Untitled case

Radian Memory Systems LLC, a Texas-based patent assertion entity (PAE), has filed a patent infringement lawsuit against Samsung Electronics Co., Ltd. and its subsidiary Samsung Electronics America, Inc. (collectively, "Samsung"), a global operating company specializing in electronics and technology. The plaintiff, Radian, characterizes itself as having "pioneered a new paradigm for managing flash storage media that it called Cooperative Flash Management ('CFM')" technology. The asserted patents, including U.S. Patent No. 11,347,656, generally relate to this cooperative flash management technology designed to enhance the performance and efficiency of solid-state drives (SSDs) in enterprise and data center environments. Radian alleges that Samsung's ZNS-capable SSD products, which implement functionalities similar to or disclosed in the NVMe Zoned Namespaces Command Set Specification, infringe its patents.

The case, Civil Action No. 2:24-cv-01073, was filed in the Eastern District of Texas, Marshall Division, and is presided over by District Judge Rodney Gilstrap. The Eastern District of Texas has historically been a popular venue for patent litigation due to its reputation for plaintiff-friendly procedures and accelerated trial schedules, often referred to as a "rocket docket." While the Supreme Court's TC Heartland decision in 2017 limited venue options for domestic corporations, plaintiffs have reportedly adopted strategies to maintain filings in the Eastern District of Texas, such as by targeting foreign affiliates.

This case is particularly notable due to the intervention of the U.S. Department of Justice (DOJ) Antitrust Division and the U.S. Patent and Trademark Office (USPTO), which jointly submitted a rare Statement of Interest. This statement urged the court to recognize that patent owners, including non-practicing entities like Radian, can suffer irreparable harm from continued infringement and may be entitled to injunctive relief, even at a preliminary stage, emphasizing that the inadequacy of a monetary remedy can be difficult to accurately calculate. This government backing for injunctive relief for NPEs in such a high-profile case could have significant implications for patent enforcement strategies and the valuation of patent portfolios, particularly in the competitive solid-state drive market and the broader technology industry.

Key Legal Developments in Radian Memory Systems LLC v. Samsung Electronics Co., Ltd. et al.

Case Number: 2:24-cv-01073
Court: U.S. District Court for the Eastern District of Texas
Patents at Issue: U.S. Patent No. 11,347,656 (and initially, others including 11,544,183)

This patent infringement suit, filed by Radian Memory Systems LLC against Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc., has seen several significant developments since its inception.

Filing & Initial Pleadings

• Complaint Filed: Radian Memory Systems LLC initiated the lawsuit on December 23, 2024, in the Eastern District of Texas, alleging infringement of multiple patents, including U.S. Patent No. 11,347,656 and U.S. Patent No. 11,544,183.
• Motion for Preliminary Injunction: On May 6, 2025, Radian filed a motion for a preliminary injunction, seeking to prevent Samsung from making, using, selling, offering to sell, and importing solid-state drives (SSDs) that incorporate the disputed "commands, responses, capabilities, or functionalities" related to the NVMe Zoned Namespaces Command Set Specification. Samsung opposed this motion on May 28, 2025, arguing that Radian failed to establish a likelihood of irreparable harm and that the market was moving away from the technology at issue.
• United States' Statement of Interest: On June 24, 2025, the United States (through the USPTO and DOJ) filed a Statement of Interest in the case, supporting the premise that ongoing patent infringement may justify an injunction, even for non-practicing entities, due to the difficulty in accurately calculating monetary remedies. The government's brief encouraged courts to permit injunctive relief to prevent ongoing violations of rights in unique assets.

Pre-Trial Motions and Developments

• Withdrawal of Preliminary Injunction Motion and Motion to Dismiss: Radian Memory Systems LLC subsequently withdrew its motion for a preliminary injunction and moved to dismiss its own lawsuit. The reasons for the dismissal motion are not explicitly detailed in the provided snippets but were mentioned in the context of a PTAB proceeding.
• Limited Discovery and Extension of Claim Construction Deadlines: As of January 19, 2026, Radian had pursued only limited discovery and sought to extend existing claim construction deadlines, suggesting the case had not yet reached a mature discovery or claim construction phase before the motion to dismiss.

Parallel PTAB IPR Proceedings

• IPR2025-01266: Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. filed an Inter Partes Review (IPR) petition, IPR2025-01266, challenging U.S. Patent No. 11,544,183, which was one of the patents initially asserted in the district court action. The IPR petition highlighted Radian's motion to dismiss the district court case and the withdrawal of the preliminary injunction motion as factors that could eliminate the basis for discretionary denial of the IPR under Fintiv factors, due to the absence of parallel litigation. The IPR was focused on the '183 patent, and a final written decision was projected for January 20, 2027.
• No specific IPR for 11,347,656 found: While Radian asserted multiple patents, including 11,347,656, the provided search results only explicitly mention IPR2025-01266 in relation to U.S. Patent No. 11,544,183. Therefore, no specific parallel PTAB IPR/PGR proceeding for U.S. Patent No. 11,347,656 has been identified in the provided information.

