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ITCJune 1, 2026·337-TA-1506·SUPPLEMENTAL COMPLAINT FILED

Certain Nand and Dram Memory Chips and Products Containing the Same; Inv. No. 337-TA-1506 (Violation)

U.S. International Trade Commission

Holding

This supplemental complaint, filed by MonolithIC 3D Inc. in response to an OUII request for additional information, replaces paragraph 24 of the May 11, 2026 verified complaint (DN 3908) to describe the categories of accused products. It adds no respondents and alleges no additional unfair acts.

Why It Matters

The supplement clarifies the accused product categories (3D NAND chips, HBM DRAM chips, and products containing them) for a Section 337 investigation, which bears on the scope of any requested relief. It is a limited procedural clarification and does not change the underlying allegations. The document does not identify the asserted patents or the relief sought.

Full Summary

This supplemental complaint, filed by MonolithIC 3D Inc. in response to an OUII request for additional information, replaces paragraph 24 of the May 11, 2026 verified complaint (DN 3908) to describe the categories of accused products. It adds no respondents and alleges no additional unfair acts. The supplement clarifies the accused product categories (3D NAND chips, HBM DRAM chips, and products containing them) for a Section 337 investigation, which bears on the scope of any requested relief. It is a limited procedural clarification and does not change the underlying allegations. The document does not identify the asserted patents or the relief sought. Complainant is MonolithIC 3D Inc., represented by Fabricant Rubino Lambrianakos LLP; the document does not name the respondents. Filed as the Second Supplement to the Verified Complaint (Docket No. 3908), which was filed May 11, 2026, in response to an OUII request. Replaces paragraph 24 of the complaint under 19 C.F.R. 210.10(b)(1) and 210.12(a)(12). Accused categories: certain 3D NAND memory chips, HBM DRAM memory chips, and products containing them such as NAND flash and storage products, SSD products, and DRAM products. Alleged unfair acts: sale for importation, importation, and/or sale within the United States after importation of the Accused Products. The supplement adds no respondents or additional unfair acts, and the original February 17, 2026 verification remains accurate.

Key Points

  • Complainant is MonolithIC 3D Inc., represented by Fabricant Rubino Lambrianakos LLP; the document does not name the respondents.
  • Filed as the Second Supplement to the Verified Complaint (Docket No. 3908), which was filed May 11, 2026, in response to an OUII request.
  • Replaces paragraph 24 of the complaint under 19 C.F.R. 210.10(b)(1) and 210.12(a)(12).
  • Accused categories: certain 3D NAND memory chips, HBM DRAM memory chips, and products containing them such as NAND flash and storage products, SSD products, and DRAM products.
  • Alleged unfair acts: sale for importation, importation, and/or sale within the United States after importation of the Accused Products.
  • The supplement adds no respondents or additional unfair acts, and the original February 17, 2026 verification remains accurate.
amended complaintinfringement

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