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Now it is quite possible Intel is an infringer on NetList patents~? WOW~!
If so it shows the importance of NetList patents pertaining to other companies and the applications assigned to them. There is NO way to get around NetList patents. NONE~!
This could be huge. Imagine how much money in just licensing this could mean.
And how long has this been going on if proven true~?
Many other ENORMOUS companies are in violation as well IMO. Not just Samsung, Micron, and Google. MANY who use large server arrays have been doing so without paying licensing let alone royalties for the benefit of NetList patented PIP.
Just my opinion.
Hoping Gilstrap and Payne lower the boom on the Clown Cartel, the 3 Amigos.
Both judges need to send a very strong message to the 3 Amigos in monetary form. Money is the only thing they understand. the Clown Cartel are nothing less than Philly looters. A MOAIS (Mother Of All Infringement Settlements) needs to be applied to all of these criminal Companies. JMO
NetList baby~!
Patents Assigned to Netlist, Inc.
https://patents.justia.com/assignee/netlist-inc?page=4
Hong about HBM, CXL & nand
Suji “Can you just talk about the NAND controller that kind of arbitrages NAND for DRAM? And is that technology or even the hybrid DIMM product itself, the name has a play into this going forward? Or have you kind of repositioned that technology in some of the new products you'd be planning to target gen AI?”
Reply by Chun K. Hong
“Yes, Suji, I think that's an important part of what we're doing here in the R&D side. We've been working on the hybrid DIMM use of -- using a lot of NAND to replicate DRAM performance for the CXL bus. So the way you can distinguish an AI server from a standard enterprise server is that the AI server operates first off of a GPU, which requires hundreds of gigabytes of HBM. A standard enterprise server that's been around for 34 years do not require HBM. So that's one. And we have part of the win that we got against Samsung was on our HBM patents.
The other thing is that in main memory, 2 other elements. So one is HBM.
TOMKiLA
19m
$NLST MRDIMM is the next LRDIMM?
MRDIMM or multi-ranked buffer DIMMs. This next-generation ultrafast DDR5 memory is being designed to double the throughput of existing DDR5 DIMMs, eventually delivering speeds up to 17,600 mega transfers per second. And while the standard for MRDIMM has not been finalized, the memory industry appears poised to once again rely on many of Netlist's technologies to enable MRDIMMs functionality.
These new technologies are transforming the memory marketplace and provide a strong platform for Netlist's growth.
The other thing is that in main memory, 2 other elements. So one is HBM. The other 2 elements are that main memory in an AI server is 4 to 5x the capacity of a standard enterprise server. That requires then a move to high capacity, particularly MRDIMM. And there, we are in a very strong position, again, with dozens of patents covering MRDIMM.
TOMKiLA
4:07 PM
$NLST When we see netlists seeking billions of dollars in damages from microns for years of stolen patents, it will be poetic.
Yes, even in the Samsung case, the lawyer Sheasby had asked for billions of dollars in damages.
Unlike Samsung, Micron has never paid a dollar for licenses or agreements of any kind. This puts micron in the worst possible position, damage of minimum 2 years following Samsung's timing and potentially we can expect 5/6 or more years of total damage.
If you have to dream, do it big!!!
My personal opinion is damages for $500m
NLST One thing to keep in mind d about the BOC appeal/ cross appeal. There was more than one breach determined by Judge Scarsi. Another reason, that I am confident about the BOC appeal/ cross appeal outcome. Document 186, from the BOC case, is a good reread.
https://storage.courtlistener.com/recap/gov.uscourts.cacd.783923/gov.uscourts.cacd.783923.186.0.pdf
SilviaJ
Yesterday 10:57 PM
$NLST Interrogatories are discovery tools. They can be terrifying when presented properly by opposing counsel as they ask uncomfortable questions and have the ability to reveal mischief or wrongdoing. I like this one because it goes to the matter of (currently) unaccused products like FBDIMMs and NVDIMMs.
