TG-2006 Holdings v. Microsoft: Voluntary Dismissal With Prejudice After 399 Days
TG-2006 Holdings, LLC sued Microsoft Co. in the Western District of Texas asserting two patents covering systems and methods for tracking information in a business environment. The plaintiff voluntarily dismissed the action with prejudice under Rule 41(a)(1)(A)(i) before Microsoft filed any answer, with each party bearing its own costs.
Pre-Answer Dismissal With Prejudice in a Business-Tracking Patent Dispute
TG-2006 Holdings, LLC filed suit against Microsoft Co. on 1 February 2024 in the Western District of Texas (Case No. 6:24-cv-00065) before Judge Robert Pitman, asserting infringement of US8583514B2 and US9454741B2 — two patents directed to systems and methods for tracking information in a business environment. Microsoft is one of the most frequently named defendants in patent litigation, and W.D. Texas remains a high-volume patent venue.
On 6 March 2025, TG-2006 Holdings filed a notice of voluntary dismissal with prejudice pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i), which permits a plaintiff to dismiss unilaterally before the defendant has served an answer or a motion for summary judgment. The dismissal was with prejudice, meaning the plaintiff permanently relinquished its right to reassert these same claims against Microsoft. Each party was ordered to bear its own costs, expenses, and attorneys’ fees, suggesting no negotiated fee shifting occurred.
The 399-day duration before a pre-answer dismissal is notable — it suggests the parties may have engaged in extended pre-litigation or licensing discussions before TG-2006 Holdings concluded the action could not proceed advantageously. The public record is silent on whether any settlement consideration changed hands, and the with-prejudice designation forecloses any future inference about renewed enforcement prospects against Microsoft on these specific patents.
Filing to Voluntary dismissal in 399 days
399 days — above the median for pre-answer voluntary dismissals in W.D. Texas
Voluntarily dismissed with prejudice: what the filing means for both parties
Rule 41(a)(1)(A)(i): unilateral dismissal before answer
Under FRCP 41(a)(1)(A)(i), a plaintiff may dismiss an action without a court order by filing a notice before the defendant serves an answer or a motion for summary judgment. Here, Microsoft had not yet answered, giving TG-2006 Holdings the procedural right to exit unilaterally. Critically, the notice specifies with prejudice — a voluntary choice that converts a procedural exit into a permanent bar on refiling the same claims.
Pre-answer voluntary exitThis dismissal was explicitly with prejudice — a permanent bar
A dismissal with prejudice operates as a final adjudication on the merits, preventing TG-2006 Holdings from ever reasserting these specific infringement claims against Microsoft. A dismissal without prejudice would have preserved the right to refile. The filed notice explicitly states ‘with prejudice,’ so the public record is unambiguous — there is no possibility of resurrection of this particular action against Microsoft on US8583514B2 or US9454741B2.
Permanent bar on refilingTG-2006 Holdings permanently exits — no public recovery confirmed
By dismissing with prejudice, TG-2006 Holdings forfeited any further litigation leverage against Microsoft on these patents in this venue. The each-party-bears-own-costs stipulation means no attorney fee award was obtained. Whether a private licensing agreement or settlement payment preceded the filing is not disclosed in the public record, which is consistent with standard practice in patent assertion entity resolutions.
No public fee recoveryMicrosoft achieves finality without litigating the merits
Microsoft secured a with-prejudice dismissal without filing an answer, expending discovery resources, or litigating validity. The company avoids any judicial finding on infringement or patent scope. The each-party-pays structure means Microsoft absorbed its own defence costs, consistent with a negotiated exit rather than a contested fee motion. The patents remain valid and enforceable against third parties outside this action.
Merits never adjudicatedFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | TG–2006 Holdings, LLC | Company | Patent assertion entity — holder of US8583514B2 and US9454741B2Search in Eureka ↗ |
| Defendant | Microsoft, Co. | Company | Microsoft Co. — global software and cloud technology companySearch in Eureka ↗ |
| Plaintiff counsel | Isaac Rabicoff | Attorney | Counsel for TG–2006 Holdings, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Rabicoff Law LLC | Law Firm | Representing TG–2006 Holdings, LLCSearch in Eureka ↗ |
| Defendant counsel | Gabriel Scott Culver | Attorney | Counsel for Microsoft, Co.Search in Eureka ↗ |
| Defendant counsel | John W. McBride | Attorney | Counsel for Microsoft, Co.Search in Eureka ↗ |
| Defendant counsel | Stephanie N. DeBrow | Attorney | Counsel for Microsoft, Co.Search in Eureka ↗ |
| Defendant law firm | Norton Rose Fulbright LLP | Law Firm | Representing Microsoft, Co.Search in Eureka ↗ |
| Defendant law firm | Norton Rose Fulbright US LLP | Law Firm | Representing Microsoft, Co.Search in Eureka ↗ |
| Presiding judge | Judge Robert Pitman | Judge | Texas Western District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal notice invokes Rule 41(a)(1)(A)(i) and explicitly designates the dismissal as with prejudice, which under established precedent operates as a final judgment on the merits. The each-party-bears-own-costs language forecloses any future fee motion in this action. Because Microsoft had not yet answered, no claim construction, invalidity position, or merits finding was entered — leaving the patents’ validity and scope entirely undecided by this court.
