Plaintiff Netlist filed a complaint against SK Hynix for patent infringement. The complaint was filed in the Texas Western District Court. The asserted patents are “essential to certain DDR4 memory module standards promulgated by the Joint Electron Device Engineering Council, or ‘JEDEC,’ the standard-setting body for the microelectronics industry.”
The patents-in-suit are U.S. Patent No. 9,858,218 (“the ’218 patent”) and U.S. Patent No. 10,474,595 (“the ’595 patent”). The patents are generally for memory modules, “printed circuit board that contains, among other important components, DRAM integrated circuits.” It is usually installed into a computer and serves as temporary storage or working memory. “The ’218 patent relates to memory modules that operate in two distinct modes, where the module performs memory read or write operations in one mode, and one or more training sequences in the other. Similarly, the ’595 patent relates to memory modules that operate in two distinct modes, where the module performs memory read or write operations in one mode, and operations related to one or more training sequences in the other.”
Netlist, “a leading innovator in high-performance memory module technologies,” alleges that SK Hynix has directly and indirectly infringed upon the asserted patents. Infringing SK Hynix products include the Load Reduced Dual In-line Memory Modules (LRDIMM) and the Registered Dual In-line Memory Modules (RDIMM). Netlist’s are for cloud computing, virtualization and high-performance computing markets. The infringing SK Hynix products “are designed for use in servers, such as those supporting cloud-based computing and other data-intensive applications.” The specifications are set by JEDEC. Netlist has asserted its patent and is compliant with JEDEC’s patent policy. Netlist contacted SK Hynix to license its patents for LRDIMM and RDIMM, allegedly to no avail.
Netlist claims that SK Hynix infringes upon the ’218 patent because both are “memory module[s] operable with a memory controller of a host system” which include “a printed circuit board having edge connections that fit into a corresponding slot of the host system so as to be in electrical communication with the memory controller, the edge connections including first edge connections, second edge connections, and an error edge connection in addition to the first edge connections and the second edge connections.” SK Hynix allegedly infringes upon this claim because it includes a printed circuit board which has edge connection that fit into corresponding slots of the host system for communication, such as between the memory module and the memory controller and it has contacts or edge connections to connect a memory controller of a computer system.
Netlist has sought a declaratory judgment, compensation for damages, an award for costs, and other relief as determined by the Court. Netlist is represented by Mintz Levin Cohn Ferris Glovsky and Popeo.