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Safe IP v. Grammarly – Plagiarism Detection Patent Dispute | PatSnap
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Case ID1:22-cv-00919
FiledJul 2022
ClosedNov 2025
Patent Litigation

Safe IP v. Grammarly: Plagiarism Detection Patent Case Terminated After 1,228 Days

Safe IP, LLC filed suit against Grammarly, Inc. in the District of Delaware asserting US9043375B2, a patent covering plagiarism detection systems. The case was part of a coordinated multi-case filing and was terminated after 1,228 days, with the record silent on a merits adjudication.

Resolution time
1228days
1,228 days — above the median for D. Del. patent cases, suggesting procedural complexity
Patents asserted
1
US9043375B2 — plagiarism detection system, natural language processing and text-comparison technology
Outcome
Case Terminated
Case terminated per court order; basis of termination does not specify merits disposition
Cost ruling
Not Recorded
No fee or cost award reflected in the public docket for this case
Published by PatSnap Insights Team · Verified by PatSnap Eureka Data
Case overview

Coordinated patent filing against Grammarly ends without merits ruling

Safe IP, LLC filed this infringement action on 11 July 2022 in the District of Delaware before Judge Colm F. Connolly, asserting US9043375B2 against Grammarly, Inc. The patent, carrying application number US12/253249, covers plagiarism detection system technology — a domain directly relevant to Grammarly’s commercial AI writing and grammar-assistance platform. The case was one of at least three coordinated filings by Safe IP on the same day, with companion cases 1:22-cv-00918 and 1:22-cv-00920 filed concurrently against related or separate defendants.

The case was stayed relatively early: on 22 November 2022, the court entered an order staying the case and terminating a scheduled evidentiary hearing that had been set for 30 November 2022. The stay order covered all three companion cases simultaneously, suggesting a systemic procedural development — potentially related to Judge Connolly’s standing orders on third-party litigation funding disclosures, which were active at the time and affected numerous NPE cases in Delaware. The case formally closed on 20 November 2025, though the basis of termination is recorded simply as ‘Case Terminated’ without specifying settlement, voluntary dismissal, or a merits judgment.

The 1,228-day duration between filing and closure is notable given the early stay, suggesting the case remained in a dormant or administrative posture for the majority of its life. The public record does not disclose whether any financial consideration changed hands or whether the termination reflects a strategic withdrawal. The coordinated multi-case structure, combined with the rapid stay and the NPE profile of Safe IP, LLC, is consistent with a licensing-focused enforcement strategy. What drove the ultimate closure — and whether Grammarly obtained any licence or release — is not determinable from available public records.

Case at a glance
Case no.1:22-cv-00919
PlaintiffSafe IP, LLC
CourtDelaware
JudgeColm F. Connolly
FiledJuly 11, 2022
ClosedNovember 20, 2025
Duration1228 days
OutcomeCase Terminated
Verdict causeInfringement Action
BasisCase Terminated
Prior Art Intelligence
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Case data sourced from PACER / Delaware District Court via PatSnap Eureka Litigation Intelligence Explore similar cases ↗
Case timeline

Filing to Case Terminated in 1228 days

1,228 days — above the median for D. Del. patent cases, suggesting procedural complexity

Case timeline: Complaint filed JUL 11 2022, MAR–APR — 1228 days total Horizontal timeline showing the three key events in Safe IP, LLC v Grammarly, Inc. from filing to resolution. Source: PACER, Delaware District Court. JUL 11 2022 Complaint filed Pre-trial proceedings NOV 20 2025 Case Terminated 1228 DAYS TOTAL
Dismissal terms

Case terminated: what the record does and does not tell us

Legal mechanism

Case terminated without a recorded merits disposition

The docket records ‘Case Terminated’ as the basis of closure, which is a procedural label rather than a substantive outcome. It does not equate to a judgment on infringement, validity, or damages. The early stay order in November 2022 — which simultaneously affected three companion cases — suggests the termination may have followed an extended period of administrative dormancy rather than active litigation leading to a decision.

No merits adjudication
Patent holder outcome

Outcome for Safe IP is ambiguous from the public record

The basis of termination does not specify voluntary dismissal with or without prejudice, settlement, or a consent judgment. The public record is therefore silent on whether Safe IP obtained any licensing revenue, royalty, or other consideration from Grammarly. The absence of a with-prejudice dismissal notation means the enforceability of US9043375B2 against third parties is not formally constrained by this case’s outcome alone.

Record silent on consideration
Defendant outcome

Grammarly avoided a merits finding — but exposure is unresolved publicly

Grammarly was represented by Shaw Keller LLP and Nathan Roger Hoeschen. The termination without a recorded merits ruling means no court has publicly adjudicated whether Grammarly’s plagiarism detection features infringe US9043375B2. Whether any covenant not to sue or licence was obtained as part of the closure is not reflected in the docket, leaving the public posture of Grammarly’s freedom to operate under this patent uncertain.

No infringement finding recorded
Commercial implications

Patent remains a live risk for NLP and text-analysis product teams

US9043375B2 covers plagiarism detection technology — a field now central to AI writing tools, large language model output checkers, and academic integrity platforms. The absence of an invalidity or non-infringement ruling means the patent survived this case with its enforceability intact. Competitors and adjacent-technology firms in the AI content and text-analysis space should treat this patent as unresolved and consider FTO analysis before product launches in the plagiarism or originality-detection domain.