US8583514B2 & US9454741B2 — Business Information Tracking Systems
US8583514B2 (Application No. 10/918037) and US9454741B2 (Application No. 14/078093) both cover systems and methods for tracking information in a business environment. The earlier application number for US8583514B2 suggests a mid-2000s priority date, placing it in the formative era of enterprise software and workflow automation. US9454741B2, with its 14-series application number, likely represents a continuation or related filing extending the original claim scope into more specific data management and tracking configurations.
Business environment tracking patents sit at the intersection of enterprise software, CRM systems, workflow automation, and SaaS platforms — all high-value commercial sectors. Asserting these patents against Microsoft, whose product portfolio spans Dynamics 365, Azure, and Microsoft 365, suggests the claim scope may read on broadly deployed enterprise tools. With no validity ruling issued in this case, the patents retain full presumptive validity and remain a potential enforcement asset against any vendor operating in the business information management space.
Should your product team run an FTO against US8583514B2 and US9454741B2?
Any company developing or commercialising software that tracks, manages, or processes information in a business workflow context — including CRM platforms, ERP systems, project management tools, or enterprise SaaS products — should assess exposure to US8583514B2 and US9454741B2. The dismissal of this action against Microsoft does not constitute a non-infringement finding, and TG-2006 Holdings retains the ability to assert these patents against other defendants.
PatSnap Eureka’s FTO Search Agent can map the full claim scope of both patents, identify continuation and divisional family members that may carry similar or narrower claims, and flag prior art that could support an invalidity position. Given the pre-answer dismissal, no claim construction record exists from this case — making an independent claim analysis even more important for R&D and product teams evaluating their exposure in the business-tracking software space.
Run a freedom-to-operate analysis on US8583514B2 to assess your product’s exposure
Run FTO in Eureka →Similar Patent Cases: Business Information Tracking in W.D. Texas
Explore related patent infringement actions asserting business-process and information-tracking patents in the Western District of Texas against major software defendants.
What this case signals for the business-software patent IP landscape
Pre-answer dismissals with prejudice against major defendants often reflect a shift in enforcement economics or a private resolution. Here is what practitioners should watch.
W.D. Texas remains a live venue for software patent assertions against Microsoft
Despite the dismissal, the filing confirms that patent assertion entities continue to target Microsoft in W.D. Texas on software and business-process patents. Companies in the business-tracking software space should monitor claim scope of US8583514B2 and US9454741B2 — the patents were not invalidated and remain enforceable against other defendants.
With-prejudice exits signal enforcement economics, not patent weakness
A voluntary dismissal with prejudice does not constitute a finding of invalidity or non-infringement. Product teams and in-house counsel should not treat this outcome as clearing a freedom-to-operate path against these patents for other companies. An independent FTO analysis remains appropriate for any product that tracks or manages information in a business workflow context.
TG–2006 v Microsoft — key questions answered
A dismissal with prejudice under Rule 41(a)(1)(A)(i) operates as a final adjudication on the merits. TG-2006 Holdings cannot refile the same infringement claims against Microsoft based on US8583514B2 or US9454741B2. Because Microsoft had not yet answered, no merits ruling, claim construction, or invalidity finding was issued by the court.
Yes. The dismissal with prejudice only bars TG-2006 Holdings from reasserting these specific claims against Microsoft. The patents retain their full presumptive validity and remain enforceable against any other defendant whose products or services fall within the claim scope. No invalidity finding was entered in this case.
The public record does not disclose the reason. The 399-day duration before a pre-answer dismissal is consistent with extended licensing discussions, a private settlement, or a strategic reassessment of litigation economics. The with-prejudice designation and no-fee-shifting terms suggest a negotiated resolution is possible, but cannot be confirmed from publicly available filings.
Under 35 U.S.C. § 285, a court may award attorney fees to the prevailing party in exceptional patent cases. By stipulating that each party bears its own costs, the parties foreclosed any future fee motion in this action. This is typical in negotiated exits and does not indicate either party was found to have litigated in bad faith.
Both patents cover systems and methods for tracking information in a business environment. Products that could potentially fall within scope include CRM platforms, ERP systems, enterprise workflow tools, project management software, and business data management SaaS applications. A formal FTO analysis is required to assess actual claim scope — no claim construction was issued in this case to guide interpretation.
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