James B. Goodman filed a complaint alleging patent infringement on Thursday in the Western District of Texas against Dell Inc., Dell Technologies, Inc. and Dell Technologies, LLC (collectively Dell) regarding its DDR4 memory device products.
Goodman’s patents-in-suit are U.S. Patent No. 4,617,624B2; 6,243,315B1 (“the ’315 Patent”); and 6,257,911B1, entitled “Multiple configuration memory circuit,” “Computer memory system with a low power down mode,” and “low insertion force connector with wipe,” respectively. Dell is accused of infringing the patents manufacturing, importing, and selling infringing products in the United States.
The plaintiff proffered that Dell infringed at least claim 5 of the ’315 patent “by providing a memory system for use in a computer system that (has) a plurality of volatile solid state memory devices that retain information when an electrical power source is applied to said memory devices within a predetermined voltage range and capable of being placed in a self refresh mode.” Dell allegedly utilizes the DDR4 memory product, which is compliant with the Joint Electron Device Engineering Council Solid State Technology Association (JEDEC), to imply adherence to the specified standards and requirements.
The complaint goes on to explain that the DDR4 SDRAM has a “high-speed dynamic random-access memory internally configured to sixteen banks,” meaning there are “two or more memory devices in the memory system into which data may be written or from which data may be retrieved while a[n] electrical power source … is applied to the memory devices and when the voltage reaches a predetermined threshold outside that range, the memory devices will no longer retain their current state of information.” The product is a chip, which the plaintiff claims requires “a specific range of applied voltage to retain data” as specified by JEDEC. Thus, the plaintiff used this alleged information, namely the DDR4’s supposed use of a plurality of volatile state memory devices, requiring an electrical source, as evidence for his allegations against Dell’s use of this patented technology.
Additionally, as stated in the patented claim, the DDR4 SDRAM is purportedly “capable of being placed in a self refresh mode.” Claim 5 states that when “memory devices are electrically isolated, any signals received on said respective address lines and respective control lines do not reach said memory devices.” The plaintiff averred that Dell infringed this patent from its alleged use of this technology with its DDR4 memory device.
According to the complaint, Dell directly and willfully infringed and induced infringement of the patents. The plaintiff has sought declaratory judgment, an award for damages, an award for costs and fees, an award for royalties, and other relief.
Goodman is represented by Garteiser Honea, PLLC.