INTERROGATORY NO. 14:
Identify the role played by any Micron employees in JEDEC meetings regarding the design and function of the PMIC present on DDR5 modules, the adoption of distributed buffers in DDR4 LRDIMMs, or the adoption of the Advanced Memory Buffer (“AMB”) for DDR2 FBDIMMs, and the Micron employees who first defined these features on Micron DDR5 products, Micron NVDIMM products, Micron FBDIMMs, or Micron LRDIMMs.
read the whole thread............. https://stocktwits.com/SilviaJ/message/546347330
TOMKiLA
46m
$NLST NVIDIA h100 and amd MI300 will use HBM in their GPU.
Nvidia h100 will sells over 1.5/2M units the next year against 500k units of 2023. (HBM will fly a lot)
Nobody can say about the amd product right now but this is the alternative of h100.
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all quiet on the western front this morning. no docs dropped last night. enjoy your morning !
NLST Another to be heard Oct 23rd in Micron #203 case is Motion/Doc #179 with the unsealed version filed Sept 27 as Doc #201—PLAINTIFF NETLIST, INC.’S MOTION TO COMPEL PRODUCTION OF CONTRACTS AND MOUs WITH MAJOR CUSTOMERS, COMMISSION RECORDS, AND DECISIONS TO DISCONTINUE HMC PRODUCTS.
Intro in pic & link to filing below —
https://storage.courtlistener.com/recap/gov.uscourts.txed.215248/gov.uscourts.txed.215248.201.0.pdf
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NLST Continuing with Motions to be heard Oct 23rd in Micron #203 case... 137 & 146 have been posted prior and are publicly accessible on Courtlistener docket, link provided yesterday in my chart post.
—#137—PLAINTIFF NETLIST, INC.’S MOTION TO COMPEL MICRON DEFENDANTS TO PRODUCE DOCUMENTS RELATING TO THE ACCUSED FEATURES OF MICRON’S PRODUCTS—unsealed version is #150.
—#146—PLAINTIFF NETLIST, INC.’S MOTION TO SHOW CAUSE WHY DEFENDANTS SHOULD NOT BE HELD IN CONTEMPT FOR VIOLATING THE COURT’S JULY 26, 2023 ORDER—unsealed version is #149.
—#178—PLAINTIFF NETLIST’S MOTION FOR AN ORDER TO SHOW CAUSE WHY EVIDENTIARY SANCTIONS RELATING TO THE ’060 AND ’160 PATENTS SHOULD NOT BE ISSUED ON DEFENDANTS—unsealed version filed Sept 27 as Doc #200 posted below.
Table of Contents in pic & link to filing —
https://storage.courtlistener.com/recap/gov.uscourts.txed.215248/gov.uscourts.txed.215248.200.0.pdf
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TOMKiLA
28m
$NLST mytreasure, the 355k netlist shares. When all the big wins come, the value of this company will be enormous. Nvidia and other companies taught me what it means to be patient. Netlist Inc will become a giant and no one will be able to stop it.
A big round of applause to the genius inventors of netlist because they are the main reason why these patents are potentially worth billions of dollars today.
These inventors created successful products such as lridmm and nvdimm. They are the ones who reduce energy expenditure, improve performance and save memory giants billions of dollars.
A genius has a value that cannot be estimated. If tesla with autonomous driving alone is worth $600b, what can we say about lrdimm, nvidimm and many other things invented by the geniuses at netlist inc?
Patent 912 is worth its weight in gold because it is the thing that revolutionized the web search market. RANK, netlist will demonstrate to the whole world who Google really is.
This is one of the motions to be heard at the Oct 23rd hearing in the Micron #203 case—original Motion/Doc #186, and was filed unsealed Sept 26 as Doc 195—"PLAINTIFF NETLIST, INC.’S MOTION TO COMPEL PRODUCTION OF REVERSE-ENGINEERING, SIMULATION DATA, AND COMPLETE HBM TECHNICAL DOCUMENTS".
"Plaintiff Netlist hereby moves for an order:
(1) Compelling Micron to produce all reverse engineering and competitive analysis __(redacted)__.
