Netlist, Inc. v. Micron Technology, Inc.

CourtDistrict Court, E.D. Texas
DecidedMarch 27, 2025
Docket2:23-cv-00628
StatusUnknown

This text of Netlist, Inc. v. Micron Technology, Inc. (Netlist, Inc. v. Micron Technology, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Netlist, Inc. v. Micron Technology, Inc., (E.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

NETLIST, INC., § § Plaintiff, § § v. § CIVIL ACTION NO. 2:23-CV-00628-JRG § MICRON TECHNOLOGY, INC., § MICRON SEMICONDUCTOR § PRODUCTS, INC., MICRON § TECHNOLOGY TEXAS LLC, § § Defendants. §

MEMORANDUM OPINION AND ORDER Before the Court is the Motion to Stay (the “Motion”) filed by Defendants Micron Technology, Inc., Micron Semiconductor Products, Inc., and Micron Technology Texas LLC (collectively, “Micron” or “Defendants”). (Dkt. No. 46). In the Motion, Micron asks the Court to exercise its discretion to stay this declaratory judgment action pending resolution of its Idaho state-court actions. (Id. at 1.) Having considered the Motion, and for the reasons set forth herein, the Court finds that the Motion should be GRANTED AS MODIFIED. I. PROCEDURAL HISTORY On April 28, 2021, Plaintiff Netlist, Inc. (“Plaintiff” or “Netlist”) brought a patent infringement action against Micron in the Western District of Texas, asserting U.S. Patent No. 8,301,833 (the “’833 Patent” or “W.D. Texas Patent”). (Dkt. No. 1 at ¶ 20; see also Netlist, Inc. v. Micron Tech., Inc. et. al., Case No. 1:22-cv-134-DAE (W.D. Tex. Apr. 28. 2021).)1

1 Before Netlist filed this action, the Patent Trial and Appeal Board (“PTAB”) issued its Final Written Decision determining that claims 1-15 of U.S. Patent No. 8,874,831 (the “’831 Patent”) were unpatentable. (Dkt. No. 46-2 at ¶ 23; SK Hynix Inc., et al. v. Netlist, Inc., IPR2017-00692, Paper No. 25 (P.T.A.B. July 5, 2018).) Micron contends that claim 15 of the ’833 Patent is “virtually identical” to claim 15 of the ’831 Patent. (Dkt. No. 46-2 at ¶ 24.) Despite the PTAB decision being non-final, Micron contends that Netlist acted with bad faith because it knew or reasonably should have known that its lawsuit over the ’833 Patent was meritless. (Id. at ¶ 39.) Netlist brought two additional patent infringement actions against Micron in the Eastern District of Texas. (Dkt. 1 at ¶¶ 2, 21.) The first, Netlist, Inc. v. Micron Tech., Inc. et. al., (“Micron I”) was filed on June 10, 2022. (Case No. 2:22-cv-203, Dkt. 1 (E.D. Tex.)) In Micron I, Netlist asserted U.S. Patent Nos. 10,860,506 (the “’506 patent”); 10,949,339 (the “’339 Patent”);

11,016,918 (the “’918 Patent”); 11,232,054 (the “’054 patent); 8,787,060 (the ’”060 Patent”); and 9,318,160 (the “’160 Patent”) (the “Micron I Patents”). (Id. at 2.)2 The second case in the Eastern District of Texas, Netlist, Inc. v. Micron Tech., Inc. et. al., (“Micron II”), was filed on August 1, 2022. (Case No. 2:22-cv-294; Dkt. 1). In Micron II, Netlist asserted U.S. Patent Nos. 7,619,912 (the “’912 Patent”); 11,093,417 (the “’417 Patent”); and 9,858,215 (the “’215 Patent”) (the “Micron II Patents”) (collectively, with the Micron I Patents, the “E.D. Texas Patents”). (Dkt. No. 11 at ¶ 2.) On August 28, 2023, the PTAB issued a Final Written Decision finding that all challenged claims of the ’833 Patent—the W.D. Texas Patent—were unpatentable. (Final Written Decision in IPR2022-00418; Dkt. No. 46 at 4.) Subsequently, during the fall of 2023, the PTAB issued Final