Patent enforceability unresolved
Legal analysis based on PACER docket records for case 1:22-cv-00919 and PatSnap Eureka litigation intelligence Search PatSnap Eureka ↗
Parties and representation

Full party and counsel information

RoleNameTypeDetail
PlaintiffSafe IP, LLCCompanyPatent assertion entity — holder of US9043375B2 covering plagiarism detection systemsSearch in Eureka ↗
DefendantGrammarly, Inc.CompanyGrammarly, Inc. — AI-powered writing assistance and grammar-checking platformSearch in Eureka ↗
Plaintiff counselJimmy C. ChongAttorneyCounsel for Safe IP, LLCSearch in Eureka ↗
Plaintiff counselWilliam P. Ramey , IIIAttorneyCounsel for Safe IP, LLCSearch in Eureka ↗
Plaintiff law firmChong Law Firm PALaw FirmRepresenting Safe IP, LLCSearch in Eureka ↗
Defendant counselNathan Roger HoeschenAttorneyCounsel for Grammarly, Inc.Search in Eureka ↗
Defendant law firmShaw Keller LLPLaw FirmRepresenting Grammarly, Inc.Search in Eureka ↗
Presiding judgeJudge Colm F. ConnollyJudgeDelaware District CourtSearch in Eureka ↗
Official verdict

Official order — verbatim text

“Terminating Hearings: 11/30/2022 Evidentiary Hearing has been terminated per Order Staying Case(s). Associated Cases: 1:22-cv-00918-CFC, 1:22-cv-00919-CFC, 1:22-cv-00920-CFC(kmd) (Entered: 11/22/2022)”
Source: PACER Docket, Case 1:22-cv-00919, Delaware District Court

The docket entry records the termination of a scheduled evidentiary hearing and the imposition of a stay across three companion cases in November 2022. This procedural entry does not constitute a verdict on infringement or validity. The formal ‘Case Terminated’ basis entered upon closure in November 2025 likewise carries no merits content. The record as a whole is consistent with a case that was administratively resolved — whether by settlement, withdrawal, or attrition — without any judicial determination on the substantive patent claims.

PACER case 1:22-cv-00919 · Public docket record Explore in Eureka ↗
Patent at issue

US9043375B2 — Plagiarism Detection System Technology

Publication No.US9043375B2
Application No.US12/253249
Patent details
ProductAutomated plagiarism detection system using text comparison and analysis methods
Cited in actionJuly 11, 2022

US9043375B2, filed under application number US12/253249, protects technology in the plagiarism detection domain — specifically systems and methods for identifying copied or substantially similar textual content. This class of invention sits at the intersection of natural language processing, information retrieval, and text-similarity analysis. The patent’s claims are relevant to any product that ingests user-submitted text and compares it against a corpus to detect non-original content — a description that maps directly to features deployed by academic platforms, writing assistants, and increasingly by AI content governance tools.

The commercial significance of US9043375B2 has grown since its filing, as AI writing tools have expanded the scope of what constitutes originality detection. Grammarly’s platform, which assists users with drafting and editing, plausibly overlaps with plagiarism-detection functionality at the feature level. More broadly, the rise of LLM-generated content has driven a new class of AI output detection products — tools that analyse text for signs of machine authorship — which may fall within reading of plagiarism-detection claims depending on how broadly the patent’s claims are construed. Any firm in the AI text-analysis, academic integrity, or content governance sector should conduct independent claim mapping before product launch.

Patent data sourced from USPTO via PatSnap Eureka patent database Search patent records in Eureka ↗
Freedom to operate

Should your team run an FTO against US9043375B2?

If your product performs any form of automated text similarity analysis, originality scoring, or plagiarism detection — including AI-generated content detection — US9043375B2 should be on your FTO radar. The patent survived this litigation without an invalidity ruling, meaning its claims remain presumptively valid. Safe IP’s demonstrated willingness to assert the patent against a high-profile defendant like Grammarly suggests enforcement capacity. Product teams at edtech firms, writing platforms, LLM providers, and academic integrity vendors face the highest exposure.

PatSnap Eureka’s FTO Search Agent can map the claims of US9043375B2 against your product’s technical architecture in minutes, surfacing prior art, claim scope analysis, and comparable cases. Use Eureka to identify whether your text-comparison pipeline, similarity scoring algorithm, or corpus-matching logic intersects with the asserted claims — before you ship. Monitoring Safe IP’s related portfolio and prosecution history is also available through Eureka’s assignee tracking features.

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Related litigation

Similar plagiarism detection and NLP patent cases in D. Delaware

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Strategic implications

What this case signals for the AI writing and NLP patent landscape

Safe IP’s coordinated multi-case strategy against Grammarly highlights rising NPE activity targeting AI-powered text-analysis products.

Coordinated NPE filings signal systematic enforcement campaigns

The simultaneous filing of three related cases in D. Del. on the same day is consistent with a licensing campaign rather than a dispute-resolution strategy. Product teams and in-house counsel in the AI writing and grammar-technology sector should monitor Safe IP’s portfolio for further assertion activity, particularly as LLM-based content tools proliferate.

Early stay orders in D. Del. can extend case lifespans dramatically

The stay entered just four months after filing — and covering all companion cases simultaneously — is consistent with Judge Connolly’s disclosure-focused case management orders in the 2022–2023 period. IP teams should account for the possibility that D. Del. NPE cases may be administratively dormant for years before formal termination, complicating FTO assessments.

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Unlock gated insights on NPE enforcement trends in AI/NLP technology at the District of Delaware level.
LLM content detection riskSafe IP portfolio mapD. Del. NPE stay patterns
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Frequently asked questions

Safe v Grammarly — key questions answered

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Run an FTO analysis on US9043375B2 before your next product launch in text analysis or AI content detection. Monitor Safe IP and related NPE portfolios for new enforcement activity targeting your technology stack.

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