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

This supplemental complaint, filed by MonolithIC 3D Inc. in response to an OUII request, replaces paragraphs 24 and 59 of its May 11, 2026 Verified Complaint to identify accused product categories and to show that KIOXIA's accused products are imported. It adds no respondents and alleges no additional unfair acts. The supplement clarifies the accused product categories (3D NAND, HBM DRAM, SSD, and related memory products) and supports the importation element of a Section 337 violation. It shows the complaint was supplemented at OUII's request, which bears on whether the investigation is instituted. The text does not state the relief sought. Complainant is MonolithIC 3D Inc.; the supplement is signed by counsel Evan H. Langdon of Fabricant Rubino Lambrianakos LLP. Paragraph 24 is replaced to list the accused product categories: 3D NAND memory chips, HBM DRAM memory chips, NAND flash and storage products, SSD products, DRAM products, AI-NAND products, HBF products, FPGA products, and PIM products, plus memory products containing them. Paragraph 59 is replaced to allege importation of KIOXIA's accused products, citing Corsair MP700 Elite packaging marked 'Made in Taiwan' that incorporates a KIOXIA BiCS8 3D TLC product. The supplement cites KIOXIA's admissions in its response in Investigation No. 337-TA-1492 that KIOXIA entities import and sell 3D NAND chips in the United States. The supplement states it adds no respondents and alleges no additional unfair acts, and that the original February 17, 2026 verification remains accurate. The asserted patents are not identified in this excerpt, and no relief or domestic industry allegations appear.