appeal Dismissed’, which is consistent with an affirmance that extinguishes the appeal without remand.
A 575-day appellate timeline is broadly consistent with Federal Circuit norms for patent infringement appeals that proceed to a merits decision. The public record does not disclose the specific grounds on which Realtime Tracker challenged the lower ruling, nor whether validity, claim construction, or infringement findings were the central disputes. What the record confirms is that none of those arguments proved sufficient to move the panel. The outcome strengthens the precedential posture of the lower decision and raises the litigation cost for any future challenge to the same patent family.
Filing to Appeal Dismissed in 575 days
575 days — longer than the median Federal Circuit merits appeal (approx. 18 months)
Federal Circuit affirms: what the ruling means for both parties
AFFIRMED: the Federal Circuit found no reversible error below
An affirmance at the Federal Circuit means the appellate panel reviewed the lower court’s record and concluded that no reversible legal or factual error was committed. The lower decision is left wholly intact. The Federal Circuit applies de novo review to legal questions such as claim construction, and clear-error review to factual findings — clearing both bars is required for a reversal. Realtime Tracker did not clear them.
Lower ruling standsRealtime Tracker’s patent survives this appellate challenge
For Realtime Tracker as appellant, the affirmance is an adverse result — it confirms the lower ruling against it and exhausts Federal Circuit review. However, if the underlying decision did not invalidate US8229810B2, the patent itself survives and may remain enforceable against other parties. The affirmance signals that the asserted claims withstood appellate scrutiny in this proceeding, which may strengthen Realtime Tracker’s leverage in future licensing or enforcement actions.
Patent enforceability intactRelx prevails: appellate options for Realtime Tracker now severely limited
Relx, Inc. as appellee achieves a full appellate victory. Realtime Tracker’s options after a Federal Circuit affirmance are narrow: a petition for rehearing en banc (rarely granted) or a petition for certiorari to the U.S. Supreme Court (even rarer in patent cases). The practical effect is that this dispute is commercially resolved in Relx’s favour at the Federal Circuit level, and the cost and risk of further pursuit falls entirely on Realtime Tracker.
Relx appellate win confirmedAffirmance raises the bar for future challenges to billable timekeeper IP
A Federal Circuit affirmance signals that the legal and factual record supporting the lower decision was robust. For competitors or licensees in the automated time-tracking and legal billing technology sector, this outcome suggests that US8229810B2 and the lower court’s treatment of it carry strengthened precedential weight. Any future invalidity challenge — whether via IPR or litigation — will need to contend with an appellate record that was tested and found adequate.
Higher challenge thresholdFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | REALTIME TRACKER, INC. | Company | Automated billing technology IP holder — asserting US8229810B2 covering realtime timekeeper systemsSearch in Eureka ↗ |
| Defendant | Relx, Inc. | Company | Relx, Inc. — global information analytics and legal services group; appellee in this Federal Circuit proceedingSearch in Eureka ↗ |
| Plaintiff counsel | Robert K. Goethals | Attorney | Counsel for REALTIME TRACKER, INC.Search in Eureka ↗ |
| Plaintiff law firm | Leichtman Law PLLC | Law Firm | Representing REALTIME TRACKER, INC.Search in Eureka ↗ |
| Defendant counsel | John David Luken | Attorney | Counsel for Relx, Inc.Search in Eureka ↗ |
| Defendant counsel | Oleg Khariton | Attorney | Counsel for Relx, Inc.Search in Eureka ↗ |
| Defendant law firm | Dinsmore & Shohl, LLP | Law Firm | Representing Relx, Inc.Search in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Court of Appeals for the Federal CircuitSearch in Eureka ↗ |
Official order — verbatim text
The Federal Circuit’s judgment — ‘AFFIRMED’ — is terse by design: it signals a clean merits affirmance with no remand, no partial reversal, and no modification of the lower ruling. Under Federal Circuit practice, affirmance requires the panel to find that, on every dispositive issue raised on appeal — whether claim construction, infringement analysis, or validity — the lower tribunal committed no reversible error. The absence of any qualifying language or remand instruction suggests the panel was unpersuaded by each ground of appeal advanced by Realtime Tracker, leaving Relx’s position below fully vindicated.
