DCT

2:24-cv-01073

Radian Memory Systems v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-1073, E.D. Tex., 12/24/2024
  • Venue Allegations: Plaintiff alleges venue is proper against Samsung Electronics Co., Ltd. as a foreign entity subject to personal jurisdiction in the district. Venue is alleged against Samsung Electronics America, Inc. based on its maintenance of a regular and established place of business in Plano, Texas, within the district, where it allegedly commits acts of infringement and maintains business property.
  • Core Dispute: Plaintiff alleges that Defendant’s Zoned Namespaces (ZNS) solid-state drives (SSDs) infringe seven patents related to cooperative flash memory management technologies.
  • Technical Context: The technology concerns advanced methods for managing NAND flash memory in high-performance storage devices to overcome the inefficiencies, latency, and premature wear associated with conventional Flash Translation Layers (FTLs), a domain critical for enterprise and data center storage solutions.
  • Key Procedural History: The complaint alleges that Samsung had extensive pre-suit knowledge of Radian's technology and patents. It details numerous instances where Radian's patents were cited by USPTO examiners against Samsung’s own patent applications, or were cited by Samsung itself during prosecution. The complaint also alleges that Samsung was a key participant in the NVMe industry group that developed the ZNS standard, a standard Radian claims is based on its patented Cooperative Flash Management (CFM) technology, which Radian had presented at industry conferences attended by Samsung employees.

Case Timeline

Date Event
2014-09-09 Earliest Priority Date for ’801 Patent
2015-07-31 Earliest Priority Date for ’656, ’657, ’995 Patents
2016-06-16 Earliest Priority Date for ’183 Patent
2019-01-24 Earliest Priority Date for ’772, ’614 Patents
2021-06-02 Samsung announces debut of PM1731a, its first ZNS SSD
2022-04-19 Issue Date for ’995 Patent
2022-05-31 Issue Date for ’656, ’657 Patents
2023-01-03 Issue Date for ’183 Patent
2023-06-20 Issue Date for ’614 Patent
2023-07-25 Issue Date for ’772 Patent
2023-08-29 Issue Date for ’801 Patent
2024-12-24 Complaint Filing Date

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

U.S. Patent No. 11,544,183 - "Nonvolatile Memory Controller Host-Issued Address Delimited Erasure and Memory Controller Remapping of Host-Address Space for Bad Blocks"

  • Issued: January 3, 2023 (Compl. ¶737)

The Invention Explained

  • Problem Addressed: The patent describes that conventional flash memory controllers using a Flash Translation Layer (FTL) suffer from substantial overhead, write amplification, and bandwidth competition. These issues lead to inconsistent latency and premature wear on the memory, which is problematic for high-performance storage applications (Compl. ¶741; ’183 Patent, col. 1:30-3:37).
  • The Patented Solution: The invention proposes a system of "cooperative interaction" where the memory controller offloads some management responsibility to the host computer. The controller tracks and provides the host with information about subdivisions of the memory, which the host then uses to issue write commands targeted to specific physical locations. This approach is intended to substantially eliminate the need for an FTL on the controller, thereby simplifying the controller design, reducing wear, and avoiding duplication of management features (Compl. ¶742; ’183 Patent, col. 5:27-37, col. 6:33-37).
  • Technical Importance: This cooperative host-controller architecture aimed to redefine responsibilities to improve quality-of-service, performance, cost, and endurance for data center class storage devices (Compl. ¶11).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶745).
  • Claim 1 of the ’183 Patent recites a memory controller comprising:
    • A host interface and a memory interface.
    • Logic to track information indicating the extent of page utilization of each memory subdivision.
    • Logic to receive a write request from a host that designates a specific subdivision and, in response, update the page utilization information for that subdivision.
    • Logic to send the host the page utilization information and a corresponding address.
    • Logic to receive an erasure request for a specific subdivision and responsively control erasure of erase blocks within that subdivision.
    • Logic to detect a defect in an erase block during erasure and substitute a different erase block.
  • The complaint alleges infringement of at least one claim and indicates additional infringed claims may be disclosed later (Compl. ¶6).

