Vilox Technologies v. Salesforce: Infringement Claims Dismissed Without Prejudice
Vilox Technologies, LLC and Vilox, LLC filed patent infringement claims against Salesforce, Inc. in the Northern District of California, asserting two patents covering on-the-fly database search technology against Salesforce Report Builder, the Lightning Platform, and Visualforce. After 679 days, the plaintiffs voluntarily dismissed all claims without prejudice before Salesforce filed an answer — leaving the door open for refiling.
Salesforce database search patents dismissed before merits — but refiling remains possible
On October 2, 2023, Vilox Technologies, LLC and Vilox, LLC filed a patent infringement action against Salesforce, Inc. in the Northern District of California (Case No. 3:23-cv-05047), before Judge Araceli Martinez-Olguin. The plaintiffs asserted two patents — US7188100B2 and US6760720B1 — covering on-the-fly database search and query processing technology, targeting Salesforce products including Report Builder, the Lightning Platform, and Visualforce.
On August 11, 2025, the plaintiffs filed a notice of voluntary dismissal pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i), explicitly designating the dismissal as without prejudice as to the asserted patents. Because Salesforce had not yet filed an answer or a motion for summary judgment, the plaintiffs were entitled to dismiss as of right without court approval. This means Vilox retains the right to refile substantially the same claims at a future date, subject to applicable statutes of limitations and any intervening legal developments.
The 679-day duration before a pre-answer voluntary dismissal is notable — most Rule 41(a)(1) dismissals occur far earlier in litigation. The extended timeline suggests the parties may have engaged in substantive negotiations, claim mapping, or licensing discussions before Vilox elected not to proceed to a merits ruling. The public record does not disclose whether any settlement, licensing agreement, or other arrangement was reached, and Salesforce has not publicly confirmed any resolution. The without-prejudice designation means the asserted patents remain live enforcement assets.
Filing to Voluntary dismissal in 679 days
679 days — longer than most voluntary pre-answer dismissals, suggesting active pre-litigation negotiations
Voluntarily dismissed without prejudice: what the Rule 41 filing means for both sides
Rule 41(a)(1)(A)(i): dismissal as of right, no court order required
Under Federal Rule of Civil Procedure 41(a)(1)(A)(i), a plaintiff may dismiss an action without a court order by filing a notice of dismissal before the defendant serves an answer or a motion for summary judgment. Salesforce had done neither, so Vilox’s dismissal was self-executing and immediate. The explicit without-prejudice designation preserves all of the plaintiffs’ claims for potential future litigation.
Pre-answer voluntary dismissalWithout prejudice confirmed — refiling rights preserved for Vilox
The dismissal notice explicitly states the claims are dismissed WITHOUT PREJUDICE as to the asserted patents. This is legally significant: it means no judgment was entered on the merits and Vilox is not barred from refiling substantially identical claims. Had the notice been silent on prejudice, courts apply different interpretations by circuit. Here, the public record is unambiguous — Vilox retains enforcement optionality on both US7188100B2 and US6760720B1.
Claims refiling rights preservedSalesforce avoids merits ruling — but faces ongoing patent exposure
Salesforce, Inc. escapes this specific action without an adverse judgment, and no claim construction or infringement finding was made. However, because the dismissal is without prejudice, Salesforce has not secured a definitive ruling that its Report Builder, Lightning Platform, or Visualforce products are non-infringing. The asserted patents remain valid and enforceable, and Salesforce’s litigation risk on this technology has not been resolved.
No merits immunity for SalesforceOn-the-fly search patents remain active enforcement tools in the CRM sector
The without-prejudice dismissal means US7188100B2 and US6760720B1 can still be asserted against Salesforce or third parties operating similar database query and search-on-the-fly functionality. Competitors and licensees in the CRM, cloud database, and enterprise SaaS space should treat these patents as live enforcement assets. The 679-day timeline before dismissal suggests Vilox conducted substantive pre-trial work, potentially positioning the patents for a stronger future assertion.
Live enforcement risk for SaaS sectorFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Vilox Technologies, LLC | Company | IP licensing entity — holder of US7188100B2 and US6760720B1, on-the-fly database search patentsSearch in Eureka ↗ |
| Co-Plaintiff | Vilox, LLC | Company | Search in Eureka ↗ |
| Defendant | Salesforce, Inc. | Company | Salesforce, Inc. — enterprise CRM and cloud platform provider; maker of Report Builder and Lightning PlatformSearch in Eureka ↗ |
| Plaintiff counsel | Jennifer L. Ishimoto | Attorney | Counsel for Vilox Technologies, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Susan S.Q. Kalra | Attorney | Counsel for Vilox Technologies, LLCSearch in Eureka ↗ |
| Plaintiff counsel | William P. Ramey , III | Attorney | Counsel for Vilox Technologies, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Jennifer Ishimoto | Law Firm | Representing Vilox Technologies, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Ramey & Schwaller, LLP | Law Firm | Representing Vilox Technologies, LLCSearch in Eureka ↗ |
| Defendant counsel | Amara Osisioma | Attorney | Counsel for Salesforce, Inc.Search in Eureka ↗ |
| Defendant counsel | Chao Wendy Wang | Attorney | Counsel for Salesforce, Inc.Search in Eureka ↗ |
| Defendant counsel | Jose Carlos Villarreal | Attorney | Counsel for Salesforce, Inc.Search in Eureka ↗ |
| Defendant counsel | Lance Goodman | Attorney | Counsel for Salesforce, Inc.Search in Eureka ↗ |
| Defendant counsel | Nicholas A. Baniel | Attorney | Counsel for Salesforce, Inc.Search in Eureka ↗ |
| Defendant counsel | Sarah JoAnn Guske | Attorney | Counsel for Salesforce, Inc.Search in Eureka ↗ |
| Defendant law firm | Baker Botts LLP | Law Firm | Representing Salesforce, Inc.Search in Eureka ↗ |
| Defendant law firm | Morgan, Lewis & Bockius LLP | Law Firm | Representing Salesforce, Inc.Search in Eureka ↗ |
| Presiding judge | Judge Araceli Martinez-Olguin | Judge | California Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal notice invokes Rule 41(a)(1)(A)(i) as the procedural basis, confirming no court approval was required given Salesforce had not yet answered or moved for summary judgment. The explicit without-prejudice language as to the asserted patent is the operative phrase: it confirms that no res judicata effect attaches, and Vilox retains full rights to refile. The phrasing does not disclose any settlement, covenant not to sue, or licensing arrangement, leaving the commercial terms — if any exist — outside the public record.
