Untitled case

The patent infringement case 7:25-cv-00061 in the U.S. District Court for the Western District of Texas involves plaintiff Dialect, LLC, a patent assertion entity (NPE) focused on natural language processing and voice technology, and defendant Salesforce Inc., a global leader in cloud-based CRM software. The litigation centered on U.S. Patent No. 8,015,006, which generally describes systems and methods for processing natural language speech utterances using context-specific domain agents to improve voice-driven interaction and information retrieval. Dialect, LLC alleged that Salesforce's Voice AI Agents, a product line enabling automated conversational AI interactions within its ecosystem, infringed the asserted patent.

The case was filed in the Western District of Texas, presided over by Judge David Counts. The Western District of Texas gained prominence as a patent litigation venue, largely due to its patent-friendly environment, efficient scheduling practices, and a historical reluctance to transfer cases, particularly under Judge Alan Albright, though Judge Counts presided over this specific matter. This venue choice is often strategic for patent plaintiffs, including NPEs like Dialect, LLC.

The litigation is notable as it involves a patent assertion entity targeting a major technology company in the rapidly growing voice AI and CRM sectors. However, the case concluded swiftly with a voluntary dismissal without prejudice by Dialect, LLC on September 17, 2025, only 223 days after filing, before Salesforce had even served an answer or motion for summary judgment. This "without prejudice" dismissal means Dialect, LLC retains the right to refile the lawsuit in the future, suggesting a tactical pause rather than a complete surrender of the claims.

The patent infringement case Dialect, LLC v. Salesforce Inc., 7:25-cv-00061, in the U.S. District Court for the Western District of Texas, concerning U.S. Patent No. 8,015,006, saw a swift resolution through voluntary dismissal.

Here are the key legal developments and the outcome:

• Filing & Initial Pleadings (2025-02-06): Dialect, LLC, a patent assertion entity, filed the patent infringement complaint against Salesforce Inc. on February 6, 2025, in the Western District of Texas. The lawsuit alleged that Salesforce's Voice AI Agents infringed U.S. Patent No. 8,015,006, which generally describes systems and methods for processing natural language speech utterances. Salesforce had not yet served an answer or a motion for summary judgment prior to the case's dismissal.
• Pre-trial Motions of Substance: The case concluded before any substantive pre-trial motions, such as motions to dismiss, transfer, or stay pending IPR, could be fully litigated or ruled upon by the court.
• Claim Construction (Markman) Outcomes: As the case was dismissed at an early stage, it did not reach the claim construction (Markman) phase, and therefore, no claim construction ruling was issued.
• Discovery Milestones: There were no significant discovery milestones or strategic developments reported, given the early dismissal of the case.
• Trial Events, Verdict, and Post-Trial Motions: The litigation did not proceed to trial, and consequently, there was no verdict or any post-trial motions.
• Dismissal (2025-09-17): The case was voluntarily dismissed without prejudice by Dialect, LLC on September 17, 2025. This dismissal occurred just 223 days after the initial filing and before Salesforce had filed an answer or a motion for summary judgment, invoking Federal Rule of Civil Procedure 41(a)(1)(A)(i). No damages were awarded, and no injunctive relief was granted or denied. Each party was ordered to bear its own costs, expenses, and attorney fees. The "without prejudice" designation means Dialect, LLC retains the right to refile the lawsuit in the future.
• Parallel PTAB IPR/PGR Proceedings: A search for inter partes review (IPR) or post-grant review (PGR) proceedings concerning U.S. Patent No. 8,015,006 at the Patent Trial and Appeal Board (PTAB) revealed no such proceedings during the relevant period of this litigation.

Plaintiff Dialect, LLC was represented by attorneys from Blue Peak Law Group LLP and Scott Douglass & McConnico LLP in the case Dialect, LLC v. Salesforce Inc., 7:25-cv-00061.