U.S. Patent No. 11,709,772 - "Storage System with Multiplane Segments and Cooperative Flash Management"

  • Issued: July 25, 2023 (Compl. ¶835)

The Invention Explained

  • Problem Addressed: The patent notes the difficulty of realizing the performance benefits of multi-plane or multi-die flash memory architectures at the application level. Logical addresses from a host are typically random and become scattered throughout the physical memory, which prevents the host or controller from grouping related data in a manner optimized for parallel, multi-plane access (Compl. ¶839; ’772 Patent, col. 2:5-41).
  • The Patented Solution: The invention provides the host with "insight into geometry," allowing it to organize the address space and pre-plan data placement for writes. This facilitates later multi-plane read access that is consistent with the physical addressing restrictions of the memory array, thereby improving throughput without being encumbered by controller-level address translation (Compl. ¶840; ’772 Patent, col. 5:1-10).
  • Technical Importance: This solution enables software to leverage the inherent physical parallelism of modern NAND flash memory, which is a primary mechanism for increasing SSD performance.

Key Claims at a Glance

  • The complaint asserts independent claim 2 (Compl. ¶843).
  • Claim 2 of the ’772 Patent recites a solid-state storage drive (SSD) comprising:
    • A host interface for communicating with a host using NVMe commands.
    • Non-volatile NAND flash memory comprising erase units and pages.
    • Logic coupled to the host interface and flash memory, which operates to:
    • Divide the flash memory into zones, where each zone comprises two or more erase units on two or more different planes.
    • In response to a host write command, perform a multi-plane write of data to erase units on different planes within the specified zone.
    • Generate metadata based on the accessing and maintenance of erase units in the zone.
    • Based on the metadata, make a notification available to the host that recommends performing maintenance on the zone.
  • The complaint alleges infringement of at least one claim and indicates additional infringed claims may be disclosed later (Compl. ¶6).

U.S. Patent No. 11,681,614 - "Storage Device with Subdivisions, Subdivision Query, and Write Operations"

  • Issued: June 20, 2023 (Compl. ¶926)
  • Technology Synopsis: The patent addresses the difficulty of realizing multi-plane benefits in conventional memory devices due to the scattering of logical addresses (Compl. ¶930; ’614 Patent, col. 2:7-41). The solution provides the host with "insight into geometry" to organize address space for improved, multi-plane memory access (Compl. ¶931; ’614 Patent, col. 4:61-64).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶934).
  • Accused Features: The complaint alleges that Samsung's ZNS SSDs, which divide flash memory into zones and respond to host commands for operations within those zones, infringe this patent (Compl. ¶¶935-968).

U.S. Patent No. 11,740,801 - "Cooperative Flash Management of Storage Device Subdivisions"

  • Issued: August 29, 2023 (Compl. ¶1018)
  • Technology Synopsis: The patent describes techniques for efficiently managing data storage and migration in a heterogeneous memory system by using "per-data metrics" (such as hot/cold status or age) and memory degradation metrics (Compl. ¶1022; ’801 Patent, col. 1:66-2:4, col. 4:61-64). The system uses these metrics to manage memory operations, such as moving data that violates a persistence criterion to a different location or tier (Compl. ¶1023; ’801 Patent, col. 3:23-46).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶1026).
  • Accused Features: The complaint alleges that Samsung's ZNS SSDs, which map logical addresses to physical subdivisions (zones) and provide information about those zones to the host for maintenance purposes, infringe this patent (Compl. ¶¶1027-1071).

