Netlist, Inc. v. Samsung Electronics Co. Ltd. et al

  • Court: Texas State, Marshall Division, District Court
  • Case Number: 2:21-cv-00463
  • Filed: August 11, 2023
  • Judges: Rodney Gilstrap
  • Case Type: 830 Patent
  • Cause: 35:271 Patent Infringement

Parties Involved

  • Plaintiff(s): Netlist, Inc.
    • Counsel for Plaintiff: Jason G. Sheasby | Andrew J. Strabone | Benjamin Monnin | Dovid Z. Kahn | Hong Annita Zhong | Lisa Sharrock Glasser | Michael David Harbour | Michael Meir Rosen | Michael William Tezyan | Nora Isabella Chestney | Rebecca L. Carson | Stephen M Payne | Thomas C Werner | Yanan Zhao | Jennifer Leigh Truelove | Kevin Lee Burgess | Samuel Franklin Baxter | Peter Rho | Soo A Hong
    • Expert witness for Plaintiff(s): Michael Brogioli | Dr. Andreas Groehn | Dr. William Henry Mangione-Smith |  David Kennedy |
  • Defendant(s): Samsung Electronics Co. Ltd. | Samsung Electronics America,  | Samsung Semiconductor, Inc.
    • Counsel for Defendants: Ruffin B. Cordell| Anthony Van Nguyen | Brian Livedalen | Daniel Aaron Tishman | Francis J. Albert | Karolina Jesien |Katherine Reardon | Lauren A. Degnan | Matthew Alan Colvin | Matthew Mosteller | Michael J. McKeon | Sara Christina Fish | Thomas Howard Reger II | Alice Juwon Ahn | Brian R. Nester | Peter Swanson | Robert Jason Fowler | Andrew Thompson (Tom) Gorham | James Travis Underwood | Melissa Richards Smith
    • Expert witness for Defendant(s): Phillip Kline | Joseph C. McAlexander III | Gabriel Robins | Paul K. Meyer | John B. Halbert

 Verdict Information

  • Verdict Date: April 21, 2023
  • Damages awarded to Plaintiff(s): $303,150,000
    • For the Infringement of ‘339 patent: $33,150,000
    • For the Infringement of ‘918 and ‘054 patents: $147,225,000
    • For the Infringement of  ‘060 and ‘160 patent: $122,775,000

About the Patent Infringement Case


Netlist, a pioneer in high-performance memory module technologies, filed a lawsuit against Samsung Electronics Co., Ltd. The lawsuit alleges infringement of three key patents. The complaint asserts that Samsung’s products infringe claims covered by U.S. Patent Nos. 10,858,506, 10,949,339, and 10,990,918. These products include DDR4 and DDR5 memory modules like LRDIMMs, RDIMMs, SODIMMs, and UDIMMs.

The ‘506 patent covers a memory module design with timing-controlled data buffering. Each buffer circuit can receive module control signals. They can also receive a module clock signal. Each circuit buffers a respective set of data signals accordingly. Netlist claims that Samsung’s accused DDR4 LRDIMM products incorporate data buffers that delay read strobes. They sample read data using the delayed strobes and transmit the sampled data to the memory controller, thereby infringing the ‘506 patent.

The ‘339 patent protects a memory module architecture with controlled byte-wise buffers. According to the complaint, Samsung’s DDR4 LRDIMMs infringe this patent by employing byte-wise buffers that actively drive respective byte-wise sections of write data to the memory devices during a specific time period, in response to module control signals.

The ‘918 patent covers a flash-DRAM hybrid memory module design that incorporates multiple buck converters and a converter circuit to provide regulated voltages to various components, such as SDRAM devices and a register clock driver (RCD). Netlist alleges that Samsung’s accused DDR5 memory modules, equipped with an on-DIMM power management integrated circuit (PMIC), infringe the ‘918 patent by implementing the claimed buck converters and converter circuit architecture.