The counsel of record for Dialect, LLC includes:

• Garland T. Stephens (Lead Counsel)

  • Firm: Blue Peak Law Group LLP, Houston, TX
  • Experience Note: Mr. Stephens has represented Dialect, LLC in other patent infringement cases, including Dialect, LLC v. Amazon.com, Inc. (1:23-cv-581) and Dialect, LLC v. Google LLC (1:23-cv-00378). He was admitted pro hac vice in the Google case.

• Richard M. Koehl (Counsel)

  • Firm: Blue Peak Law Group LLP, New York, NY
  • Experience Note: Also represented Dialect, LLC in Dialect, LLC v. Amazon.com, Inc..

• Robert Pierce Earle (Counsel)

  • Firm: Scott Douglass & McConnico LLP
  • Experience Note: Specific patent litigation experience for this attorney was not immediately available in the search results.

• Steven J. Wingard (Counsel)

  • Firm: Scott Douglass & McConnico LLP
  • Experience Note: Specific patent litigation experience for this attorney was not immediately available in the search results.

Another attorney, Justin Constant, was admitted for Dialect LLC in a related case, Dialect, LLC v. Meta Platforms, Inc. (7:25-cv-00060), which was filed around the same time and also in the Western District of Texas. While that case involved a different defendant (Meta Platforms), the shared plaintiff and similar timing suggest potential overlap in counsel for Dialect's overall litigation strategy.

In the patent infringement case Dialect, LLC v. Salesforce Inc., 7:25-cv-00061, Salesforce Inc. was represented by counsel from at least two law firms: Gibson, Dunn & Crutcher LLP and Akin Gump Strauss Hauer & Feld LLP. Morgan, Lewis & Bockius LLP is also a prominent firm with experience defending against non-practicing entities and has a strong patent litigation practice, making them a likely candidate for involvement, though direct confirmation for this specific case was not explicitly found in all searches. Salesforce also has in-house counsel for intellectual property matters.

Here's a breakdown of the defendant's counsel:

• Jeffrey T. Thomas (Lead Counsel)

  • Firm: Gibson, Dunn & Crutcher LLP, Orange County, CA.
  • Experience Note: Mr. Thomas is an experienced trial lawyer specializing in intellectual property, antitrust, and complex business litigation. He has represented major clients in patent and trade secret litigation, including trials resulting in favorable verdicts for his clients, such as Hewlett-Packard Co. against Oracle Corp. He has been recognized as a top intellectual property litigator and a "Life Science Star."

• Jonathan R. Ch Merhige (Counsel)

  • Firm: Akin Gump Strauss Hauer & Feld LLP.
  • Experience Note: While specific details for this case were not found, Akin Gump has a strong intellectual property practice with lawyers experienced in patent infringement litigation in federal district courts and before the PTAB. Jonathan R. Miller from Rozier Hardt McDonough PLLC, whose practice focuses on patent litigation, was also found in a general search, but his direct involvement in Dialect, LLC v. Salesforce Inc. was not confirmed.

• C. Brandon Rash (Counsel)

  • Firm: Akin Gump Strauss Hauer & Feld LLP.
  • Experience Note: Mr. Rash has over a decade of experience in all aspects of patent litigation, including pre-litigation, trial, and appeal, in federal district courts, the ITC, and PTAB. He has represented clients in complex multi-front patent and trade secret litigations.

• Jonathan James Underwood (Counsel)

  • Firm: Akin Gump Strauss Hauer & Feld LLP.
  • Experience Note: Dr. Underwood is experienced in all phases of patent infringement litigation, including ANDA litigation, at both trial and appellate levels, and also represents clients in IPR proceedings before the USPTO. He holds a Ph.D. in synthetic organic chemistry, bringing significant scientific acumen to his cases.

It is important to note that the case was dismissed voluntarily by Dialect, LLC early in the proceedings, before Salesforce had served an answer or motion for summary judgment. This means that some attorneys might have been involved in pre-filing analysis or early strategic discussions but may not have formally appeared on the docket.

Salesforce also maintains an in-house Intellectual Property team, including "AI Patent Counsel," responsible for managing patent portfolios, developing global patent strategies, and counseling on patent risks. Sabastian Niles is the President and Chief Legal Officer of Salesforce, overseeing global legal and corporate affairs.