(2) Compelling Micron to produce all simulation data comparing Micron’s HBM3 products to Micron’s HBM2E products; and
(3) Compelling Micron to produce the missing pages and hyperlinks within Micron’s production of HBM technical documents."
Intro/Background in pic & link to filing below —
https://storage.courtlistener.com/recap/gov.uscourts.txed.215248/gov.uscourts.txed.215248.195.0.pdf
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NLST Things move fast in Texas — the transfer of Netlist's Motion-to-Compel-Intel case has been received & opened in ED-TX, and assigned Judge Gilstrap.
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Micron LPDDR5 16 Gb Non-EUVL Chip Found in Apple iPhone 15 Pro
Unveiling the World's First D1ß (D1b) DRAM
https://www.techinsights.com/blog/micron-lpddr5-16-gb-non-euvl-chip-found-apple-iphone-15-pro
NLST Alone from 4 patents concerning DDR and HBM in a very few years and alone from Samsung. Would be about 300, 500, 750 and 1 Bio USD for 2024 - 2027.
Not dreaming, no fantasy - only and exclusively based on the rate determined by the Tx court in the 303 Mio USD judgement against Samsung and industry forecast, including forecast from our litigation opponents.
Samsung better works on a deal, because this calculation could become much worse with the judgements from the other cases approaching in Texas, Delaware and Europe. Same applies to Micron.
NLST Each GB of memory costs $3 so a 16GB DDR5 memory is priced at $50.
DDR5 share this year is expected to reach 50% of all DDR sales and surpass DDR4.
As you can see from the image, the sale of all notebooks & desktops exceeded 60 million units in the second quarter of 2023.
It is interesting to estimate that ddr5 will grow exponentially in the next 5 years. As Hong says, HBM and DDR5 are expected to increase volumes by 3/4 times in the next few years.
Great opportunity for netlist inc.
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NLST Now we just need the Compel Google case to follow into ED TX... Netlist did include the same—"Alternatively, Netlist’s Motion Should Be Transferred to the Eastern District of Texas Where the Underlying Patent Infringement Action Is Pending"—but Netlist requested & received 3 extensions of time to file its Reply to Google's Response—to Sept 15 / to Sept 25 / to Oct 16—there has to be a reason strategic or otherwise... it's mainly Sheasby on top of all the moving parts, being a conductor... things need to be done methodically... thought process and considerations are very complex, inlcuding assessing most effective/efficient use of resources. And since much is fluid, I have trust when Netlist seeks any type of extension... Google has not opposed. For perspective, today's Transfer in the Intel case came 2 weeks after Netlist's Reply... we'll get to Google in Oct, they have a lot more skeletons in their closet.
https://sih-st-charts.stocktwits-cdn.com/production/original_546166370.png
NLST - The relevancy of the transferring of the Netlist's Motion to Compel Intel to Comply w/ Subpoenas to the E.D. of Texas is very significant.
Not only is Netlist seeking from Intel the number of Micron Accused Products Intel Imported into or Used, Sold, Offered for Sale in the United States but also;
Netlist is seeking documents sufficient to show the locations where Intel evaluates or analyzes any Micron Accused Memory Products to determine whether to purchase quantities of the design. This request is relevant to determine whether substantial activities of a sales transaction occurred in the United States and therefore is properly within the damages base for Netlist's infringement claims.
The Federal Circuit found in Carnegie Mellon Univ. v. Marvell Tech. Grp., . . . that it is appropriate to consider the entire sales cycle of the accused products in assessing damages, including evidence showing that "the activities related to designing, simulating, testing, evaluating, qualifying the chips by Marvell as well as by its customers occur in the United States". Additionally, the Court overseeing the underlying litigation has already determined that the locations where Micron's customers perform testing/qualification of the accused products is relevant. Intel has not claimed that it has shared such information with Micron, thus, Netlist must seek it from Intel.