Written Decisions finding that all challenged claims of the ’339 Patent, the ’506 Patent, the ’054 Patent, and the ’918 Patent—four of the nine E.D. Texas Patents—were unpatentable. (Final Written Decisions in IPR2022-00639, IPR2022-00711, IPR2022-00999, IPR2022-00996; Dkt. No. 46 at 4.)3

2 Before Netlist filed its Complaint in Micron I, Samsung Electronics Co., Ltd. (“Samsung”) filed petitions at the PTAB challenging the validity of all claims of the ’054 and ’918 Patents. (See Dkt. No. 46-5 at ¶ 20; see IPR Petitions in IPR2022-00999, IPR2022-00996.) On this basis, Micron contends that Netlist acted with subjective bad faith because it knew or reasonably should have known that Micron I was meritless. (Id. at ¶ 30.)

3 Before the PTAB determined that any of these patents were unpatentable, a jury returned a unanimous verdict in Netlist, Inc. v. Samsung Electronics Co., Ltd., Case No. 2:21-cv-463 (E.D. Tex.), on April 21, 2023, finding that Samsung infringed at least one of the claims of the ’339, the ’918, the ’054, the ’060, and the ’160 Patents, that none of the asserted claims were invalid, that Samsung’s infringement was willful, and that Samsung owed Netlist approximately $300 million for that infringement. (Case No. 2:21-cv-463, Dkt. No. 551.) Samsung has appealed that decision to the United States Court of Appeals for the Federal Circuit. (See Netlist, Inc. v. Samsung Electronics Co., Ltd., Case No. 24-2203 (Fed. Cir. Aug. 13, 2024.) On December 11, 2023, only days after the PTAB issued its most recent Final Written Decision, Micron sued Netlist in Idaho state court (the “First Idaho State Court Action”), alleging that Netlist violated the Idaho Bad Faith Assertions of Patent Infringement Act (Idaho Code § 48-1703) (the “Idaho Act”). (Dkt. No. 46 at 4; Dkt. No. 1 at ¶ 5.)

Under the Idaho Act, “[i]t is unlawful for a person to make a bad faith assertion of patent infringement in a demand letter, a complaint or any other communication.” Idaho Code § 48-1703(1). The Idaho Act allows courts to consider several factors as “evidence that a person has made a bad faith assertion of patent infringement,” including the following factors: (f) The person asserting a claim or allegation of patent infringement acts in subjective bad faith, or a reasonable actor in the person’s position would know or reasonably should know that such assertion is meritless. (h) The person or its subsidiaries or affiliates have previously filed or threatened to file one (1) or more lawsuits alleging patent infringement based on the same or similar claim, the person attempted to enforce the claim of patent infringement in litigation and a court found the claim to be meritless. (i) Any other factor the court finds relevant. Id. §48-1703(2).4 In the First Idaho State Court Action, Micron contends that Netlist violated the Idaho Act by asserting the ’833 Patent—the W.D. Texas Patent—when it knew (or should have known) that it was invalid. (Dkt. No. 46 at 1, 4; Dkt. No. 46-2 at ¶ 38.) A jury trial in this case is scheduled to begin on October 27, 2025. (Dkt. No. 46 at 4.) “Fearing more suits would follow,” Netlist brought this action on December 22, 2023, seeking declaratory judgment under 28 U.S.C. §§ 2201-2202 that its lawsuits against Micron in

4 The Idaho Act also provides that “[a] court may consider the following factors as evidence that a person has not made a bad faith assertion of patent infringement: (a) The person engages in a good faith effort to establish that the target has infringed the patent and to negotiate an appropriate remedy. (b) The person makes a substantial investment in the use of the patent or in the production or sale of a product or item covered by the patent. (c) The person has: (i) Demonstrated good faith in previous efforts to enforce the patent, or a substantially similar patent; or (ii) Successfully enforced the patent, or a substantially similar patent, through litigation. (d) Any other factor the court finds relevant.” The Court notes that Netlist has successfully enforced several of these patents through litigation. See, e.g., supra note 3; see also infra at 5. this district for the nine asserted E.D. Texas Patents do not violate the Idaho Act. (Dkt. No. 1 at ¶¶ 6, 15, 22; Dkt. No. 46 at 4-5; Dkt. No. 48 at 3.) A jury trial in this case is scheduled to begin on July 7, 2025, before the First Idaho State Court Action. (See Dkt. No.

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Netlist, Inc. v. Micron Technology, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/netlist-inc-v-micron-technology-inc-txed-2025.