Certain Dynamic Random Access Memory (DRAM) Devices, Products Containing the Same, and Components Thereof (II); Inv. No. 337-TA-1511 (Violation)

This supplemental complaint, filed by Netlist, Inc. in Inv. No. 337-TA-1511, supplements the June 16, 2026 complaint on the '537 and '937 patents with certified assignment records, omitted exhibits, redacted public exhibits, and added importation evidence for Samsung HBM, DDR5 RDIMMs and MRDIMMs. It amends paragraphs 77, 84, 85, 87 and 89 to allege that Samsung, Google, Super Micro, NVIDIA and Broadcom import or sell the accused products. The supplement fills gaps in the original complaint on ownership, infringement and domestic industry exhibits, and on importation, which supports institution of the investigation. It targets high-bandwidth memory and DDR5 memory modules used in AI servers and accelerators, so an exclusion order could affect downstream products of major technology companies. The document does not itself state the relief in detail. Complainant is Netlist, Inc.; the letter names Samsung Respondents, Super Micro, Google, NVIDIA and Broadcom as importers of accused products. Asserted patents are U.S. Patent Nos. 12,646,537 and 12,650,937, which issued June 2 and June 9, 2026 respectively. Accused products are Samsung HBM (HBM3, HBM3E, HBM4) and DDR5 RDIMMs and MRDIMMs, plus downstream products such as Google TPUs and Super Micro H13 and H14 servers. Certified assignment records are provided as Exs. A and B, and the omitted claim chart exhibits CC-01 to CC-60 and the complete Park Declaration (Ex. 8) are delivered. Redacted public versions of infringement charts, domestic industry charts and the Sasaki declaration are provided, and confidential treatment is requested for Exhibit CC-37C. Amended paragraphs 77.1-77.3 cite receipts for domestic purchases of Samsung DDR5 modules made after the '937 patent issued.