Recog IP v. Williams-Sonoma: Dismissed With Prejudice in 139 Days
Recog IP LLC asserted US7296062B2 — a patent covering methods for re-locating information pages on the web — against retail giant Williams-Sonoma in the Western District of Texas. The case resolved in just 139 days via a stipulated dismissal with prejudice, with each party bearing its own costs.
Web page relocation patent claim ends in swift stipulated dismissal
On January 25, 2023, Recog IP LLC — a non-practicing entity represented by Direction IP Law — filed suit against Williams-Sonoma, Inc. in the Western District of Texas before Judge Alan D. Albright, asserting infringement of US7296062B2. The patent claims a method for generating a presentation that re-locates an information page already called by a user, a technology squarely relevant to e-commerce and web navigation infrastructure.
The case closed on June 13, 2023, just 139 days after filing. The recorded basis of termination is Dismissed with Prejudice. The docket order reflects a stipulation under Fed. R. Civ. P. 41(a)(1)(A)(ii) in which both parties agreed to dismiss all of Recog IP's claims with prejudice, with each party bearing its own costs, expenses, and attorneys' fees. The specific terms underlying the parties' agreement are not disclosed in the available record.
The 139-day lifespan — from filing to closure — is notably short for patent litigation in the Western District of Texas, a court known for aggressive scheduling. The swift resolution may suggest early case assessment led to a negotiated exit, though the precise commercial or legal drivers are not disclosed in the public record. What is certain is that the dismissal with prejudice forecloses Recog IP from re-filing the same claims against Williams-Sonoma.
See Complete Case & Patent Analysis →Filing to Dismissed with Prejudice in 139 days
139 days — well under the W.D. Texas median for patent cases proceeding to trial
US7296062B2 — Method for re-locating web information pages
Any company operating an e-commerce platform, content management system, or web application that implements URL redirection, page re-location, or broken-link resolution functionality should consider assessing its exposure to US7296062B2. The patent's method claims target the process of generating a re-location presentation — a function embedded in many standard web infrastructure deployments. Given that Recog IP has already demonstrated willingness to assert this patent in federal court, the enforcement risk is not merely theoretical.
Official order — verbatim text
The stipulated dismissal filed under Fed. R. Civ. P. 41(a)(1)(A)(ii) reflects a mutual agreement by both parties to end the litigation before any substantive merits ruling. The with-prejudice designation carries the legal weight of a final judgment on the merits as between these parties, permanently foreclosing Recog IP from reasserting US7296062B2 against Williams-Sonoma. The cost-neutral arrangement means neither party obtained a fee award. No findings on validity or infringement appear in the public record.
Dismissed with prejudice: what the stipulated resolution means for both parties
Rule 41 stipulated dismissal with prejudice explained
A dismissal with prejudice under Fed. R. Civ. P. 41(a)(1)(A)(ii) is a jointly filed stipulation requiring no court order. The 'with prejudice' designation is the operative consequence: it operates as a final adjudication on the merits, permanently barring Recog IP from reasserting the same patent claims against Williams-Sonoma in any future action.
Merits-barring dismissalRecog IP loses the right to re-file against Williams-Sonoma
A with-prejudice dismissal extinguishes Recog IP's ability to re-litigate US7296062B2 against Williams-Sonoma. The patent itself remains nominally in force and could be asserted against other defendants, but this particular enforcement action is permanently closed. The cost-bearing arrangement — each party pays its own — means Recog IP avoided a fee-shifting award under 35 U.S.C. § 285.
No re-filing against this defendantWilliams-Sonoma obtains permanent bar on this claim
Williams-Sonoma, defended by DLA Piper, secured a with-prejudice dismissal — meaning the infringement claim under US7296062B2 cannot be revived against it. The company avoided both an injunction and a damages award. Each party bearing its own fees means Williams-Sonoma incurred its own litigation costs but was not required to pay Recog IP's fees, nor did it recover its own attorneys' fees from the plaintiff.
Permanent claim bar securedNPE web-navigation patent enforcement: a signal for e-commerce defendants
US7296062B2 targets web page re-location methods directly relevant to e-commerce platforms. The swift, cost-neutral dismissal is consistent with a pattern where NPE plaintiffs and well-resourced retail defendants reach early resolution without public disclosure of terms. Other e-commerce operators with similar web navigation infrastructure should monitor Recog IP's broader portfolio for continued enforcement activity.
