DCT

1:25-cv-00942

Micron Technology Inc v. Netlist Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00942, D. Del., 07/29/2025
  • Venue Allegations: Venue is asserted as proper in the District of Delaware because Defendant Netlist, Inc. is a Delaware corporation and therefore subject to personal jurisdiction in the district.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its memory module products do not infringe Defendant’s patent related to on-module power management for hybrid volatile/non-volatile memory systems.
  • Technical Context: The technology concerns dual in-line memory modules (DIMMs) that integrate both volatile (DRAM) and non-volatile (Flash) memory with on-board controllers and power management circuits to enhance performance and data integrity in computer systems.
  • Key Procedural History: The complaint alleges a contentious litigation history between the parties, referencing prior lawsuits and communications. Plaintiff alleges that Defendant has a pattern of asserting patents that were later invalidated by the U.S. Patent and Trademark Office's Patent Trial and Appeal Board (PTAB). The current dispute arises from Defendant's alleged threats of litigation and demands for a license concerning the patent-in-suit, including multiple on-site inspections of Plaintiff's design files.

Case Timeline

Date Event
2007-06-01 ’366 Patent Earliest Priority Date
2021-04-28 Netlist sends letter to Micron alleging infringement by its DIMM products
2021-05-19 Netlist sends follow-up letter regarding licenses for RDIMM, LRDIMM, and NVDIMM products
2021-07-09 Netlist sends letter urging a meeting with "decision makers" to discuss its patent portfolio
2023-07-01 Netlist representatives begin conducting inspections of Micron's design files (occurred on 34 occasions through October 2023)
2025-06-03 Netlist identifies asserted claims of the '366 patent in a "Supplemental Amendment and Examiner Interview Summary"
2025-07-29 U.S. Patent No. 12,373,366 Issues
2025-07-29 Complaint for Declaratory Judgment Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 12,373,366 - "MEMORY WITH ON-MODULE POWER MANAGEMENT"

  • Patent Identification: U.S. Patent No. 12,373,366, “MEMORY WITH ON-MODULE POWER MANAGEMENT,” issued July 29, 2025 (the “’366 Patent”).

The Invention Explained

  • Problem Addressed: The patent’s background section identifies the performance bottleneck created when a high-speed central processing unit (CPU) must manage data transfers to and from slower memory and storage subsystems, which consumes processing cycles and degrades overall system performance (’366 Patent, col. 1:40-62).
  • The Patented Solution: The invention describes a memory module, such as a Dual In-line Memory Module (DIMM), equipped with its own intelligent controller and power management circuitry (’366 Patent, Abstract). This on-module system includes multiple power converter circuits and a voltage monitor circuit. The voltage monitor is configured to detect a trigger condition, such as an input voltage exceeding a threshold, and in response, the controller initiates a write operation to save data into on-module nonvolatile memory, thereby preserving data integrity during power events without requiring direct, cycle-by-cycle management by the host system's CPU (’366 Patent, col. 24:50-58).
  • Technical Importance: By embedding power management intelligence directly onto the memory module, the patented technology sought to offload critical data-preservation tasks from the CPU, aiming to improve both system reliability and data throughput, particularly in server environments where uptime and data integrity are paramount (’366 Patent, col. 1:12-24).

Key Claims at a Glance

  • The complaint identifies independent claims 1, 16, and 29 as having been asserted by Netlist (Compl. ¶27).
  • The essential elements of independent claim 1 include:
    • A dual in-line memory module (DIMM) with a printed circuit board (PCB) and specific sets of edge connections for power, data, and address/control signals.
    • A controller on the PCB that includes a voltage monitor circuit and nonvolatile memory.
    • The voltage monitor circuit is configured to: (i) monitor an input voltage, (ii) generate a trigger signal upon detecting a trigger condition, and (iii) transmit the signal to the controller.
    • The controller is configured to write data into the nonvolatile memory in response to the trigger signal, which occurs when the input voltage exceeds a threshold.
    • A set of components including DDR SDRAM devices.
    • First, second, third, and fourth converter circuits coupled to the PCB to receive power and deliver it via four regulated voltage lines.
    • A specific configuration of DDR SDRAM devices arranged in a first group of at least five devices and a second group of at least four devices, connected to distinct chip select lines.
  • The prayer for relief seeks a declaration of non-infringement as to "any claim" in the patent (Compl. p. 12, ¶a).

III. The Accused Instrumentality

Product Identification

  • Plaintiff’s DDR4 and DDR5 DIMM products (Compl. ¶13).

Functionality and Market Context

  • The complaint, seeking a declaration of non-infringement, does not provide a detailed affirmative description of the accused products' functionality. Instead, it asserts that the products lack the specific features required by the patent's independent claims (Compl. ¶¶28-32).
  • The core of the Plaintiff's position is that its industry-standard DDR4 and DDR5 DIMM products do not incorporate the particular "controller" or the specific four-"converter" power architecture recited in the asserted claims (Compl. ¶¶29-30).
  • Plaintiff positions itself as a "world leader in innovative computer-memory and data-storage solutions" and the "only United States founded memory semiconductor designer and manufacturer," framing the accused products as part of its core business in a competitive global market (Compl. ¶2).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The analysis below summarizes the Plaintiff's (Micron's) arguments for why its products do not meet the limitations of the asserted claims.