Current Posture

As of the current information, Radian Memory Systems LLC has moved to dismiss its own lawsuit in the Eastern District of Texas. The status of this dismissal motion and the ultimate disposition of the district court case are not definitively stated as a final judgment or appeal in the provided sources. The existence of the IPR for a co-asserted patent and Radian's motion to dismiss suggest a potential shift in litigation strategy.## Key Legal Developments in Radian Memory Systems LLC v. Samsung Electronics Co., Ltd. et al.

Case Number: 2:24-cv-01073
Court: U.S. District Court for the Eastern District of Texas
Patents at Issue: U.S. Patent No. 11,347,656 (among others initially, including 11,544,183)

This patent infringement suit, filed by Radian Memory Systems LLC against Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc., saw several significant developments, primarily culminating in its dismissal.

Filing & Initial Pleadings

• Complaint Filed: Radian Memory Systems LLC initiated the lawsuit on December 23, 2024, in the Eastern District of Texas. The complaint asserted infringement of multiple patents, including U.S. Patent No. 11,347,656 and U.S. Patent No. 11,544,183, related to cooperative flash management technology for solid-state drives (SSDs).
• Motion for Preliminary Injunction: On May 6, 2025, Radian filed a motion for a preliminary injunction, seeking to prevent Samsung from making, using, selling, offering to sell, and importing SSDs that allegedly infringed the asserted patents, specifically those incorporating "commands, responses, capabilities, or functionalities" disclosed in the NVMe Zoned Namespaces Command Set Specification. Samsung opposed this motion on May 28, 2025, arguing that Radian failed to establish a likelihood of irreparable harm and that the market was evolving away from the technology in question.
• United States' Statement of Interest: On June 24, 2025, the United States (through the USPTO and DOJ) filed a Statement of Interest in the case. This brief supported the position that ongoing patent infringement could warrant an injunction, even for non-practicing entities, due to the inherent difficulty in accurately calculating monetary damages for unique assets like patents.

Pre-Trial Motions and Final Disposition

• Withdrawal of Preliminary Injunction Motion: Radian Memory Systems LLC withdrew its motion for a preliminary injunction.
• Joint Motion to Dismiss: A "JOINT MOTION to Dismiss All Claims and Defenses and Joint Stipulation" was filed by Radian Memory Systems LLC on December 18, 2025. This motion to dismiss the entire case without prejudice was noted in related PTAB proceedings.
• Case Dismissed: The case was dismissed, as evidenced by references in PTAB documents discussing the impact of the district court action's dismissal on discretionary denial factors. The exact date of the court's order granting the dismissal was not explicitly found, but the joint motion was filed on December 18, 2025.

Due to the early dismissal of the case, there is no public information available regarding:

• Samsung's formal Answer or Counterclaims in the district court beyond their opposition to the preliminary injunction and their engagement in the joint dismissal.
• Claim construction (Markman) outcomes, as the case did not reach that stage.
• Significant discovery milestones beyond "limited discovery" and requests to extend deadlines.
• Trial events, verdict, or post-trial motions.
• Appeals.

Parallel PTAB IPR Proceedings

• IPR2025-01266 (U.S. Patent No. 11,544,183): Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. filed an Inter Partes Review (IPR) petition, IPR2025-01266, challenging U.S. Patent No. 11,544,183. This was one of the patents initially asserted in the district court action. The IPR petition noted Radian's motion to dismiss the district court case and the withdrawal of the preliminary injunction motion, arguing that these actions should weigh against a discretionary denial of the IPR under the Fintiv factors, as the absence of parallel litigation reduces the risk of inconsistent outcomes or duplicative efforts. As of January 19, 2026, a final written decision for this IPR was projected for January 20, 2027.
• No IPR found for U.S. Patent No. 11,347,656: A specific Inter Partes Review or Post-Grant Review proceeding for U.S. Patent No. 11,347,656 was not found in the provided search results. While Radian asserted this patent in the district court action, the IPR details located were specifically for U.S. Patent No. 11,544,183.

Counsel of Record for Plaintiff Radian Memory Systems LLC

Plaintiff Radian Memory Systems LLC in Case 2:24-cv-01073 is represented by attorneys from Caldwell Cassady & Curry PC and Miller Fair Henry PLLC. Caldwell Cassady & Curry PC appears to serve as lead counsel, while Miller Fair Henry PLLC provides local counsel support.

