Unified Patents v. Radian Memory Systems LLC

Unified Patents, as Petitioner, initiated an Inter Partes Review (IPR2025-01377) against Radian Memory Systems LLC, the Patent Owner of US11347656. Unified Patents is a member-based organization focused on deterring "patent trolls" and non-practicing entities (NPEs) by challenging the validity of patents, often through IPRs. Radian Memory Systems LLC, while also developing flash memory products, has been characterized in related litigation as a plaintiff tied to Fortress Investment Group LLC, a firm often associated with patent assertion entities, and has been identified as an NPE in other contexts.

The patent at issue, US11347656, generally relates to memory technologies, specifically an innovative approach to managing flash solid-state drives (SSDs) for improved performance and cost efficiencies, referred to as Cooperative Flash Management (CFM) or Symphonic technology. While this IPR directly challenged the validity of the patent, the underlying context includes Radian's broader patent assertion activities. For instance, Radian Memory Systems LLC filed a patent infringement lawsuit against Samsung (2:24-cv-01073) in the Eastern District of Texas, asserting seven patents, including US11347656. In that case, Radian alleged that Samsung, a member of the NVM Express (NVMe) standards organization, infringed its patented technology related to Zoned Namespaces (ZNS) after Radian refused to join NVMe due to royalty-free licensing requirements. Samsung and Radian Memory Systems LLC subsequently settled their patent infringement dispute.

The procedural posture of IPR2025-01377 before the Patent Trial and Appeal Board (PTAB) is significant because IPRs provide an administrative alternative to district court litigation for challenging patent validity. The PTAB, part of the USPTO, conducts these reviews to determine if a patent claim is unpatentable based on prior art. The case is notable as it exemplifies Unified Patents' strategy of targeting patents held by alleged NPEs to reduce the burden of what it considers "frivolous" patent litigation. The settlement of this IPR, especially in conjunction with the settlement of Radian's parallel district court case against Samsung, highlights the interconnected strategies often employed by and against patent assertion entities.

The Inter Partes Review (IPR) case IPR2025-01377, styled Unified Patents v. Radian Memory Systems LLC in the prompt, was formally initiated by Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. as Petitioners against Radian Memory Systems LLC as the Patent Owner. The challenged patent was U.S. Patent No. 11,347,656. The case concluded with a settlement prior to the institution of trial.

Here are the key legal developments and outcome:

• Parallel District Court Litigation (Pre-IPR Filing Context): Prior to the IPR filing, Radian Memory Systems LLC initiated a patent infringement lawsuit against Samsung Electronics Co., Ltd. in the U.S. District Court for the Eastern District of Texas (Civil Action No. 2:24-cv-1073). In this litigation, Radian sought a preliminary injunction, asserting irreparable harm from alleged infringement of its flash solid-state drive (SSD) technology. On June 24, 2025, the U.S. Department of Justice and the U.S. Patent and Trademark Office filed a Statement of Interest in this district court case, advocating that the court consider evidence of irreparable harm, including the difficulty of calculating monetary damages, when assessing preliminary injunction requests for patent owners. This parallel litigation likely provided a significant backdrop to the subsequent IPR proceedings and their eventual settlement.

• IPR Petition Filing (2025-08-05): Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. filed the Inter Partes Review petition, IPR2025-01377, challenging claims of U.S. Patent No. 11,347,656. The petition date was August 5, 2025.

• Settlement and Termination (2025-12-30): Before the Patent Trial and Appeal Board (PTAB) reached a decision on whether to institute a trial in IPR2025-01377, the parties—Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. (Petitioners), and Radian Memory Systems LLC (Patent Owner)—reached a settlement. A Joint Motion to Terminate due to settlement was filed. On December 30, 2025, the PTAB granted this Joint Motion to Terminate, thereby ending the IPR proceeding.

• Broader Settlement: This settlement was part of a broader resolution that encompassed several other IPRs filed by Samsung against Radian Memory Systems LLC, all of which were terminated on the same day due to settlement. These included IPR2025-01266, IPR2025-01289, IPR2025-01321, IPR2025-01350, IPR2025-01376, and IPR2025-01378.

The outcome of IPR2025-01377 was a settlement and termination prior to institution of trial, effectively concluding the PTAB challenge to U.S. Patent No. 11,347,656 without a merits decision from the Board.

Unified Patents, as an organization, generally acts as a "deterrence entity" and not a law firm, and therefore does not have an attorney-client relationship with its members. Its goal is to deter "frivolous patent litigation" by non-practicing entities (NPEs) through various actions, including filing Inter Partes Reviews (IPRs) against patents it believes are invalid.