E-commerce IP risk signalFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Recog IP, LLC | Company | Non-practicing entity (NPE) — holder of US7296062B2 covering web page relocation methodsSearch in Eureka ↗ |
| Defendant | Williams-Sonoma, Inc. | Company | Williams-Sonoma, Inc. — national specialty retailer operating e-commerce and physical retail channelsSearch in Eureka ↗ |
| Plaintiff counsel | David R. Bennett, Esq., | Attorney | Counsel for Recog IP, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Direction IP law | Law Firm | Representing Recog IP, LLCSearch in Eureka ↗ |
| Defendant counsel | John M. Guaragna | Attorney | Counsel for Williams-Sonoma, Inc.Search in Eureka ↗ |
| Defendant law firm | DLA Piper US LLP | Law Firm | Representing Williams-Sonoma, Inc.Search in Eureka ↗ |
| Presiding judge | Judge Alan D Albright | Judge | Texas Western District CourtSearch in Eureka ↗ |
R&D signals in the web navigation and URL management space
Forward-looking patent and R&D intelligence derived from the Recog IP v. Williams-Sonoma assertion — relevant for e-commerce platforms, web infrastructure teams, and IP strategists.
Recog IP's web-method patent portfolio and filing activity
Recog IP's assertion of US7296062B2 suggests a portfolio focused on internet-method and web navigation IP. Understanding the full scope of their holdings — including any continuation, divisional, or related applications from the US10/108595 family — is critical for e-commerce companies assessing ongoing NPE exposure in this technology space.
NPE portfolio watchFiling trends in URL redirection and web page re-location technology
Patent filing activity around URL management, HTTP redirect mechanisms, and dynamic page re-location has evolved significantly since the priority date of US7296062B2. Tracking recent filings in this space helps identify which assignees are building forward-looking IP positions around next-generation web navigation — and where white space may exist for defensive filing.
Web infrastructure IP trendsWilliams-Sonoma's own web and e-commerce patent activity
Large specialty retailers like Williams-Sonoma increasingly build defensive IP portfolios around their e-commerce platforms and digital customer experience technologies. Analysing Williams-Sonoma's own patent filings in web infrastructure and online retail provides insight into their defensive posture and any areas where their stack may intersect with third-party method claims.
Retail e-commerce IP postureAdjacent white space in broken-link resolution and dynamic routing
Beyond traditional HTTP redirects, emerging approaches to broken-link resolution — including AI-driven URL prediction, semantic page matching, and edge-network routing — represent adjacent R&D opportunities where the patent landscape may be less crowded. Companies innovating in these areas may find filing opportunities that create freedom-to-operate and defensive value simultaneously.
Defensive filing opportunitySimilar web-navigation patent cases in W.D. Texas and federal courts
Explore comparable NPE-led internet-method patent infringement cases before Judge Albright and across federal district courts targeting e-commerce web infrastructure.
What this case signals for the web navigation IP landscape
A 139-day lifecycle in W.D. Texas suggests both parties moved quickly to an exit. Here is what that means strategically.
W.D. Texas remains a preferred venue for NPE web-tech assertions
Judge Albright's docket and scheduling practices in the Western District of Texas continue to attract NPE plaintiffs asserting software and internet-method patents. E-commerce companies operating at scale should maintain standing patent monitoring programs covering web infrastructure IP, particularly method claims covering navigation and page-delivery techniques.
With-prejudice dismissal bars re-filing — but the patent lives on
US7296062B2 is not invalidated by this dismissal. Recog IP retains the ability to assert it against other defendants. Competitors of Williams-Sonoma in e-commerce and web retail should assess their own exposure to this patent's claims, particularly any method for generating redirect or re-location presentations for moved or expired URLs.
Recog v Williams-Sonoma — key questions answered
The case was dismissed with prejudice. Both parties filed a joint stipulation under Fed. R. Civ. P. 41(a)(1)(A)(ii) on June 13, 2023, agreeing to dismiss all of Recog IP's claims with prejudice, with each party bearing its own costs, expenses, and attorneys' fees. The specific terms underlying the agreement are not disclosed in the available public record.
Recog IP asserted US7296062B2 (application number US10/108595), which claims a method for generating a presentation for re-locating an information page that has already been called by a user. The patent covers web navigation and URL re-location methodology and was asserted in the context of Williams-Sonoma's e-commerce operations.
A dismissal with prejudice operates as a final adjudication on the merits as between the specific parties. Recog IP is permanently barred from re-filing the same claims under US7296062B2 against Williams-Sonoma. However, the patent itself is not invalidated and Recog IP retains the right to assert it against other defendants in separate proceedings.
The Western District of Texas, and specifically Judge Alan D. Albright's court, has been a frequently chosen venue by NPE plaintiffs for patent infringement actions due to its historically plaintiff-friendly scheduling and procedural posture. The case was filed on January 25, 2023, consistent with a broader pattern of NPE patent assertions in that jurisdiction.
The case lasted 139 days, from filing on January 25, 2023 to closure on June 13, 2023. This is a notably short duration for patent litigation in the Western District of Texas, where cases often proceed on aggressive scheduling orders. The swift resolution suggests the parties reached an agreement well before any substantive merits proceedings.
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