U.S. Patent No. 11,347,657 - "Addressing Techniques for Write and Erase Operations in a Non-Volatile Storage Device"

  • Issued: May 31, 2022 (Compl. ¶1121)
  • Technology Synopsis: The patent discloses hierarchical address virtualization within a memory controller, which subdivides an incoming memory address into discrete fields corresponding to hierarchical groups of structural elements (Compl. ¶1124, 1125; ’657 Patent, Abstract, col. 2:66-3:21). This allows a host to direct operations to physically distinct structures in a way that limits performance-degrading conflicts.
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶1128).
  • Accused Features: The complaint alleges that Samsung's ZNS SSDs, which receive address information from a host and derive address portions to identify specific namespaces and zones, infringe this patent (Compl. ¶¶1139-1165).

U.S. Patent No. 11,347,656 - "Storage Drive with Geometry Emulation Based on Division Addressing and Decoupled Bad Block Management"

  • Issued: May 31, 2022 (Compl. ¶1215)
  • Technology Synopsis: The technology is substantially similar to that of the ’657 Patent, concerning hierarchical address virtualization within a memory controller to provide predictable I/O latency (Compl. ¶1218, 1219; ’656 Patent, Abstract, col. 2:66-3:21). This patent's claims appear to focus on remapping logical erase units to physical units to handle failure conditions.
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶1222).
  • Accused Features: The complaint alleges that Samsung's ZNS SSDs, which derive address portions from host commands to identify namespaces and zones and which perform bad block management, infringe this patent (Compl. ¶¶1223-1254).

U.S. Patent No. 11,307,995 - "Storage Device With Geometry Emulation Based on Division Programming and Decoupled NAND Maintenance"

  • Issued: April 19, 2022 (Compl. ¶1304)
  • Technology Synopsis: The technology is substantially similar to that of the ’657 and ’656 Patents, concerning hierarchical address virtualization within a memory controller (Compl. ¶1307, 1308; ’995 Patent, Abstract, col. 2:66-3:21). This patent's claims appear to focus on maintaining and using metadata related to when data was programmed to manage data copying and remapping.
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶1311).
  • Accused Features: The complaint alleges that Samsung's ZNS SSDs, which derive address portions to identify namespaces and zones and which use metadata for maintenance operations like wear-leveling, infringe this patent (Compl. ¶¶1312-1350).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Samsung Solid-State Drive (SSD) products that implement Zoned Namespaces (ZNS) technology. Specific product families identified include the PM1731a, PM1733, PM1735, PM9731a, and PB SSD products, as well as other Samsung SSDs that implement ZNS or substantially similar functionalities (Compl. ¶327). The Samsung PM1733 is used as a primary exemplar throughout the infringement allegations (Compl. ¶753).

Functionality and Market Context

The accused products are alleged to implement the NVMe ZNS Command Set Specification, an architecture that divides the SSD's memory into distinct zones (Compl. ¶196, ¶748). This technology is promoted for its ability to increase storage efficiency, reduce write amplification, optimize performance, and extend the lifespan of an SSD, particularly in enterprise, data center, and cloud environments (Compl. ¶196, ¶323). The complaint alleges that the accused SSDs use various NVMe commands, including Zone Management Receive and Zone Management Send, to manage these zones in cooperation with a host system (Compl. ¶¶352-362). The complaint includes a product photo of the Samsung PM1733 SSD, annotating the memory controller and flash memory chips (Compl. ¶753, p. 84).