’366 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Non-Infringing Functionality Complaint Citation Patent Citation
(b) a controller including a voltage monitor circuit... configured to: (i) monitor an input voltage... (ii) generate a trigger signal upon detecting a trigger condition; and (iii) transmit the trigger signal... wherein the controller is configured to perform... a write operation to write data into the nonvolatile memory... Plaintiff alleges its DIMM products do not satisfy the "controller" limitation, asserting they do not contain a controller with the claimed structure or functionality. ¶29 col. 24:50-58
(d) first, second, third, and fourth converter circuits coupled to the PCB... and configured to receive power from the input voltage supply line and to deliver power via first, second, third, and fourth regulated voltage lines... Plaintiff alleges its DIMM products do not satisfy the "converter" limitation, asserting they do not contain the four claimed converter circuits. ¶30 col. 26:10-42
(d4) a fourth component configured to receive power via at least the fourth regulated voltage line; Plaintiff alleges its DIMM products do not satisfy this limitation regarding a fourth component powered by a fourth regulated voltage line. ¶31 col. 45:10-23
(e2) wherein each component of the set of components... receives power only via the one or more of the first, second, third, and fourth regulated voltage lines, Plaintiff alleges its DIMM products do not satisfy this limitation, which requires components to receive power "only" from the claimed regulated voltage lines. ¶32 col. 45:30-33
  • Identified Points of Contention:
    • Scope Questions: A primary issue for the court will be construing the term "controller." Does the term, as defined by its specific functions in claim 1(b) (voltage monitoring, trigger generation, and writing to nonvolatile memory), read on the standard Power Management Integrated Circuits (PMICs) used in modern DIMMs, or does it require a more specialized, distinct component as described in the patent's embodiments? (Compl. ¶29).
    • Technical Questions: A key factual dispute will be whether Plaintiff's products contain the specific power architecture claimed, namely the "first, second, third, and fourth converter circuits" (Compl. ¶30). The analysis will question whether the multiple voltage regulation stages within a modern PMIC can be considered distinct "converters" or if the patent requires physically separate circuits. Further, the negative limitation requiring components to receive power "only" from the specified lines raises a stringent factual test that, if met by Plaintiff, could be a strong basis for non-infringement (Compl. ¶32).

V. Key Claim Terms for Construction

  • The Term: "controller"

  • Context and Importance: This term is central to the dispute, as Plaintiff's primary non-infringement argument is that its products lack the claimed "controller" (Compl. ¶29). The claim itself provides a functional definition, tying the controller to monitoring voltage, generating a trigger, and initiating a write to nonvolatile memory. The construction of this term may be dispositive.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: A party advocating for a broader scope might point to the patent's general description of the controller's role in managing the interface between volatile and non-volatile memory subsystems, arguing any on-module logic performing this general function falls within the claim's scope (’366 Patent, col. 4:10-24).
    • Evidence for a Narrower Interpretation: Practitioners may focus on the patent’s detailed embodiments to narrow the term. Figure 7 and the accompanying text depict the "on-DIMM Controller (CDC) 502" as a complex, multi-block component including a scheduler, command interpreter, and distinct control modules, suggesting a far more specific and capable device than a generic PMIC (’366 Patent, Fig. 7; col. 15:7-25).

  • The Term: "first, second, third, and fourth converter circuits"

  • Context and Importance: Plaintiff explicitly denies that its products include these four circuits (Compl. ¶30). The infringement analysis depends on whether the power regulation architecture in the accused DIMMs can be characterized as having four distinct "converter circuits."

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: A party could argue that functionally distinct voltage regulation outputs from a single, complex PMIC satisfy the limitation, viewing them as separate logical "circuits" even if physically integrated.
    • Evidence for a Narrower Interpretation: The patent specification, particularly in diagrams like Figure 16, illustrates distinct blocks for different converters (e.g., "Buck Converter" 1122, "Dual Buck Reg/Conv" 1124, "BUCK-BOOST CONVERTER" 1126), which may support an interpretation that the claims require physically or at least structurally distinct circuits (’366 Patent, Fig. 16).

VI. Other Allegations

  • Indirect Infringement: The complaint seeks a declaratory judgment of non-infringement for both direct and indirect infringement (Compl. ¶35). However, it does not plead specific facts to negate the elements of indirect infringement (e.g., knowledge and intent), focusing its arguments entirely on the absence of underlying direct infringement by its products.
  • Willful Infringement: As a declaratory judgment action filed by the accused infringer, the complaint does not contain a claim for willful infringement against the Plaintiff. However, the complaint repeatedly alleges that the Defendant (Netlist) has engaged in "bad faith" conduct, such as enforcing patents it allegedly knew were invalid and making "non-credible" infringement allegations (Compl. ¶¶ 4, 10). These allegations appear calculated to support a future motion for an "exceptional case" finding under 35 U.S.C. § 285, which would allow Plaintiff to recover attorneys' fees (Compl. p. 12, ¶e).

VII. Analyst’s Conclusion: Key Questions for the Case

  • A key evidentiary question will be one of architectural correspondence: do Plaintiff's standard DDR4 and DDR5 DIMMs contain the specific four-converter power delivery system and the functionally-defined "controller" required by the independent claims, or is there a fundamental technical mismatch between the accused products' integrated PMIC-based design and the patent's more discrete, multi-component architecture?
  • The case will also turn on a core issue of claim construction: can the term "controller," which is defined in the claim by its role in triggering data backups to non-volatile memory, be construed to cover a standard on-DIMM PMIC, or is it limited by the specification's embodiments to a more complex and specialized data management unit? The court's answer to this question may resolve the central dispute.