While Unified Patents itself is the Petitioner in IPR2025-01377, the IPR was settled along with several other related IPRs against Radian Memory Systems LLC. The settlement order for these IPRs, including IPR2025-01377, lists the attorneys representing the Petitioner (which in this context refers to Unified Patents).

The counsel of record representing Unified Patents in IPR2025-01377 were:

• James Glass
  • Role: Attorney for Petitioner
  • Firm: Quinn Emanuel Urquhart & Sullivan, LLP
  • Experience Note: Quinn Emanuel is a prominent law firm known for its extensive intellectual property and patent litigation practice.
• John McKee
  • Role: Attorney for Petitioner
  • Firm: Quinn Emanuel Urquhart & Sullivan, LLP
  • Experience Note: As part of Quinn Emanuel, likely involved in patent litigation and IPR proceedings.
• Greg Miraglia
  • Role: Attorney for Petitioner
  • Firm: Quinn Emanuel Urquhart & Sullivan, LLP
  • Experience Note: As part of Quinn Emanuel, likely involved in patent litigation and IPR proceedings.
• Nima Hefazi
  • Role: Attorney for Petitioner
  • Firm: Quinn Emanuel Urquhart & Sullivan, LLP
  • Experience Note: As part of Quinn Emanuel, likely involved in patent litigation and IPR proceedings.
• Luiz Miranda
  • Role: Attorney for Petitioner
  • Firm: Quinn Emanuel Urquhart & Sullivan, LLP
  • Experience Note: As part of Quinn Emanuel, likely involved in patent litigation and IPR proceedings.

It is worth noting that Unified Patents also employs in-house Senior Patent Counsel, such as Jenn Bisk, Kyla Bulter, Michelle Aspen, Jordan Rossen, and Jessica Marks, who manage patent office proceedings internally, draft and litigate patent office proceedings, and support senior attorneys. However, the settlement order for IPR2025-01377 explicitly lists the attorneys from Quinn Emanuel as counsel for the Petitioner.

Radian Memory Systems LLC, the Patent Owner in IPR2025-01377, was represented by counsel from Lowenstein & Weatherwax LLP and Caldwell Cassady & Curry PC.

The attorneys of record for Radian Memory Systems LLC in this IPR and related proceedings include:

• Kenneth Weatherwax (Lead Counsel)
  • Firm: Lowenstein & Weatherwax LLP, Los Angeles, CA.
  • Experience: Mr. Weatherwax is a partner at Lowenstein & Weatherwax LLP and has represented patent owners in various IPR proceedings.
• Parham Hendifar (Counsel)
  • Firm: Lowenstein & Weatherwax LLP, Los Angeles, CA.
  • Experience: Mr. Hendifar is an attorney at Lowenstein & Weatherwax LLP.
• Nathan Lowenstein (Counsel)
  • Firm: Lowenstein & Weatherwax LLP, Los Angeles, CA.
  • Experience: Mr. Lowenstein is a partner at Lowenstein & Weatherwax LLP and has extensive experience in post-grant patent proceedings, including drafting patent owner responses, taking depositions, and presenting oral arguments before the PTAB. He has been actively involved in multiple IPRs concerning Radian Memory Systems LLC patents, among others.
• Colette Woo (Counsel)
  • Firm: Lowenstein & Weatherwax LLP, Los Angeles, CA.
  • Experience: Ms. Woo is an attorney at Lowenstein & Weatherwax LLP.
• Dennis J. Courtney (Backup Counsel)
  • Firm: Lowenstein & Weatherwax LLP.
  • Experience: Mr. Courtney was designated as backup counsel for Radian Memory Systems LLC in related IPR proceedings and has been actively involved in multiple IPRs, particularly those involving Samsung Electronics Co., Ltd. et al. v. Radian Memory Systems LLC.
• Xu Zhou (Counsel)
  • Firm: Caldwell Cassady & Curry PC.
  • Experience: Ms. Zhou is an attorney with Caldwell Cassady & Curry PC. This firm also represented Radian Memory Systems LLC in its patent infringement lawsuit against Samsung in the Eastern District of Texas.

It is worth noting that Radian Memory Systems LLC was also represented by Bradley W. Caldwell and Adrienne Roberts Dellinger of Caldwell Cassady & Curry, PC in the parallel district court case against Samsung (2:24-cv-01073).