Here is a breakdown of the identified counsel:

Caldwell Cassady & Curry PC

• Office Location: Dallas, TX

• Attorneys:

  • Bradley W. Caldwell
    • Role: Lead Counsel
    • Firm: Caldwell Cassady & Curry PC, Dallas, TX
    • Relevant Experience: A nationally recognized trial lawyer specializing in patent infringement and complex commercial litigation, with courtroom victories totaling over $3 billion, including multiple multi-million dollar verdicts against Apple, Microsoft, Samsung, and LG. He has been named a "Titan of the Plaintiffs Bar" by Law360 twice and "Litigator of the Week" by The American Lawyer.
  • Jason D. Cassady
    • Role: Lead Counsel
    • Firm: Caldwell Cassady & Curry PC, Dallas, TX
    • Relevant Experience: A principal at the firm focusing on intellectual property and complex commercial litigation, with extensive federal trial experience in patent cases involving diverse technologies such as secure computer networking, integrated circuits, and video game controllers. He was trial counsel in a $533 million patent infringement verdict against Apple Inc. and has secured numerous "Top 100" verdicts in the U.S.
  • John Austin Curry
    • Role: Lead Counsel
    • Firm: Caldwell Cassady & Curry PC, Dallas, TX
    • Relevant Experience: A trial lawyer concentrating on patent infringement disputes and cases involving advanced technologies in electrical engineering, computer science, and medical devices. He has helped clients achieve trial verdicts totaling over $2 billion and is Board Certified in Patent Litigation by the National Board of Trial Advocacy.
  • Hamad M. Hamad
    • Role: Lead Counsel
    • Firm: Caldwell Cassady & Curry PC, Dallas, TX
    • Relevant Experience: A principal at the firm with broad experience in intellectual property disputes and complex commercial litigation, representing both plaintiffs and defendants. He was a key member of trial teams that won significant verdicts against Apple Inc. and has experience with matters before the Patent Trial and Appeal Board.
  • Adrienne R. Dellinger
    • Role: Lead Counsel
    • Firm: Caldwell Cassady & Curry PC, Dallas, TX
    • Relevant Experience: An accomplished patent litigator with expertise in technical disciplines such as telecommunications, oil & gas, and semiconductor design. She has guided clients through all stages of litigation, including a patent infringement case resulting in a jury verdict over $100 million. She previously served as a judicial clerk for Judge Rodney Gilstrap in the Eastern District of Texas.
  • Andrew T. Langford
    • Role: Counsel
    • Firm: Caldwell Cassady & Curry PC, Dallas, TX
    • Relevant Experience: Listed as an attorney for the plaintiff, specializing in intellectual property litigation.
  • Alexander J. Gras
    • Role: Counsel
    • Firm: Caldwell Cassady & Curry PC, Dallas, TX
    • Relevant Experience: A lawyer practicing intellectual property and commercial litigation.

Miller Fair Henry PLLC

• Office Location: Longview, TX

• Attorneys:

  • Andrea L. Fair
    • Role: Local Counsel
    • Firm: Miller Fair Henry PLLC, Longview, TX
    • Relevant Experience: A name partner known for her high-stakes intellectual property trial practice, frequently managing jury selection, examining witnesses, and handling arguments. She has assisted in securing over $1 billion in patent infringement verdicts, including multiple against Samsung, and has been inducted into the International Society of Barristers. She frequently serves as local counsel in the Eastern District of Texas.

Counsel of record representing the defendants, Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc., in Radian Memory Systems LLC v. Samsung Electronics Co., Ltd. et al. (2:24-cv-01073) include attorneys from Quinn Emanuel Urquhart & Sullivan LLP and local counsel from Gillam & Smith LLP.

The identified defense counsel are:

• Sean S. Pak

  • Role: Lead Counsel (inferred from firm's prominence in patent litigation and listing as primary counsel for defendants)
  • Firm: Quinn Emanuel Urquhart & Sullivan, LLP
  • Office Location: San Francisco, CA (common office for patent litigation partners at Quinn Emanuel, though specific location for this case should be verified if possible through a firm profile search)
  • Experience Note: Mr. Pak is a partner at Quinn Emanuel and frequently represents major technology companies in high-stakes patent disputes, particularly in the Eastern District of Texas.

• Arian Joseph Koochesfahani

  • Role: Counsel (appeared Pro Hac Vice)
  • Firm: Quinn Emanuel Urquhart & Sullivan, LLP
  • Office Location: Likely a Quinn Emanuel office (e.g., San Francisco, CA or Washington D.C., as is common for attorneys appearing pro hac vice from national firms).
  • Experience Note: As an attorney at Quinn Emanuel, Mr. Koochesfahani likely has experience in complex patent litigation, often supporting lead partners on significant cases.

• Melissa R. Smith

  • Role: Local Counsel
  • Firm: Gillam & Smith LLP
  • Office Location: Marshall, TX (Eastern District of Texas is her primary practice location)
  • Experience Note: Ms. Smith is a highly experienced trial attorney who regularly serves as local counsel in patent infringement cases in the Eastern District of Texas. She is known for her extensive knowledge of local court rules and procedures.