Wyoming Technology Licensing v. Clinc: Dismissed Without Prejudice in 114 Days
Wyoming Technology Licensing, LLC asserted US9824150B2 — covering systems and methods for information discovery and retrieval — against AI conversational platform company Clinc, Inc. in the Eastern District of Michigan. The case closed in just 114 days when the plaintiff voluntarily dismissed without prejudice, leaving the door open to future action.
Early voluntary exit in an information-retrieval patent dispute
On 2 May 2023, Wyoming Technology Licensing, LLC filed a patent infringement action against Clinc, Inc. in the United States District Court for the Eastern District of Michigan (Case No. 2:23-cv-11032). The suit asserted US9824150B2, directed to systems and methods for providing information discovery and retrieval, against Clinc's conversational AI platform. Plaintiff was represented by Garteiser Honea PC, with Rene A. Vazquez as counsel of record.
The recorded basis of termination is Dismissed without Prejudice. The docket order states that, pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) and 41(a)(1)(B), Plaintiff Wyoming Technology Licensing, LLC submitted a notice of voluntary dismissal WITHOUT PREJUDICE of Defendant Clinc, Inc. A Rule 41(a)(1)(A)(i) dismissal filed before the defendant has served an answer or motion for summary judgment is self-executing and requires no court order. The specific terms, if any, underlying this dismissal are not disclosed in the available record.
The 114-day case duration suggests the matter resolved — or was paused — well before substantive motion practice or claim construction proceedings. Whether the dismissal reflects a negotiated resolution, a strategic reassessment, or an intention to refile remains unknown from the public record. Because the dismissal is without prejudice, the plaintiff retains the ability to reassert the same claims against Clinc in a future action, subject to applicable statutes of limitations.
See Complete Case & Patent Analysis →Filing to Dismissed without Prejudice in 114 days
Days from filing to dismissal — a rapid close before substantive proceedings
US9824150B2 — systems and methods for information discovery and retrieval
Any organisation developing or deploying systems that discover, retrieve, or surface information in response to natural-language queries — including conversational AI assistants, enterprise search platforms, chatbot infrastructure, and query-understanding engines — should assess whether their architecture falls within the claims of US9824150B2. This patent was actively asserted against a conversational AI company in 2023, and the without-prejudice dismissal leaves enforcement risk unresolved for the sector.
Official order — verbatim text
The voluntary dismissal was filed under Rule 41(a)(1)(A)(i), making it self-executing upon filing — no judicial ruling on the merits was issued. The without-prejudice designation means the infringement claims against Clinc remain legally unresolved, and Wyoming Technology Licensing retains standing to reassert them in a future action. The specific terms, if any, are not disclosed in the available record.
Dismissed without prejudice: what the voluntary exit means for both parties
Rule 41(a)(1)(A)(i): a self-executing voluntary dismissal
Under Fed. R. Civ. P. 41(a)(1)(A)(i), a plaintiff may dismiss an action without a court order by filing a notice of dismissal before the opposing party has served an answer or motion for summary judgment. Such a dismissal takes effect immediately upon filing and carries no judicial endorsement of either party's position on the merits.
No court order requiredDismissal without prejudice preserves the right to refile
A dismissal without prejudice does not adjudicate the underlying patent infringement claims. Wyoming Technology Licensing retains the ability to assert US9824150B2 against Clinc in a future proceeding, subject to applicable statutes of limitations and any applicable Rule 41(a)(1)(B) 'two-dismissal' constraints. The public record does not disclose whether any conditions or agreements accompanied this dismissal.
Claims preserved for future actionClinc faces no judgment — but uncertainty remains
Clinc, Inc. obtains a clean exit from this specific proceeding with no adverse judgment entered against it. No defendant agents or law firm are recorded in the available docket, suggesting the dismissal may have occurred before Clinc formally appeared. However, because the dismissal is without prejudice, Clinc cannot treat this as a final resolution of the patent claims against its platform.
No judgment; exposure persistsInformation-retrieval IP risk remains live in the conversational AI sector
US9824150B2 covers systems and methods for information discovery and retrieval — technology central to conversational AI and enterprise search products. A without-prejudice dismissal signals that the patent holder has not abandoned its enforcement posture. Competitors and potential licensees operating in the natural language processing and information retrieval space should monitor Wyoming Technology Licensing's assertion activity and Clinc's product roadmap.
