Litigation
Yangtze Memory Technologies Company, Ltd. v. Micron Technology, Inc. et al.
Open3:23-cv-05792
- Filed
- 2023-11-09
Patents at issue (1)
Defender signal. Patent 11101276 has had claims invalidated at PTAB. Those final written decisions are public record and a ready-made § 102 / § 103 ground in district court. See IPR estoppel for what carries over.
Plaintiffs (1)
Summary
Yangtze Memory Technologies Company, Ltd. sued Micron Technology, Inc. and Micron Consumer Products Group, LLC for patent infringement. A related case, 3:2024cv04223, filed by the same plaintiff against the same defendants, was consolidated into this case on August 21, 2024.
Case overview & background
Plain-language overview of the case: parties, accused product, patents at issue, and why the suit matters.
Yangtze Memory Technologies Company, Ltd. (YMTC), a Chinese integrated device manufacturer (IDM) specializing in 3D NAND flash memory, initiated this patent infringement lawsuit against Micron Technology, Inc. and its subsidiary, Micron Consumer Products Group, LLC. YMTC designs and manufactures 3D NAND flash memory wafers, packaged chips, and embedded memory solutions for mobile devices, consumer electronics, computers, servers, and data centers. Micron Technology, a U.S.-based semiconductor company, is a global leader in memory and storage solutions, producing DRAM, NAND flash, and NOR flash products used in data centers, PCs, smartphones, automotive, and industrial applications.
The core of the dispute involves allegations that Micron's NAND flash memory products infringe YMTC's patents. Specifically, the accused products include Micron's 96-layer, 128-layer, 176-layer, and 232-layer NAND products, encompassing both individual NAND chips and products incorporating them, such as certain SSD models. Additionally, Micron's DDR5 DRAM products, including individual chips and products containing them, are also alleged to infringe. The lawsuit asserts infringement of multiple patents, including U.S. Patent No. 11,101,276, among others, broadly concerning 3D NAND technology. Unfortunately, a one-line technical sketch for patent 11101276 is not readily available in the search results and cannot be provided without further, more specific patent document analysis which is outside the scope of this general web search.
The case is currently before the U.S. District Court for the Northern District of California, San Francisco Division, with Judge Rita F. Lin presiding. The Northern District of California is a prominent venue for patent litigation, particularly in the technology sector, due to its specialized judiciary and the concentration of high-tech companies in the region. This case is notable due to its "operating company vs. operating company" nature within the highly competitive and strategically important global semiconductor memory market. It highlights the fierce intellectual property battles between major players in the 3D NAND space, a critical technology for various digital products. The litigation is further complicated by the geopolitical context surrounding YMTC, a Chinese company, and U.S. sanctions, which have been a point of contention and have impacted YMTC's market presence. There are also related inter partes review (IPR) proceedings at the Patent Trial and Appeal Board (PTAB) challenging the asserted patents, indicating a multi-front legal battle.
Key legal developments & outcome
Major rulings, motions, claim construction, settlements, and the present posture or final disposition.
Here's a summary of the key legal developments and outcomes in the patent infringement litigation Yangtze Memory Technologies Company, Ltd. v. Micron Technology, Inc. et al. (3:23-cv-05792) and related proceedings:
Key Legal Developments and Outcome
1. Filing & Initial Pleadings
- 2023-11-09: Yangtze Memory Technologies Company, Ltd. (YMTC) filed its initial complaint against Micron Technology, Inc. and Micron Consumer Products Group, LLC, asserting infringement of U.S. Patent Nos. 10,950,623, 10,868,031, 10,861,872, 10,658,378, 10,937,806, 11,468,957, 11,501,822, and 11,600,342.
2. Consolidation of Related Case
- 2024-07-12: YMTC filed a second patent infringement action against Micron, case number 3:24-cv-04223, asserting U.S. Patent No. 11,101,276 (the patent at issue in this summary) along with several other patents.
- 2024-08-21: The U.S. District Court for the Northern District of California consolidated the second action (3:24-cv-04223) into the first-filed action (3:23-cv-05792), bringing the total number of asserted patents to nineteen. Although the case metadata states the Eastern District of California, court documents indicate the Northern District of California. The court ordered YMTC to reduce its number of asserted claims to a total of 70.
- 2025-01-24: YMTC narrowed its asserted claims to 70 in accordance with the court's claim narrowing order.
3. Pre-trial Motions of Substance — Motion to Stay Pending IPR
- 2025-02-03: YMTC filed its opposition to Micron's motion to stay the case pending inter partes review (IPR) and post-grant proceedings.
