Unified Patents, LLC v. Radian Memory Systems LLC

This case involves an Inter Partes Review (IPR) initiated by Unified Patents, LLC challenging the patentability of U.S. Patent No. 11,740,801, owned by Radian Memory Systems LLC. The proceeding at the Patent Trial and Appeal Board (PTAB) has concluded with a settlement between the parties.

Unified Patents, LLC is a member-based organization focused on deterring "frivolous patent litigation" and reducing assertions by Non-Practicing Entities (NPEs) by directly challenging the validity of their patents through IPRs. They operate in various technology sectors and emphasize a deterrence model that does not involve paying money to NPEs. Radian Memory Systems LLC, the patent owner, was originally an operating company that developed "Cooperative Flash Management" (CFM) technology for solid-state drives (SSDs). However, the specific entity involved in this IPR is identified as a Texas-based Patent Assertion Entity (PAE) tied to Fortress Investment Group LLC, having acquired a portfolio of over 80 U.S. patents from the original Radian Memory Systems Inc. in May 2024. This structure indicates that Radian Memory Systems LLC is primarily engaged in patent monetization rather than product sales.

The patent at issue, U.S. Patent No. 11,740,801, is titled "Storage systems and methods using host provided logical-to-physical mapping tables for management of non-volatile storage." It generally describes systems and methods for managing non-volatile memory, such as flash memory in SSDs, through a host-directed approach to logical-to-physical mapping. While there isn't an "accused product" in an IPR, this IPR (and several others against Radian's patents) arose in the context of Radian Memory Systems LLC asserting this and related patents in district court litigation, notably against Samsung, over solid-state drives supporting "Zoned Namespaces" (ZNS) technology. Radian alleged that Samsung incorporated features of its Cooperative Flash Management (CFM) technology into the NVMe's ZNS standard after Radian refused to join the NVMe consortium, which would have required royalty-free licensing.

This IPR was filed at the Patent Trial and Appeal Board (PTAB), an administrative body within the U.S. Patent and Trademark Office, where the patentability of claims can be challenged based on prior art. The IPR was part of a cluster of challenges against Radian's patents, all of which were resolved through joint motions to terminate due to settlement, as overseen by a panel including Acting Chief Administrative Patent Judge Kalyan K. Deshpande. The case is notable due to Radian Memory Systems LLC's status as a Fortress-backed NPE actively asserting its portfolio in the critical data center memory market. The IPRs by Unified Patents represent a defensive strategy against such assertions. Furthermore, the underlying district court litigation involving Samsung gained significant attention when the U.S. government, through the Department of Justice and USPTO, filed a Statement of Interest supporting Radian's request for a preliminary injunction, arguing for the availability of injunctive relief for patent owners, including NPEs, when monetary damages are difficult to calculate. Radian later withdrew its preliminary injunction request, and Radian and Samsung ultimately settled their patent infringement claims related to SSDs with zoned namespaces.

The case in question, IPR2025-01350, styled as Unified Patents, LLC v. Radian Memory Systems LLC in the prompt, is an Inter Partes Review (IPR) proceeding before the Patent Trial and Appeal Board (PTAB), not a district court patent infringement litigation. While Unified Patents, LLC is an organization known for challenging patents through IPRs, for IPR2025-01350 specifically, the Petitioner was Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.. Radian Memory Systems LLC was the Patent Owner. This IPR was closely related to an underlying patent infringement lawsuit filed by Radian Memory Systems LLC against Samsung Electronics Co. in district court.

Here are the key legal developments and outcome:

• Parallel District Court Infringement Litigation (Radian Memory Systems LLC v. Samsung Electronics Co., Ltd., E.D. Tex., 2:24-cv-01073):

  • 2024-12-23: Radian Memory Systems LLC filed a patent infringement complaint against Samsung Electronics Co., Ltd. in the U.S. District Court for the Eastern District of Texas. The lawsuit involved patents related to "Symphonic Cooperative Flash Management" technology for solid-state drives.
  • 2025-05-01: District Judge Rodney Gilstrap signed an order granting modified motions for leave to file excess pages concerning a motion for preliminary injunction.
  • 2025-06-24: The United States government, through the Department of Justice Antitrust Division and the U.S. Patent and Trademark Office (USPTO), filed a rare Statement of Interest in the district court case. The government supported Radian's motion for a preliminary injunction, arguing that irreparable harm is often present in patent infringement cases, even for non-practicing entities (NPEs) like Radian.
  • Status: The district court case (2:24-cv-01073) is listed as "Closed" as of May 28, 2025. This closure likely occurred in conjunction with or shortly after the settlement of the related IPRs.

• IPR Proceeding (IPR2025-01350, Samsung Electronics Co., Ltd. et al. v. Radian Memory Systems LLC):

  • 2025-07-28: Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. filed the IPR petition (IPR2025-01350) challenging U.S. Patent No. 11,740,801, owned by Radian Memory Systems LLC. This was one of several IPR petitions filed by Samsung against Radian Memory Systems LLC's patents around this period.
  • 2025-12-30: The Patent Trial and Appeal Board (PTAB) granted a Joint Motion to Terminate due to settlement between Samsung and Radian Memory Systems LLC. This termination order applied to IPR2025-01350 and several other related IPRs challenging Radian's patents (e.g., IPR2025-01266, IPR2025-01289, IPR2025-01321, IPR2025-01376, IPR2025-01377, and IPR2025-01378). The parties filed a confidential settlement agreement and a binding term sheet. The IPR was terminated prior to a full decision on institution of trial.

