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ITCJune 1, 2026·337-TA-3908·SUPPLEMENTAL COMPLAINT FILED

Certain NAND and DRAM Memory Chips and Products Containing the Same; Inv. No. 337-TA-3908 (Violation)

U.S. International Trade Commission

Holding

This supplemental complaint replaces paragraph 24 to clarify that MonolithIC 3D Inc. accuses proposed/unknown respondents of violating Section 337 by importing, selling for importation, and selling after importation certain 3D NAND memory chips, HBM DRAM memory chips, and products containing them that allegedly infringe one or more asserted patents. The supplement states that it does not add respondents or new unfair acts.

Why It Matters

The accused products cover high-value memory technologies used in SSDs, NAND flash/storage products, DRAM products, and other electronics. If instituted and proven, the case could support import relief such as an exclusion order barring infringing memory chips and downstream products from the U.S. market.

Full Summary

This supplemental complaint replaces paragraph 24 to clarify that MonolithIC 3D Inc. accuses proposed/unknown respondents of violating Section 337 by importing, selling for importation, and selling after importation certain 3D NAND memory chips, HBM DRAM memory chips, and products containing them that allegedly infringe one or more asserted patents. The supplement states that it does not add respondents or new unfair acts. The accused products cover high-value memory technologies used in SSDs, NAND flash/storage products, DRAM products, and other electronics. If instituted and proven, the case could support import relief such as an exclusion order barring infringing memory chips and downstream products from the U.S. market. Supplemental filing made in response to an OUII request for additional information. Replaces Complaint paragraph 24 to identify accused product categories: 3D NAND, HBM DRAM, NAND storage/flash products, SSDs, and DRAM products. No additional respondents or additional unfair acts are alleged in the supplement.

Key Points

  • Supplemental filing made in response to an OUII request for additional information.
  • Replaces Complaint paragraph 24 to identify accused product categories: 3D NAND, HBM DRAM, NAND storage/flash products, SSDs, and DRAM products.
  • No additional respondents or additional unfair acts are alleged in the supplement.
infringementexclusion ordercease & desistamended complaint

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