First, the discovery deadline in the underlying suit is September 5, 2023, and
the motion now before the undersigned was filed on September 1, 2023, and became
ripe on September 8, 2023. The undersigned is loath to interfere in the discovery
scheduling of its sister court in the Eastern District. That court and not this, has a
better idea of whether this motion should be entertained, let alone granted.
like i said, we've already won the award of hundreds of millions of dollars. the writing is on the wall for all to see. there toast, another slam dunk.........
NLST An Order granting transfer was just issued for Netlist in the Motion to Compel case against Intel, relating to discovery for Micron #203 cass—"The underlying case in issue is a patent case involving complicated relationships between many parties and non-parties and their interests in the patents in issue. The interest in having a single court decide all these issues outweighs Intel’s interest in having the issue decided in Austin. These facts present sufficient “exceptional circumstances” to support the transfer of the motion under Rule 45(f). Accordingly, transfer of Netlist’s Motion to Compel Dkt. 1, is proper."—
"IT IS THEREFORE ORDERED that Petitioner Netlist’s Motion to Compel Intel Corporation to Comply with Subpoenas, Dkt. 1, is GRANTED IN PART and Netlist’s Motion to Compel and all other remaining pending motions in the case are HEREBY TRANSFERRED to the United States District Court for the Eastern District of Texas."
More specifics in filing below
https://storage.courtlistener.com/recap/gov.uscourts.txwd.1172755732/gov.uscourts.txwd.1172755732.9.0.pdf
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NLST Twelve dates to pencil in on your calendar:
10/12 - Sam Germany decision
10/19 - 339 IPR FWD
10/20 - CC Hearing Sam/Goog DE
10/21 - 506 IPR FWD
10/23 - MU EDTX Hearing on 14 smokin' hot motions
11/01 - 314 IPR FWD
11/09 - Goog Germany hearing
12/06 - 054 IPR FWD
12/07 - 918 IPR FWD
01/22/24 - MU EDTX Trial
4/15/24 - MU/Sam EDTX Trial
4/19/24 - Claim 16/912 IPR FWD
it actually is....... NLST It's been a week... good time for a post of the current litigation situation.
Anything new/changed is highlighted yellow... which is the Oct 23rd hearing in the Micron #203 case on 14 Netlist & Micron motions.
Motion #'s are — 137 / 146 / 178 / 179 / 181 / 184 / 185 / 186 / 187 / 188 / 189 / 190 / 191 / 193 — feel free to search the docket on Courtlistener for a description of the motions.
https://www.courtlistener.com/docket/63378313/netlist-inc-v-micron-technology-inc/?filed_after=&filed_before=&entry_gte=&entry_lte=&order_by=desc
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prime311
9:39 AM
$NLST Good Morning Netlisters. Everything that I posted yesterday was just from the first time that Sheasby took the podium. McKean rebutted next. I will pick up there with my next posts, as soon as I have time to type everything up. In the interim, everyone should read this: ipwatchdog.com/2018/10/10/u.... McKean, Gilstrap, and Sheasby all referenced the Phillips Standard during the Claims Construction.
https://ipwatchdog.com/2018/10/10/uspto-publishes-final-rule-phillips-standard-ptab/id=102210/
gonna cough it big soon !!
TOMKiLA
16m
$NLST micron has 48k employees, it spends $219m per quarter to retain them. WHAT COULD NETLIST DO WITH $1b cash?
just one patent case is worth $303.15m plus interest and additional damages.
Netlist could hire 500/1000 engineers, it could take advantage of state incentives and open a factory in the USA and independently produce a significant quantity of dram and nand products.
The fourth-largest memory maker shows revenues of $229m in the second quarter of 2023.
Netlist can easily surpass this figure once the micron and samsung cases are resolved.
Amazon, Apple, Nvidia, AMD, Intel etc need to diversify their suppliers.
NETLIST can do great things with sk hynix, micron and samsung patents.
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robcobb
25m
$NLST Just another thing from the hearing ,everyone knows the Samsung lawyers knew me and Larry (Prime)were Nlst investors from the Samsung trial .At the recent hearing I caught Michael Mckean taking long stares at me and Larry as we took notes while other lawyers were arguing.After the hearing was over me and Larry were walking out together,Michael Mckean came by and said (with a grin on his face )how are you guys doing ? I thought this to be funny since he knew we were Nlst investors!