Enforcement risk unresolvedFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Wyoming Technology Licensing, LLC | Company | /Search in Eureka ↗ |
| Defendant | Clinc, Inc. | Company | /Search in Eureka ↗ |
| Plaintiff counsel | Rene A. Vazquez | Attorney | Counsel for Wyoming Technology Licensing, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Garteiser Honea PC | Law Firm | Representing Wyoming Technology Licensing, LLCSearch in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Michigan Eastern District CourtSearch in Eureka ↗ |
R&D signals in the information discovery and NLP patent space
Forward-looking patent intelligence derived from this case — covering Wyoming Technology Licensing's portfolio, filing trends in NLP and information retrieval, and Clinc's competitive IP position.
Wyoming Technology Licensing's assertion footprint in NLP
Wyoming Technology Licensing's willingness to assert US9824150B2 against a conversational AI company suggests an active licensing or enforcement strategy in the information retrieval space. Understanding the breadth of this entity's patent holdings — and whether US9824150B2 sits within a larger family — is critical for NLP platform developers assessing portfolio-level exposure.
Portfolio monitoringFiling trends in information discovery and retrieval systems
The information discovery and retrieval space — spanning semantic search, query understanding, and knowledge graph retrieval — has seen intensifying patent activity as conversational AI adoption scales. Tracking filing trends in this domain can reveal emerging IP thickets and white-space opportunities for R&D teams building next-generation NLP infrastructure.
Sector filing trendsClinc's patent posture in conversational AI
Clinc, Inc. operates in the conversational AI and NLU platform space. Understanding Clinc's own patent portfolio — including filings related to dialogue management, intent recognition, and information retrieval — provides a window into their defensive IP strategy and potential cross-licensing leverage in future disputes involving similar technology.
Defensive IP strategyAdjacent innovation space near US9824150B2 claims
Identifying claim-adjacent technical areas — such as federated information retrieval, real-time conversational context management, or multimodal query systems — where patent density is lower can guide R&D teams toward defensible innovation. A white-space analysis around the US9824150B2 claim scope supports both FTO strategy and offensive filing decisions.
White space analysisSimilar information-retrieval and NLP patent cases in US district courts
Cases involving information discovery, retrieval, and conversational AI patents in US district courts — including the Eastern District of Michigan — showing comparable enforcement patterns.
What this case signals for the conversational AI IP landscape
A fast, without-prejudice exit in a core information-retrieval patent case leaves enforcement options open and raises questions for NLP platform developers.
Rule 41 without-prejudice dismissals are a key early-stage tactic
When a case closes this quickly — 114 days, before any answer was filed — it typically signals that substantive proceedings never began. Practitioners should treat a without-prejudice dismissal as a potential pause, not a conclusion. Monitor plaintiff filing activity in the months following dismissal for refiling or related assertions.
US9824150B2 remains enforceable — audit your NLP stack
No judgment of invalidity, non-infringement, or unenforceability was entered. The patent survives this litigation fully intact. Companies building or licensing information discovery and retrieval technology — including conversational AI, enterprise search, and query-understanding systems — should assess exposure to the claims of US9824150B2.
Wyoming v Clinc — key questions answered
The case was dismissed without prejudice. On 24 August 2023, plaintiff Wyoming Technology Licensing, LLC filed a notice of voluntary dismissal without prejudice under Fed. R. Civ. P. 41(a)(1)(A)(i) and 41(a)(1)(B). No judgment on the merits was entered. The specific terms, if any, are not disclosed in the public record.
Wyoming Technology Licensing asserted US9824150B2, filed under application number US14/929696. The patent covers systems and methods for providing information discovery and retrieval — a technology domain directly relevant to conversational AI, enterprise search, and natural language query systems.
A dismissal without prejudice means the infringement claims were not adjudicated on the merits and Wyoming Technology Licensing retains the right to refile the same claims against Clinc in the future. No judgment of non-infringement or invalidity was entered. Clinc's exposure to US9824150B2 therefore remains legally unresolved.
Yes. A without-prejudice dismissal under Rule 41(a)(1)(A)(i) does not bar refiling, subject to applicable statutes of limitations. However, under Rule 41(a)(1)(B), if Wyoming Technology Licensing has previously dismissed an action based on the same claims, a second dismissal would operate as an adjudication on the merits. The public record does not indicate any prior dismissal of the same claims.
Plaintiff Wyoming Technology Licensing, LLC was represented by Garteiser Honea PC, with Rene A. Vazquez listed as counsel of record. No defendant agents or law firm are recorded in the available public docket for Clinc, Inc., consistent with the case closing before the defendant formally appeared.
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