The phrase "open litigation" usually means a case that is not dismissed, but I would need to know more of the context to determine whether I would include a case that has been dismissed, with payments still unpaid to resolve the case. If in doubt, include it and explain the status.
Robert Stempler (please see DISCLAIMER below)
www.StopCollectionLawsuits.com
Generally, parties don't dismiss cases, and ask the court to retain jurisdiction to enforce anything that needs enforcement, as long as the executory things to be done aren't completely done. The judge keeps the case "pending" but it stays inactive, so it's technically still "open" but that word isn't used. The judge often schedules a hearing called an OSC re: Dismissal a month after e.g., the last of many installment payments is due, and if the payments all get made, the plaintiff makes sure to file the Request for Dismissal before that OSC date.