IV. Analysis of Infringement Allegations

’183 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
[1a] a host interface; The accused SSDs, such as the PM1733, contain a PCIe host interface for communication with a host system. A product brief screenshot shows the PM1733 has a PCIe Gen 3/4 x4 Host Interface (Compl. ¶853, p. 120). ¶756-757 col. 4:52-54
[1c] logic to track information indicating extent of page utilization of each of the subdivisions; The accused SSDs maintain a "write pointer" for each zone, which the complaint alleges indicates the extent of page utilization within that zone (subdivision). ¶760-761 col. 4:46-48
[1d] logic to receive a write request from a host via the host interface...wherein the logic to track is to...update the information indicating extent of page utilization... The accused SSDs receive Write or Zone Append commands from a host, which are write requests directed to a specific zone. In executing the write, the SSDs update the zone's write pointer. ¶762-773 col. 5:27-37
[1e] logic to send the host the information indicating extent of page utilization of the specific one of the subdivisions and an address corresponding to the specific one of the subdivisions; In response to a Zone Management Receive command, the accused SSDs send the host the write pointer (alleged page utilization info) and the starting LBA of the zone (address). ¶774-775 col. 5:48-56
[1f] logic to receive an erasure request from the host...to responsively control erasure of each unerased erase block...and to update the information indicating extent of page utilization... The accused SSDs receive a Zone Management Send command specifying a Reset Zone action, which is an erasure request. This erases the blocks in the zone and resets the write pointer. ¶776-781 col. 7:38-51
[1g] logic to, in connection with the erasure, detect a defect in one of the erase blocks...to responsively substitute one or more different erase blocks...for which the defect was detected; The accused SSDs perform bad block management, where the firmware detects a bad block, retires it, and replaces it with a reserved block. ¶782-783 col. 7:52-62

’772 Patent Infringement Allegations

Claim Element (from Independent Claim 2) Alleged Infringing Functionality Complaint Citation Patent Citation
[2a] a host interface configured to communicate with a host using commands from a Non-Volatile Memory Express (NVMe) standard; The accused SSDs, such as the PM1733, contain a host interface and are specified to be compliant with the NVMe standard. ¶852-853 col. 11:29-32
[2b] non-volatile memory comprising NAND flash memory, the NAND flash memory comprising a plurality of erase units and each erase unit comprising a plurality of pages; The accused SSDs contain Samsung V-NAND flash memory, which is comprised of erase units (blocks) that in turn are comprised of pages. ¶854-857 col. 11:33-37
[2e] divide the flash memory into zones; wherein the zones are non-overlapping subdivisions...each zone comprises two or more erase units, the erase units in at least one zone are on two or more different planes... The accused SSDs implement ZNS, dividing memory into zones. Each zone comprises multiple erase blocks (erase units), and the underlying NAND architecture has multiple planes. The complaint provides a product brief screenshot stating the PM1733 is capable of supporting ZNS implementations (Compl. ¶863, p. 128). ¶862-866 col. 11:51-59
[2f] in response to a write command from the host...perform a multi-plane write of said data to erase units on different planes in the specified zone using a common page address... The accused SSDs allegedly perform multi-plane writes to erase units on different planes within a zone, using a common page address to write concurrently. ¶867-870 col. 12:4-14
[2g] generate metadata based on accessing and maintenance of erase units in the specified zone; The accused SSDs generate metadata related to internal operations such as wear-leveling, bad block counts, and erase fail counts, which relate to the maintenance of erase units. ¶871-872 col. 12:15-18
[2h] based on the metadata, make a notification available to the host that recommends performing maintenance on the specified zone... The ZNS specification, which the accused products implement, defines a "Reset Zone Recommended" attribute that is made available to the host and serves as a notification recommending maintenance (a zone reset). ¶873-875 col. 12:19-25

Identified Points of Contention

  • Technical Equivalence: A primary point of contention will likely be whether the specific features and data structures of the NVMe ZNS standard, as implemented by Samsung, are technically equivalent to the elements recited in the claims. For the ’183 Patent, this includes whether a ZNS "write pointer" is "information indicating extent of page utilization." For the ’772 Patent, this includes whether the ZNS "Reset Zone Recommended" attribute constitutes a "notification...that recommends performing maintenance."
  • Scope Questions: The infringement theories rely on equating the patents' term "subdivision" with the ZNS term "zone." The court's construction of "subdivision" based on the patent specification will be critical. For the ’772 Patent, a question may arise as to whether the accused SSDs perform a "multi-plane write" in response to a host write command in the specific manner required by the claim, or if such operations are managed differently by the controller.

