Litigation
Untitled case
Active litigation2:24-cv-01073
Patents at issue (1)
Summary
An active patent infringement litigation case concerning US patent 11740801 filed in the Texas Eastern District Court.
Case overview & background
Plain-language overview of the case: parties, accused product, patents at issue, and why the suit matters.
This patent infringement litigation, Radian Memory Systems LLC v. Samsung Electronics Co., Ltd. et al. (Case No. 2:24-cv-01073), is actively proceeding in the U.S. District Court for the Eastern District of Texas, Marshall Division, before District Judge Rodney Gilstrap. The plaintiff, Radian Memory Systems LLC, is a patent assertion entity (PAE) linked to Fortress Investment Group LLC, specializing in software-defined flash technology designed to enhance data storage performance and efficiency. The defendants, Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc., are global technology leaders, particularly prominent in consumer electronics, semiconductors, and mobile communications. Radian Memory Systems alleges that Samsung's solid-state drives (SSDs) and related products supporting Zoned Namespaces (ZNS) technology infringe its patents. These accused products allegedly incorporate features of Radian's "Cooperative Flash Management" (CFM) technology, which aims to improve the efficiency and utilization of nonvolatile memory in data center environments by redistributing flash management responsibilities between the host system and the SSD.
Among the asserted patents, U.S. Patent 11,740,801 is specifically at issue. Titled "Cooperative flash management of storage device subdivisions," this patent describes storage systems and methods for managing data within nonvolatile memory, such as flash, using techniques for data placement and migration based on individual data metrics (like "hot/cold" status or age) and wear metrics of memory locations. The technology can be implemented by a host, a memory controller, or a cooperative scheme involving both, aiming to improve the efficient integration and utilization of nonvolatile memory in various storage system architectures. The complaint filed by Radian asserts a total of seven memory technology patents.
The case was filed on December 23, 2024, in the Eastern District of Texas, a venue widely recognized as a "patent litigation capital" and a plaintiff-friendly forum known for its experienced judges, local patent rules, expedited trial timelines, and a history of favorable jury outcomes for patent holders. This litigation gained significant notability due to the rare joint intervention by the U.S. Department of Justice (DOJ) Antitrust Division and the U.S. Patent and Trademark Office (USPTO). In a Statement of Interest filed in June 2025, the government agencies supported Radian's motion for a preliminary injunction, arguing that patent owners, including non-practicing entities, can suffer irreparable harm from ongoing infringement and may be entitled to injunctive relief, directly challenging the notion that monetary damages alone are sufficient for NPEs. Radian alleges that Samsung and other industry players incorporated its patented technology into the NVMe Zoned Namespaces (ZNS) standard after Radian declined to join the NVMe consortium due to its royalty-free licensing requirements.
Key legal developments & outcome
Major rulings, motions, claim construction, settlements, and the present posture or final disposition.
The patent infringement litigation case Radian Memory Systems LLC v. Samsung Electronics Co., Ltd. et al. (Case No. 2:24-cv-01073) was filed in the Eastern District of Texas and involved US Patent 11740801, among others. The case has seen several significant developments, including a settlement.
Key Legal Developments and Outcome:
1. Filing & Initial Pleadings:
- Complaint Filed: Radian Memory Systems LLC filed its complaint for patent infringement against Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. on December 23, 2024. The complaint alleged infringement of seven patents, including U.S. Patent No. 11,740,801, related to "Cooperative Flash Management" (CFM) technology for solid-state drives (SSDs).
2. Pre-trial Motions of Substance:
- Motion for Preliminary Injunction: In April 2025, Radian moved for a preliminary injunction against Samsung. Radian argued that it suffered irreparable harm from ongoing infringement, a claim that was supported by the U.S. Government.
- Statement of Interest by the U.S. Government: On June 24, 2025, the U.S. Department of Justice (DOJ) Antitrust Division and the U.S. Patent and Trademark Office (USPTO) jointly filed a Statement of Interest in the case. The government 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. This intervention supported Radian's preliminary injunction motion and addressed concerns about "efficient infringement."
- Withdrawal of Preliminary Injunction Motion: Following the DOJ-USPTO intervention, Radian withdrew its motion for a preliminary injunction.
3. Claim Construction (Markman):
- A Markman hearing was scheduled for February 24, 2026.
4. Parallel PTAB IPR Proceedings:
- Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. filed multiple Inter Partes Review (IPR) petitions against Radian Memory Systems, LLC's patents. For instance, IPR2025-01266, filed on January 19, 2026, concerned U.S. Patent No. 11,544,183, which was one of the patents asserted in the district court action.