US7188100B2 & US6760720B1 — on-the-fly database search and query engine technology
US7188100B2 (application US10/062459) and US6760720B1 (application US09/513340) both cover technology in the domain of on-the-fly database search — specifically, systems and methods for receiving a search request and executing queries dynamically against a database without pre-built static indexes or rigid query pre-processing. The earlier application number for US6760720B1 suggests a priority date likely in the early 2000s, placing these patents in the foundational era of enterprise database search architecture. Both patents were asserted against Salesforce’s Report Builder, Lightning Platform, and Visualforce products.
In the context of modern CRM and cloud SaaS platforms, on-the-fly search and dynamic query generation are core product features — not peripheral. The assertion of these patents against Salesforce’s flagship platform tools signals that the claim scope may be broad enough to reach widely deployed enterprise search interfaces. For IP strategists, these patents represent a potentially high-leverage enforcement asset in a market where real-time data query functionality is increasingly standard across CRM, ERP, and cloud analytics products. Competitors offering similar dynamic search or report-generation features should treat these patents as active risk vectors.
Should your product team run an FTO against US7188100B2 and US6760720B1?
Any enterprise SaaS, CRM, or cloud database platform that offers on-the-fly search, dynamic query generation, or real-time database filtering functionality should evaluate exposure to US7188100B2 and US6760720B1. The fact that Vilox named Salesforce Report Builder and the Lightning Platform — two of the most widely deployed enterprise tools in the market — suggests the plaintiffs believe the claims read broadly on standard architectural patterns for database search interfaces. A without-prejudice dismissal means these patents are actively maintained and may be reasserted.
PatSnap Eureka’s FTO Search Agent allows R&D and product teams to map specific product features against asserted claim language in US7188100B2 and US6760720B1, identify relevant prior art that may support invalidity arguments, and monitor Vilox’s future filing activity in real time. Given the 679-day litigation history and the deliberate without-prejudice exit, this is precisely the type of live enforcement scenario where proactive FTO analysis delivers strategic value before a new complaint is filed.
Run a freedom-to-operate analysis on US7188100B2 to assess your product’s exposure
Run FTO in Eureka →Similar patent cases: on-the-fly database search and CRM platform infringement actions
Patent infringement cases asserting database search and dynamic query technology against enterprise CRM and SaaS platforms in the Northern District of California and related courts.
What this case signals for the enterprise SaaS and database search IP landscape
A without-prejudice dismissal after nearly two years signals deliberate strategy, not defeat — these patents are still in play.
Without-prejudice dismissals after lengthy litigation suggest licensing strategy
When a plaintiff dismisses without prejudice after 679 days — well past the point where significant legal costs have been incurred — it typically signals either an undisclosed commercial resolution or a strategic reset. In either scenario, the patents were not abandoned, and the enforcement posture of the patent holder has not weakened. IP teams at Salesforce competitors should monitor Vilox’s next filings closely.
Salesforce’s on-the-fly database search products remain under IP scrutiny
Report Builder, the Lightning Platform, and Visualforce were specifically named as accused products. With no invalidity ruling and no non-infringement finding on record, these product lines carry unresolved IP risk tied to US7188100B2 and US6760720B1. Product teams and in-house counsel at Salesforce and comparable CRM providers should ensure FTO analysis covers these patents before expanding related features.
Vilox v Salesforce — key questions answered
It means Vilox Technologies and Vilox, LLC voluntarily dismissed all infringement claims against Salesforce before Salesforce filed an answer or motion for summary judgment. Under Rule 41(a)(1)(A)(i), such a dismissal is self-executing — no court order is required. The notice explicitly designated the dismissal as without prejudice, preserving Vilox’s right to refile substantially the same claims in the future.
Vilox asserted two patents: US7188100B2 (application US10/062459) and US6760720B1 (application US09/513340). Both cover on-the-fly database search and dynamic query processing technology. The accused Salesforce products included Report Builder, the Lightning Platform, Visualforce, and related search-on-the-fly search engine functionality.
Yes. Because the dismissal was explicitly without prejudice as to the asserted patents, no res judicata effect bars Vilox from refiling. The claims on US7188100B2 and US6760720B1 remain available for future assertion, subject to applicable statutes of limitations and any other procedural or substantive bars that may arise before refiling.
The public record does not disclose the reason for the extended timeline before the pre-answer dismissal. The 679-day duration is longer than typical Rule 41(a)(1) dismissals, which often occur within months of filing. The extended period may suggest the parties engaged in claim mapping, licensing negotiations, or other pre-trial activity, though no settlement or agreement has been publicly confirmed.
The accused products included Salesforce Report Builder, the Lightning Platform, and Visualforce, with infringement allegations tied specifically to the functionality of searching a database on-the-fly based on a query using a search-on-the-fly search engine. These are core Salesforce platform components used widely across enterprise deployments, making the scope of the assertion commercially significant.
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