TOMKiLA
48m
$NLST • Micron and sk hynix are very similar in size unlike Samsung ($200+b in revenues) and Google which everyone knows well.
• 95% of patent cases end in a deal before a jury trial.
• sk hynix has found a deal, samsung on trial but we know about samsung that they act like idiots and it's positive for netlist, more damage, more numbers, more licenses and cash.
• micron is currently burning cash, they have just under $9b cash but also have $3b debt.
the nlst case could fully affect micron's resources, something that can create enormous problems.
Potential $500m in damages for the Texas case alone, there are two more on the table without counting additional IP licenses.
• micron does not have the power of samsung or google, this is evident.
Sanjay Mehrotar: I am proud of our team's launching a suite of leading-edge products that represent one of the strongest portfolio expansions in Micron's 45-year history; all thanks to our ingenious R&D team at Netlist.
NLST: $MU dropped on this news? Someone’s anticipating a MAJOR HIT on MICRON.
“"We have samples in the hands of customers, that compared to samples from our competitors, blow away everyone," Sadana said. "In fact, the power consumption is so much lower for higher performance that some of our customers didn't believe the data till they actually tested it out."” Hmmm, I wonder which NETLIST PATENT this steals from?
Micron Chief Executive Sanjay Mehrotra told analysts during a conference call that the company expects "several hundred million" dollars worth of revenue from its new high-bandwidth chips next year. The company expects its gross margins to become positive again in the second half of its fiscal 2024.
Micron essentially sat out the current generation of high-bandwidth chips and instead made a bet that it could profit by selling higher performing chips starting next year, Sumit Sadana, Micron's chief business officer, told Reuters in an interview.
$NLST "Micron HBM3E is currently in qualification for NVIDIA compute products, which will drive HBM3E-powered AI solutions.
We are very excited with our HBM product. It is an industry-leading product with respect to performance, power, capacity, capability. And as we have mentioned, this product is in the qualification stages with our customers here and we expect revenue to begin in early 2024. And yes, we are very much still on track for meaningful revenue, $700 million in our fiscal year '24."
"Micron also has a strong position in the industry transition to DDR5. We expect Micron DDR5 volume to cross over DDR4 in early calendar 2024, ahead of the industry. We have started shipping samples to customers to help support their AI application needs."
in about 4 months or less from now gilstrap is going to be telling us how many hundreds of millions of dollars we're going to get once again, not too mention the germans will more than likely grant big money as well. trading on future events is what the market is about. right now we are trading way below our future events. lets move to the nasdaq and play this game at a higher pps !! soon the money owed or awarded us will be larger than our market cap. will the otc reflect that ? we will see soon enough...........one of these days............
prime311
6:26 PM
$NLST Good evening everyone. Sorry to take so long to start posting, but I had work to catch up on first - plus I wanted to double check my notes. During the trial, they were presenting a case before a jury and had to go slowly, and explain every claim and contention. During the CC, it was only the slew of the co-defendants’ lawyers, Sheasby, & Gilstrap. Everyone was well versed in the material, so it was pretty rapid fire. I will go through and relay what I jotted down, but I missed some things while I was writing- and I must confess that I was writing so rapidly at times that I had to decipher what I wrote down. The first item discussed was that both parties agreed to allow Gilstrap to define the term circuitry using their briefing papers. Then they immediately went to the 912 claims. Gilstrap even remarked that they were only allotted 3-1/2 hrs for the hearing, and his assumption was that the 912 would take up the majority of the hearing.
During the hearing, Gilstrap would decide which side he wanted to argue first on each claim. For the discussion about how to interpret "Rank", he called on Sheasby first. Sheasby said that the term rank was created by JEDEC. At that point Gilstrap. stopped Sheasby and asked if the patent claims SEPs, and if so, are they subject to FRAND? Sheasby responded that at the time of the patent, it was not part of the JEDEC standard, but was incorporated later. He said that the time when the patent became essential should be determined by an expert witness. Sheasby then went on to explain that rank had to be multiple DDR devices. He explained that the memory standard required 64 or 62 bits. Therefore, you had to use more than one chip to achieve the standard. He then produced depositions from Harold Stone (Micron’s expert) showing were Stone said that there would be more that one to achieve this.