- The IPR filing highlighted that the district court action also asserted U.S. Patent Nos. 11,307,995; 11,347,656; 22,347,657; 11,544,183; 11,681,614; 11,709,772; and 11,740,801.
- Petitioners in the IPRs intended to move to stay the district court litigation after institution of the IPRs.
5. Settlement & Final Disposition:
- On December 30, 2025, Radian Memory Systems and Samsung Electronics filed a Joint Motion to Terminate their Inter Partes Reviews (IPRs) on account of a settlement. The settlement between Radian and Samsung was reached approximately six months after the DOJ-USPTO Statement of Interest.
- The exact terms of the settlement are not publicly available, but the joint motion to terminate the IPRs indicates a resolution of the dispute.
Summary of Chronological Developments:
- 2024-12-23: Radian Memory Systems LLC filed a patent infringement complaint against Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. in the Eastern District of Texas, asserting U.S. Patent 11740801 and other related patents.
- 2025-04: Radian Memory Systems LLC filed a motion for a preliminary injunction against Samsung.
- 2025-06-24: The U.S. Department of Justice (DOJ) Antitrust Division and the U.S. Patent and Trademark Office (USPTO) jointly filed a Statement of Interest supporting Radian's preliminary injunction motion.
- 2025 (after June 24): Radian Memory Systems LLC withdrew its motion for a preliminary injunction.
- 2025-12-30: Radian Memory Systems and Samsung Electronics filed a Joint Motion to Terminate their IPRs, indicating a settlement of the litigation.
- 2026-01-19: Samsung filed an IPR petition (IPR2025-01266) against one of the asserted patents (U.S. Patent No. 11,544,183), mentioning the district court action and its asserted patents, including 11740801.
- 2026-02-24: A Markman hearing was scheduled. (Note: Given the settlement in December 2025, it is highly probable this Markman hearing did not proceed as scheduled for this specific case, though the scheduling itself is a development).
The final disposition of the district court case appears to be a settlement between the parties, leading to the termination of the parallel IPR proceedings.
Plaintiff representatives
Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- Miller Fair Henry
- Andrea L. Fair · Attorney for Plaintiff
- Claire Abernathy Henry · Attorney for Plaintiff
- Brett Miller · Attorney for Plaintiff
- T. John Ward · Of Counsel
- Charles Everingham IV · Of Counsel
- Caldwell Cassady Curry
- Bradley W. Caldwell · Attorney for Plaintiff
- John A. Curry · Attorney for Plaintiff
- Jason D. Cassady · Attorney for Plaintiff
- Hamad M. Hamad · Attorney for Plaintiff
- Andrew T. Langford · Attorney for Plaintiff
- Adrienne R. Dellinger · Attorney for Plaintiff
- Alexander J. Gras · Attorney for Plaintiff
The plaintiff, Radian Memory Systems LLC, in case 2:24-cv-01073, is represented by counsel from Miller Fair Henry PLLC and Caldwell Cassady Curry.
Here is the identified counsel of record for the plaintiff:
Miller Fair Henry PLLC
Andrea L. Fair
- Role: Attorney for Plaintiff (likely lead counsel or key counsel, given her experience).
- Firm & Office Location: Miller Fair Henry PLLC, Longview, Texas.
- Relevant Patent Litigation Experience: Recognized for excellence in intellectual property litigation, Ms. Fair secured $847 million and $122 million jury verdicts in patent infringement cases in 2024. She was also a finalist for Intellectual Property Attorney of the Year by American Lawyer Media and Law.com. Previously with Ward, Smith & Hill, PLLC, which was noted for understanding the Eastern District of Texas judges' decision-making mindset.
Claire Abernathy Henry
- Role: Attorney for Plaintiff (name partner).
- Firm & Office Location: Miller Fair Henry PLLC, Longview, Texas.
- Relevant Patent Litigation Experience: Represents plaintiffs and defendants in commercial disputes, securities litigation, False Claims Act cases, antitrust litigation, and high-stakes patent litigation matters in the Eastern and Western Districts of Texas.
Brett Miller
- Role: Attorney for Plaintiff (name partner).
- Firm & Office Location: Miller Fair Henry PLLC, Longview, Texas.
- Relevant Patent Litigation Experience: Became a name partner in Miller Fair Henry PLLC, succeeding Ward, Smith & Hill, PLLC.