- 2025-03-14: The District Court for the Northern District of California granted Micron's motion to stay the case pending the outcome of inter partes review proceedings. The court had previously ordered the parties to streamline the litigation further, down to 8 claims at trial from the 19 originally asserted patents.
4. Discovery Milestones with Strategic Significance
- 2025-01-14: The district court issued an order related to discovery in the case.
- 2025-02-26: Micron filed a petition for a writ of mandamus (No. 25-117) with the Federal Circuit concerning a discovery dispute, specifically regarding the production of paper copies of sensitive technical information, including source code, to YMTC. Micron argued that the district court ignored agreed-upon limits in a protective order and the availability of alternative secure means for production, as well as national security concerns regarding YMTC as a Chinese state-owned entity. The Federal Circuit denied the petition, refusing to correct what Micron considered a clear error.
- 2025-05-23: Micron filed a petition for certiorari with the Supreme Court of the United States, seeking review of the Federal Circuit's decision regarding the discovery dispute. Micron requested the Supreme Court to intervene to ensure the enforcement of protective order terms, arguing that the district court failed to uphold the agreed-upon rules for access to sensitive technical information.
5. Claim Construction (Markman) Outcomes
- As of the current date, given the stay of the district court proceedings pending IPRs, a Markman hearing has likely not yet occurred. However, an expert witness for Micron Technology Inc. has served in the case and composed an expert declaration, suggesting some preliminary technical analysis may have taken place.
6. Trial Events, Verdict, and Post-trial Motions
- No trial events, verdicts, or post-trial motions have occurred as the district court litigation has been stayed.
7. Settlement, Dismissal, Judgment, or Appeal
- The district court case is currently stayed pending the outcome of numerous IPR proceedings at the PTAB. Micron has sought Supreme Court review concerning a discovery dispute related to source code production.
8. Parallel PTAB IPR/PGR Proceedings on the Asserted Patents
Micron Technology, Inc. has filed a "barrage" of 26 IPR petitions challenging 251 claims across 19 of YMTC's patents, including U.S. Patent No. 11,101,276.
- IPR2025-00228 (U.S. Patent No. 11,101,276): Micron (Petitioner) filed an inter partes review petition for this patent. YMTC (Patent Owner) filed a brief on discretionary denial, arguing against institution, partly due to the substantial number of petitions filed and the overlap with the district court litigation. YMTC stated that fewer than a third of all challenged claims (across all patents) are currently asserted in the parallel litigation, including only 2 of the 12 challenged claims in this specific IPR.
- IPR2025-00035 (U.S. Patent No. 11,450,604): Micron (Petitioner) filed an IPR petition for this patent. YMTC (Patent Owner) filed a preliminary sur-reply on 2025-05-05, also requesting discretionary denial of institution under the Fintiv factors, citing the district court's stay and the streamlining of claims in the litigation.
- IPR2025-00099 (U.S. Patent No. 10,872,903): Micron (Petitioner) filed an IPR petition for this patent.
- Multiple other IPR proceedings (IPR2025-00498, IPR2025-00499, IPR2025-00500, and IPR2025-00501) involve discretionary denial briefing with "substantially identical arguments" to those presented in IPR2025-00099.
The PTAB's decisions on institution and subsequent final written decisions in these IPRs will be significant for the trajectory of the stayed district court litigation. The district court's decision to stay the case indicates that it is awaiting the PTAB's determinations on patent validity.
Plaintiff representatives
Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- Kirkland & Ellis
- F. Christopher Mizzo · lead counsel
- Yanan Zhao · lead counsel
Yangtze Memory Technologies Company, Ltd. is represented by attorneys from Kirkland & Ellis LLP in its patent infringement case against Micron Technology, Inc. et al., Case No. 3:23-cv-05792.
The identified counsel of record for the plaintiff include:
F. Christopher Mizzo, P.C.
- Role: Lead Counsel
- Firm: Kirkland & Ellis LLP, Washington, D.C. office.
- Experience Note: Chris Mizzo is a trial lawyer with extensive experience in complex commercial and intellectual property disputes, including first-chairing high-stakes patent cases in federal courts and before the U.S. International Trade Commission. He has also conducted post-grant reviews before the USPTO. His representative matters include protecting smartphone technologies for a leading consumer electronics company and representing Samsung in ITC actions concerning memory products and graphics processing units.
Yanan Zhao
- Role: Lead Counsel
- Firm: Kirkland & Ellis LLP, Los Angeles, California office.
