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

MonolithIC 3D Inc. filed a Section 337 complaint against as-yet unidentified/proposed respondents alleging infringement of unspecified asserted patents by imported NAND and DRAM memory chips and products containing them. The accused products include 3D NAND, HBM DRAM, SSDs, NAND storage products, AI-NAND, HBF, FPGA, and PIM-related memory products, with KIOXIA 3D NAND products identified as examples. The complaint targets core semiconductor memory technologies used in consumer storage, enterprise SSDs, AI systems, and advanced computing products. If instituted and successful, MonolithIC 3D would likely seek exclusionary relief barring infringing imported memory chips and downstream products from the U.S. market, potentially affecting major supply chains for NAND and DRAM products. MonolithIC 3D supplemented the complaint to clarify the categories of accused imported products under 19 C.F.R. §§ 210.10(b)(1) and 210.12(a)(12). The accused products include 3D NAND memory chips, HBM DRAM chips, SSDs, NAND storage, FPGA, AI-NAND, HBF, and PIM products and products containing them. The supplement cites Corsair packaging and KIOXIA admissions in another ITC investigation as evidence that representative KIOXIA 3D NAND products are imported into the United States.