T. John Ward
- Role: Of Counsel.
- Firm & Office Location: Miller Fair Henry PLLC, Longview, Texas.
- Relevant Patent Litigation Experience: Former United States District Judge for the Eastern District of Texas for 12 years, where he presided over one of the heaviest intellectual property dockets in the country, conducted over 150 jury trials, presided over hundreds of patent cases, and held over 150 claim construction hearings. His current practice focuses on patent and other complex commercial cases.
Charles Everingham IV
- Role: Of Counsel.
- Firm & Office Location: Miller Fair Henry PLLC, Longview, Texas.
- Relevant Patent Litigation Experience: Former magistrate judge.
Caldwell Cassady Curry
Bradley W. Caldwell
- Role: Attorney for Plaintiff.
- Firm & Office Location: Caldwell Cassady Curry. Specific office location not immediately available but the firm appears to be based in Dallas, TX.
- Relevant Patent Litigation Experience: Caldwell Cassady Curry is recognized for its patent litigation work.
John A. Curry
- Role: Attorney for Plaintiff.
- Firm & Office Location: Caldwell Cassady Curry. Specific office location not immediately available but the firm appears to be based in Dallas, TX.
- Relevant Patent Litigation Experience: Caldwell Cassady Curry is recognized for its patent litigation work.
Jason D. Cassady
- Role: Attorney for Plaintiff.
- Firm & Office Location: Caldwell Cassady Curry. Specific office location not immediately available but the firm appears to be based in Dallas, TX.
- Relevant Patent Litigation Experience: Caldwell Cassady Curry is recognized for its patent litigation work.
Hamad M. Hamad
- Role: Attorney for Plaintiff.
- Firm & Office Location: Caldwell Cassady Curry. Specific office location not immediately available but the firm appears to be based in Dallas, TX.
- Relevant Patent Litigation Experience: Caldwell Cassady Curry is recognized for its patent litigation work.
Andrew T. Langford
- Role: Attorney for Plaintiff.
- Firm & Office Location: Caldwell Cassady Curry. Specific office location not immediately available but the firm appears to be based in Dallas, TX.
- Relevant Patent Litigation Experience: Caldwell Cassady Curry is recognized for its patent litigation work.
Adrienne R. Dellinger
- Role: Attorney for Plaintiff.
- Firm & Office Location: Caldwell Cassady Curry. Specific office location not immediately available but the firm appears to be based in Dallas, TX.
- Relevant Patent Litigation Experience: Caldwell Cassady Curry is recognized for its patent litigation work.
Alexander J. Gras
- Role: Attorney for Plaintiff.
- Firm & Office Location: Caldwell Cassady Curry. Specific office location not immediately available but the firm appears to be based in Dallas, TX.
- Relevant Patent Litigation Experience: Caldwell Cassady Curry is recognized for its patent litigation work.
Defendant representatives
Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- Gillam & Smith
- Melissa R. Smith · Local Counsel
- Quinn Emanuel Urquhart & Sullivan
- Sean S. Pak · Lead Counsel
- Arian Joseph Koochesfahani · Lead Counsel
In the patent infringement case Radian Memory Systems LLC v. Samsung Electronics Co., Ltd., and Samsung Electronics America, Inc. (Case No. 2:24-cv-01073) in the Eastern District of Texas, the following attorneys represent the defendants, Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.:
Melissa R. Smith
- Role: Local Counsel
- Firm: Gillam & Smith LP, Tyler and Marshall, Texas
- Experience: Ms. Smith is a partner at a Marshall-based litigation boutique that frequently serves as local or trial counsel in intellectual property disputes in Texas federal courts, representing both plaintiffs and defendants.
Sean S. Pak
- Role: Lead Counsel
- Firm: Quinn Emanuel Urquhart & Sullivan, LLP (office location likely in California, given general firm profile for patent litigation, though not explicitly stated in snippets)
- Experience: Mr. Pak is identified as counsel for Samsung, a firm frequently involved in significant patent litigation. Quinn Emanuel is a prominent firm in high-stakes intellectual property disputes.
Arian Joseph Koochesfahani
- Role: Lead Counsel (appeared pro hac vice)
- Firm: Quinn Emanuel Urquhart & Sullivan, LLP (office location likely in California, given general firm profile for patent litigation, though not explicitly stated in snippets)
- Experience: Mr. Koochesfahani has appeared for all defendants and is listed alongside Sean Pak for Quinn Emanuel, a firm with extensive experience in patent infringement cases.