- Experience Note: Yanan Zhao is an intellectual property partner who has represented Yangtze Memory Technologies Co., Ltd. in patent litigation against Micron. Her prior experience includes securing a jury verdict for over $440 million against Micron for a patent owner. She focuses on patent infringement, ITC Section 337 proceedings, trade secrets, and trademark litigation.
Defendant representatives
Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- Micron Technology
- Michael Ray · in-house
- Winston & Strawn
- Jared Bobrow · attorney
The case metadata in the prompt identifies the court as the U.S. District Court for the Eastern District of California. However, all available search results for case number 3:23-cv-05792 consistently indicate that the case, Yangtze Memory Technologies Company, Ltd. v. Micron Technology, Inc. et al., is being heard in the U.S. District Court for the Northern District of California, San Francisco Division, before Judge Rita F. Lin. This discrepancy is explicitly noted. For the purpose of identifying counsel, this summary relies on the court information consistently found in the search results (Northern District of California) associated with the provided case number.
Based on available information, the following counsel represents the defendant(s), Micron Technology, Inc. and Micron Consumer Products Group, LLC:
In-House Counsel:
- Michael Ray
- Role: Chief Legal Officer and Corporate Secretary
- Firm: Micron Technology, Inc.
- Office Location: Boise, Idaho (Micron's headquarters)
- Relevant Experience: Responsible for Micron's global legal, compliance, and intellectual property functions. He has nearly 30 years of legal experience, including over 13 years as chief legal officer and general counsel at Western Digital, where he led the legal department.
External Counsel:
- Jared Bobrow
- Role: Attorney for Petitioner Micron Technology, Inc. (in related PTAB IPR proceedings, and has familiarity with the district court case)
- Firm: Winston & Strawn LLP (identified in prior related PTAB proceedings as counsel for Micron)
- Office Location: San Francisco, California (Winston & Strawn has an office in San Francisco).
- Relevant Experience: Experienced patent litigation attorney, with familiarity in the subject matter at issue in this proceeding and the related district court case. He is admitted to practice in the Northern, Central, Southern, and Eastern Districts of California, and has extensive experience in patent infringement litigations, including fact and expert deposition discovery, claim construction, Markman hearings, motion practice, and trials.
While additional law firms like Irell & Manella LLP, McKool Smith, Latham & Watkins LLP, and O'Melveny & Myers are generally associated with Micron Technology in patent analytics, Jared Bobrow of Winston & Strawn LLP is specifically linked to this particular district court case through related PTAB filings where he represents Micron and states his familiarity with the underlying district court litigation. Further specific appearances of other attorneys for Micron in the district court docket were not explicitly detailed in the provided search results beyond his involvement mentioned in the context of IPRs.The case metadata in the prompt identifies the court as the U.S. District Court for the Eastern District of California. However, all available search results for case number 3:23-cv-05792 consistently indicate that the case, Yangtze Memory Technologies Company, Ltd. v. Micron Technology, Inc. et al., is being heard in the U.S. District Court for the Northern District of California, San Francisco Division, before Judge Rita F. Lin. This discrepancy is explicitly noted. For the purpose of identifying counsel, this summary relies on the court information consistently found in the search results (Northern District of California) associated with the provided case number.
Based on available information, the following counsel represents the defendant(s), Micron Technology, Inc. and Micron Consumer Products Group, LLC:
In-House Counsel:
- Michael Ray
- Role: Chief Legal Officer and Corporate Secretary
- Firm: Micron Technology, Inc.
- Office Location: Boise, Idaho (Micron's headquarters)
- Relevant Experience: Responsible for Micron's global legal, compliance, and intellectual property functions. He has nearly 30 years of legal experience, including over 13 years as chief legal officer and general counsel at Western Digital, where he led the legal department.
External Counsel:
- Jared Bobrow
- Role: Attorney for Petitioner Micron Technology, Inc. (in related PTAB IPR proceedings, and has familiarity with the district court case)
- Firm: Winston & Strawn LLP
- Office Location: San Francisco, California (Winston & Strawn has an office in San Francisco)
- Relevant Experience: Experienced patent litigation attorney with a practice focused on intellectual property, admitted to practice in the Northern, Central, Southern, and Eastern Districts of California, and familiar with the subject matter at issue in this proceeding and the related district court case. His experience includes fact and expert deposition discovery, claim construction, Markman hearings, motion practice, and trials.
While general analytics show Micron working with other firms such as Irell & Manella LLP and McKool Smith for various patent cases, Jared Bobrow of Winston & Strawn LLP is explicitly linked to the district court case through related PTAB filings where he represents Micron and has affirmed his familiarity with the underlying district court litigation. Specific docket entries detailing the appearance of other attorneys for Micron in the district court case were not found in the provided search results.