Sheasby then produced a deposition from a Micron Exec, Boe Holbrook, also saying it would be more than one. Sheasby then put the 912 patent claims on the screen and has highlighted where every figure in the patent describes rank as plural devices. He underlined and highlighted all of the “s”’s at the end of the word devices. Later Sheasby said the Amidi prior art argument is not valid because Amidi didn’t contemplate a plurality of devices. The 912 requires plurality. I was writing and didn’t catch every part of the next argument, but Sheasby referenced the 215 patent because he said Samsung would, and stated that it says there has to be at least one memory circuit with a buffer, and that the defense will try to misconstrue that at one device.
Sheasby then went to the 912 claim 15. He said that the defense is trying to say it’s one device. Sheasby said that it actually defines devices (DDR), then defines rank. Then Sheasby said the defense will try to use the 912 figure 6a in their argument, but Sheasby said figure 6a is saying how it couples DRAMs or how it couples ranks. Sheasby referenced the Jacob’s textbook
amazon.com/Memory-Systems-C.... I linked it because it came up often in the proceedings. Sheasby showed where the text that the word rank means more than one memory device. -it seemed both sides at times referenced the textbook at various times to try to prove points. I’m guessing it points to how someone trained in the art would interpret the meanings of things. Sheasby then showed another slide of Microns expert witness Harold Stone saying it has to be more than 1
Let me post a to be continued…. I have a lot more, but I will try to make some time tonight or in the morning to give the rest of the details
it makes sense because its the truth. its like having the best player in the league on your team, but your team sux. why ? ummm..... you need to let the guy play !
i hope more court documents drop by the time i get back enforcing the point of us receiving hundreds and hundreds of millions of dollars on top of the 300 plus million already awarded ! time for some gourmet chocolate chip cheese cake..........
4-24-23 we hit 6.10, so has the company showed any progress in litigation since then ? well hell yeah! and growing stronger steadily. wheres the market rewarding us for that on the moldy old otc. the answer is, its not ! whats going on is criminal and we cant even break 2.20 today after seeing what happened in those court documents. sure a little is blacked out but its telling us we're going to win hundreds and hundreds of millions of dollars real soon. isnt a stock pps suppose to go up on that kind of news ???
we should uplist to the nasdaq and pr these court filings and let the market be our judge. you all do realize that we'll more than likely have racked up close to a billion dollars in awards to be paid by the time we have our next jury trial in 3 1/2 months. we should be trading on the possibility of the future not the demise of the otc. this 1 and 2 dollar shit isnt cutting it as far as i am concerned.
NLST Staying for now on Samsung/Micron Consolidated 912+3 case... filing is unsealed version from 9/19. Remember this interesting doc—NETLIST MOTION TO (1) DISMISS MICRON DEFENDANTS’ COUNTERCLAIMS OR IN THE ALTERNATIVE SEVER AND STAY AND (2) STRIKE MICRON DEFENDANTS’ AFFIRMATIVE DEFENSE OF PATENT MISUSE—"Netlist moves to dismiss Micron's counterclaim for alleged violations of Section 1 of the Sherman Act and to strike Micron’s affirmative defense for patent misuse as plead in its Answer and Affirmative Defenses" The irony..."Aside from being procedurally infirm, Micron’s new antitrust claim and patent misuse defense are facially deficient. Though Micron couches its allegations in antitrust buzzwords such as “price fixing,” “tying,” and “refusal deal,” its allegations attack perfectly legal and commercially common licensing terms and practices. Netlist’s motion should be granted for the following reasons." Other Intro part in pic & filing link below, good stuff.
https://storage.courtlistener.com/recap/gov.uscourts.txed.216364/gov.uscourts.txed.216364.167.0.pdf
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