V. Key Claim Terms for Construction

  • The Term: "information indicating extent of page utilization" (’183 Patent, Claim 1)
  • Context and Importance: The infringement allegation for this element relies entirely on equating it with the "write pointer" used in ZNS SSDs (Compl. ¶761). The viability of the infringement case for the ’183 patent may depend on whether this term is construed broadly enough to cover a pointer to the next available write location, or if it is construed more narrowly to require a more comprehensive status metric (e.g., a count of used/free pages).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent's abstract and summary sections may describe the invention's purpose in general terms of cooperative management, which could support interpreting this term as any data that helps the host manage space, including a simple pointer.
    • Evidence for a Narrower Interpretation: The detailed description of the ’183 Patent could describe specific embodiments that track page utilization with detailed bitmaps or counters. Such specific examples may be used to argue for a narrower construction that excludes a simple write pointer.
  • The Term: "notification available to the host that recommends performing maintenance" (’772 Patent, Claim 2)
  • Context and Importance: Plaintiff's infringement theory maps this limitation to the "Reset Zone Recommended" attribute in the ZNS standard—a bit in a data structure that a host can query (Compl. ¶874). Practitioners may focus on whether "notification" requires an active alert or message from the SSD to the host, or if it can be a passive status bit that is simply made "available" for the host to read.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification may use general language like "making data accessible" or "providing an indication" to the host, which could support construing a readable attribute bit as a "notification." (e.g., ’772 Patent, col. 12:3-9, "The memory controller makes data based on this stored information accessible to the host.").
    • Evidence for a Narrower Interpretation: The specification may describe embodiments where the controller sends an interrupt, message, or other active signal to the host. Such language could support an argument that a passive, query-able attribute bit does not meet the "notification" requirement.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement. Inducement is based on allegations that Samsung actively encouraged infringement by developing and promoting the ZNS standard, publishing product briefs and user guides instructing customers on the use of ZNS features, and providing software tools (Compl. ¶¶804-805, 812). Contributory infringement is based on allegations that the accused SSDs, including their memory controllers and firmware, are material components especially made for use in an infringing system and are not staple articles of commerce (Compl. ¶¶807, 814).

Willful Infringement

Willfulness is alleged based on Samsung's purported pre-suit knowledge of Radian's patents and technology. The complaint provides an extensive list of Samsung's own U.S. and foreign patent applications where Radian's patents were cited either by Samsung or by patent examiners (Compl. ¶¶381-590). It also alleges Samsung knew of Radian’s technology from industry conferences and its role in the NVMe working group that developed the ZNS standard, which Radian pioneered (Compl. ¶¶244-313).

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

  • A central issue will be one of technical mapping: Does the functionality of Samsung's SSDs, which operate according to the public NVM Express Zoned Namespaces standard, perform the specific steps recited in Radian's claims? The case will likely require a detailed, element-by-element comparison between the operation of a standard ZNS drive and the patent claims, focusing on whether concepts like a "write pointer" and a "Reset Zone Recommended" attribute are technically and legally equivalent to the claimed "information indicating page utilization" and "notification...that recommends maintenance."
  • A key evidentiary question will be the scope and impact of Samsung's alleged knowledge: The complaint presents substantial documentary evidence alleging Samsung's awareness of Radian's patent portfolio through years of patent prosecution history. A critical question for willfulness will be whether this evidence demonstrates that Samsung knew of or was willfully blind to the alleged infringement of the specific asserted patents when it commercialized its ZNS products.
  • The case may also turn on claim construction: The dispute may focus on the proper interpretation of key claim terms. Can the patents' term "subdivision," described in the context of cooperative flash management, be construed to cover the standardized "zone" of the ZNS protocol? The outcome of such definitional questions will be pivotal in determining whether the accused products fall within the scope of the asserted claims.