The alleged patent infringement by Samsung has inflicted significant harm upon Netlist’s business operations and market position. One of the most blatant injuries arises from the loss of profits and sales that Netlist has suffered as a direct consequence of Samsung’s infringing products. With competitors like Samsung offering lower-priced alternatives that violate Netlist’s intellectual property, customers have been lured away, resulting in substantial revenue streams being diverted from Netlist’s coffers.

Moreover, Netlist has been deprived of the right to earn reasonable royalty payments from entities like Samsung for utilizing Netlist’s patented inventions. In a desperate bid to remain competitive against Samsung’s infringing but lower-priced products, Netlist may have been forced to erode its own pricing structures, slashing prices on their memory modules below desired levels. This price erosion has directly impacted Netlist’s profit margins.

The availability of Samsung’s infringing memory modules in the market has also threatened to displace Netlist’s hard-earned market share for compatible devices and systems. As customers gravitate towards the lower-priced alternatives, Netlist’s products face the risk of losing significant ground, undermining the company’s position in the competitive landscape.

Netlist’s licensing program, which relies on licensing its patented memory technologies to other companies, has been severely impacted by Samsung’s alleged infringement. Potential licensees may be reluctant to engage in licensing agreements, effectively crippling another critical revenue stream for the company.

The cumulative effects of lost sales, lost royalties, price erosion, market share declines, and damage to the licensing program represent a grave financial injury to Netlist’s business operations. These impacts also jeopardize Netlist’s future revenue potential and growth prospects, casting a long shadow over the company’s ability to sustain its technological leadership in the memory module industry.


In its legal battle against Samsung, Netlist is seeking a comprehensive array of damages and relief measures. The company specializes in high-performance memory solutions. At the forefront of Netlist’s demands are compensatory damages, aimed at compensating the company for the substantial losses it has suffered due to Samsung’s alleged patent infringement.

Netlist is also pursuing enhanced damages, a punitive measure reserved for instances of willful infringement. By alleging that Samsung’s actions were deliberate and a flagrant disregard for its intellectual property rights, the company aims to secure a more substantial financial penalty, serving as a deterrent against future infringements.

Additionally, Netlist is demanding that Samsung bear the legal costs of this high-stakes litigation. This entails reimbursing the attorneys’ fees incurred by the company in pursuit of its claims. This demand underscores Netlist’s commitment to holding Samsung accountable and ensuring that the financial burden of seeking justice does not fall solely on the aggrieved party.

Furthermore, Netlist is seeking other equitable relief. This is a broad category that could encompass various remedies tailored to address the specific injuries sustained. This could include injunctive relief, preventing Samsung from continuing the alleged infringing activities, or measures aimed at restoring Netlist’s market position and safeguarding its intellectual property rights.

As an innovator in the memory solutions industry, Netlist’s success hinges on continuous research and patented breakthroughs. However, when competitors allegedly engage in unauthorized use of its hard-won technology, it directly undermines Netlist’s leadership position, threatening to erode the very foundation upon which the company’s success has been built. Consequently, Netlist is determined to hold Samsung accountable. Netlist seeks various forms of damages and relief measures. These measures aim to protect its intellectual property rights and market position.

 Jury Verdict

In a significant legal victory for Netlist, a jury found that Samsung Electronics infringed multiple patents held by Netlist. These patents are related to high-performance memory module technologies. Specifically, the jury determined that Samsung infringed asserted claims of the ‘339, ‘918, ‘054, ‘060, and ‘160 patents owned by Netlist. Samsung failed to prove by clear and convincing evidence that any of these asserted claims were invalid. Furthermore, the jury concluded that Samsung’s infringement of the ‘339, ‘918, and ‘054 patents was willful, indicating a blatant disregard for Netlist’s intellectual property rights. As a result, the jury awarded Netlist substantial compensatory damages totaling  $303150,000 million, including $33,150,000 for the ‘339 patent, $147,225,000 for the ‘918 and ‘054 patents, and $122,775,000 for the ‘060 and ‘160 patents.

Court Documents: Available upon Request