Netlist has filed complaints at the US International Trade Commission and the Eastern District of Texas, seeking an import ban on Samsung HBM and DDR5 RDIMM and MRDIMM DRAM AI memory product lines.

It’s demanding import bans (via SemiconductorsX) and sales prohibitions across the board, and it didn’t stop at Samsung. Notably, Google, NVIDIA, Broadcom, and Supermicro are also named alongside Samsung in the complaint filed by Netlist.

The patents at the center of this are U.S. Patent Nos. 12,646,537 and 12,650,937, both registered this year. The ‘537 covers vertically stacked memory dies with TSV structures, the core architecture inside every HBM chip Samsung ships.

The “937” covers a clock driver trick that repurposes an error signal line during initialization. Neither one, Netlist argues, is a JEDEC standard-essential patent, so Samsung can’t hide behind RAND licensing terms.

Samsung and Netlist signed a joint development deal back in 2015. Samsung walked in 2020. Two Texas juries have since handed Netlist $303 million and $118 million in willful infringement verdicts. Samsung kept shipping anyway.

Samsung Electronics previously entered into a licensing agreement with Netlist in 2015 but breached it in 2020. Despite twice receiving verdicts of willful patent infringement and damages awards (amounting to $303 million and $118 million, respectively) from federal juries in Texas, Samsung continues to import the infringing products into the United States.

C.K. Hong, CEO of Netlist, stated, “Netlist continues to lead innovative breakthroughs in the AI memory sector. This legal action expands our efforts to protect next-generation server DIMM and HBM technologies from unauthorized use.”

Samsung’s HBM3E is inside NVIDIA’s Blackwell GPUs. Those GPUs are inside data centers that half the AI industry depends on. A successful exclusion order wouldn’t just sting Samsung; it would have a very broad impact.

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