Sanas.AI Inc. v. Krisp Technologies, Inc.
- Richard Seeborg
- 3:25-cv-05666
- U.S. District Court · Northern District of California
- 3
In Sanas.AI v. Krisp, Judge Seeborg denied Krisp’s second dismissal motion because Rule 12 bars successive motions raising an available defense.
The ruling affects Krisp’s November motion to dismiss and leaves the challenged patent claims in Sanas’s amended complaint subject to further proceedings.
What happened
Sanas.AI Inc. v. Krisp Technologies, Inc. involves competing companies’ dispute over patent and other claims related to accent-conversion and noise-reduction technology. Krisp filed a second motion asking the court to dismiss claims in Sanas’s amended complaint.
Krisp argued that deciding the motion would promote efficiency because several motions were pending and the pleadings stage had continued for a long time. The court noted that Krisp’s earlier motion addressed other claims and that Krisp had already filed answers to the remaining claims.
Judge Richard Seeborg denied Krisp’s November motion. He ruled that the Federal Rules of Civil Procedure do not allow a party to file a later motion under Rule 12(b)(6) raising a defense that was available but omitted from an earlier Rule 12 motion. The court did not decide the patent-eligibility issues on their merits.
The detailed version
- Sanas.AI Inc. v. Krisp Technologies, Inc. · No. 3:25-cv-05666
- Richard Seeborg
- Dec. 19, 2025
Background
Sanas.AI Inc. and Krisp Technologies, Inc. are competitors in the market for real-time accent-conversion and background-noise-reduction technology. After discussions about a possible business collaboration ended, Sanas filed claims against Krisp, including patent infringement and several non-patent claims.
Sanas later filed a first amended complaint asserting patent infringement, co-inventorship and co-ownership, trade-secret misappropriation under federal and California law, false advertising, and unfair competition. Krisp filed an October motion under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal for failure to state a legally sufficient claim; the court denied that motion in its entirety as to Sanas’s non-patent claims. Krisp then filed a November motion seeking dismissal of Sanas’s patent claims, including an argument concerning patent eligibility.
Court’s analysis
Rule 12(g)(2) generally bars a party that has made a Rule 12 motion from making another motion under that rule based on a defense or objection that was available but omitted from the earlier motion. Rule 12(h)(2) provides that a failure-to-state-a-claim defense is not waived merely because it was omitted from an earlier Rule 12 motion; instead, it may be raised through other procedures, including a motion for judgment on the pleadings or at trial.
The court concluded that Krisp’s November motion was a successive Rule 12(b)(6) motion directed at claims in the same amended complaint. The court rejected Krisp’s argument that judicial efficiency justified deciding the later motion. It noted that the rules control and that Krisp could raise the issue through a motion for judgment on the pleadings after the pleadings closed.
Disposition
The court denied Krisp’s November motion to dismiss. The order resolved the motion because it was procedurally improper and did not decide the patent-eligibility issues on their merits.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.