US8229810B2 — Realtime Billable Timekeeper Method, System and Apparatus
US8229810B2, filed under application number US10/787607, protects a realtime billable timekeeper method, system and apparatus. The invention sits at the intersection of professional services workflow and automated time-capture technology — broadly covering systems that record, track and process billable time in real time. Application filing in the early-to-mid 2000s timeframe (consistent with a US10/ serial number) means this patent predates the widespread adoption of cloud-based legal practice management platforms, giving it potentially broad claim coverage over architectures now common in legal tech.
The strategic significance of US8229810B2 extends beyond the Relx dispute. Legal billing automation is now embedded across law firm practice management systems, corporate legal department platforms, and e-billing vendors. Any SaaS or on-premise product that captures attorney time in real time, associates it with a matter, and routes it to a billing workflow may fall within the asserted claim perimeter — depending on the constructions applied below. The Federal Circuit’s affirmance means those constructions carry appellate weight, making this patent a live commercial risk for the broader legal technology market.
Should your legal tech product be cleared against US8229810B2?
R&D and product teams building or acquiring automated time-tracking, matter management, or legal billing systems should treat US8229810B2 as a priority FTO target following this Federal Circuit affirmance. The patent’s early priority date, combined with now-settled claim constructions, means the enforceable scope may reach further into modern legal tech architectures than the product name alone suggests. Any platform feature that captures billable time in real time warrants a structured clearance review.
PatSnap Eureka’s FTO Search Agent can map the claims of US8229810B2 against your product specification, identify prosecution history estoppel that may limit scope, surface prior art that could support an IPR petition, and monitor the continuation family for newly granted claims. For legal tech companies operating under ongoing enforcement risk from this patent family, automated monitoring alerts are available through Eureka’s portfolio watch tools.
Run a freedom-to-operate analysis on US8229810B2 to assess your product’s exposure
Run FTO in Eureka →Similar Federal Circuit patent appeals in legal tech and billing software
Explore comparable Federal Circuit patent infringement appeals involving automated time-tracking, billing workflow, and professional services technology systems.
What this case signals for the legal tech and billing software IP landscape
A Federal Circuit affirmance in a billable timekeeper patent case has measurable consequences for IP enforcement strategy across legal and professional services technology.
Affirmances entrench lower-court claim construction rulings
When the Federal Circuit affirms without remand, any claim construction adopted below is now appellate-tested. Companies operating in the automated billing and time-capture space should treat the construed claim scope of US8229810B2 as settled for FTO purposes — designing around requires engaging that construction directly.
Relx’s defence strategy provides a replicable litigation template
Dinsmore & Shohl’s successful defence of Relx across a 575-day Federal Circuit proceeding suggests a defence strategy that held up to multi-standard appellate review. Firms facing similar assertions from Realtime Tracker or comparable patent holders in the billing tech space should examine this record for procedural and substantive lessons.
REALTIME v Relx — key questions answered
The Federal Circuit affirmed the lower court’s decision on 12 November 2024, finding no reversible error in the ruling below. The case concerned US8229810B2, a realtime billable timekeeper patent asserted by Realtime Tracker, Inc. against Relx, Inc. The affirmance leaves the lower ruling fully intact and exhausts Realtime Tracker’s appellate options at the Federal Circuit level.
An affirmance by the Federal Circuit means the appellate panel reviewed the lower tribunal’s record and found no reversible legal or factual error on the issues presented. The lower decision stands unchanged. The Federal Circuit applies de novo review to legal questions like claim construction and clear-error review to factual findings — an affirming panel found the lower court correct on all dispositive grounds.
The patent at issue is US8229810B2, filed under application number US10/787607. It covers a realtime billable timekeeper method, system and apparatus — technology relating to automated time-capture and billing workflow systems used in professional services contexts, including legal practice management.
The affirmance strengthens the enforceability posture of US8229810B2 and the appellate-tested claim constructions applied by the lower court. For legal tech companies operating automated billing, time-tracking, or matter management platforms, the ruling suggests this patent and its claim scope carry heightened precedential weight. An FTO review against US8229810B2 is advisable for any product that captures billable time in real time.
After a Federal Circuit affirmance, Realtime Tracker’s options are limited. It could petition for rehearing en banc — rarely granted — or seek certiorari from the U.S. Supreme Court, which accepts very few patent cases. As a practical matter, the Federal Circuit affirmance represents the effective end of this particular dispute. However, Realtime Tracker may pursue separate enforcement actions based on the same or related patents against different defendants.
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