Outcome: Both the IPR proceeding (IPR2025-01350) and the parallel district court litigation (2:24-cv-01073) concluded due to a settlement between Radian Memory Systems LLC and Samsung Electronics Co., Ltd. The PTAB formally terminated the IPR on December 30, 2025, based on this settlement.

Unified Patents, LLC is represented by the following counsel from Quinn Emanuel Urquhart & Sullivan, LLP in IPR2025-01350:

• James M. Glass

  • Role: Lead Counsel (Chair of Quinn Emanuel's Post-Grant patent practice)
  • Firm & Office: Quinn Emanuel Urquhart & Sullivan, LLP, New York, NY
  • Experience: Mr. Glass has been lead counsel in over 500 post-grant proceedings and is consistently ranked among the top-performing and most active attorneys at the PTAB. He also has extensive experience arguing at the Court of Appeals for the Federal Circuit and in district court patent infringement cases.

• John T. McKee

  • Role: Counsel (Partner)
  • Firm & Office: Quinn Emanuel Urquhart & Sullivan, LLP, New York, NY
  • Experience: Mr. McKee focuses on high-stakes intellectual property disputes, with multiple trial successes in district courts and the ITC. He is recognized as a top practitioner at the PTAB, representing petitioners, and has argued at the Federal Circuit.

• Gregory M. Miraglia

  • Role: Counsel (Associate)
  • Firm & Office: Quinn Emanuel Urquhart & Sullivan, LLP, Austin, TX
  • Experience: Mr. Miraglia's practice focuses on patent and trade secret litigation.

• Nima Hefazi

  • Role: Counsel (Attorney)
  • Firm & Office: Quinn Emanuel Urquhart & Sullivan, LLP, Los Angeles, CA
  • Experience: Mr. Hefazi has represented clients in various industries, including computer networking, software, semiconductors, and medical devices, with experience in all phases of litigation and before the USPTO.

• Luiz Miranda

  • Role: Counsel (Associate)
  • Firm & Office: Quinn Emanuel Urquhart & Sullivan, LLP, Chicago, IL
  • Experience: Mr. Miranda is a registered patent attorney focusing on complex intellectual property disputes in district courts, the ITC, and the PTAB. He previously worked for thirteen years as a software developer and design engineer.

No specific Unified Patents in-house counsel were listed in the available records as counsel of record for this particular IPR.

In the Inter Partes Review (IPR) case IPR2025-01350, Unified Patents, LLC v. Radian Memory Systems LLC, the defendant, Radian Memory Systems LLC, was represented by counsel from Lowenstein & Weatherwax LLP and Caldwell Cassady Curry PC.

Here is a breakdown of the identified counsel:

1. Kenneth Weatherwax

• Role: Lead Counsel
• Firm: Lowenstein & Weatherwax LLP
• Office Location: Not explicitly stated in the search results for this case, but Lowenstein & Weatherwax LLP is based in Los Angeles, California.
• Relevant Experience: Kenneth Weatherwax is a registered patent practitioner.

2. Parham Hendifar

• Role: Counsel
• Firm: Lowenstein & Weatherwax LLP
• Office Location: Not explicitly stated in the search results for this case, but Lowenstein & Weatherwax LLP is based in Los Angeles, California.
• Relevant Experience: Not detailed in the provided search results, but generally practices in patent litigation.

3. Nathan Lowenstein

• Role: Counsel
• Firm: Lowenstein & Weatherwax LLP
• Office Location: Not explicitly stated in the search results for this case, but Lowenstein & Weatherwax LLP is based in Los Angeles, California.
• Relevant Experience: Not detailed in the provided search results, but generally practices in patent litigation.

4. Colette Woo

• Role: Counsel
• Firm: Lowenstein & Weatherwax LLP
• Office Location: Not explicitly stated in the search results for this case, but Lowenstein & Weatherwax LLP is based in Los Angeles, California.
• Relevant Experience: Not detailed in the provided search results, but generally practices in patent litigation.

5. Dennis J. Courtney

• Role: Backup Counsel, designated as a provisionally recognized PTAB attorney.
• Firm: Lowenstein & Weatherwax LLP
• Office Location: Not explicitly stated in the search results for this case, but Lowenstein & Weatherwax LLP is based in Los Angeles, California.
• Relevant Experience: Mr. Courtney is a partner at Lowenstein & Weatherwax LLP and an experienced litigator, with the majority of his practice consisting of patent litigation and other patent-related matters such as PTAB litigations and matters in federal district and appellate courts.

6. Xu Zhou

• Role: Counsel
• Firm: Caldwell Cassady Curry PC
• Office Location: Not explicitly stated in the search results, but Caldwell Cassady Curry PC is based in Dallas, Texas.
• Relevant Experience: Not detailed in the provided search results, but typically involved in patent litigation. Austin Curry, a lawyer at Caldwell Cassady Curry, has represented Radian Memory Systems in other related patent infringement cases against Samsung, making extensive arguments grounded in 18th-century English Court of Chancery precedent regarding injunctive relief for non-practicing entities.