From YMB....... Google
GoogleStoleOurPatent912 11 hours ago
Read this from Netlists statement:
The need for discovery to progress is particularly important because of the aggressive
positions Google has taken. The JEDEC Committees promulgate standards on various memory
modules. Netlist is able to determine what claims in the ’912 patent read on the standard. But there
is no requirement that Google comply with the standard and Google’s use of memory modules is
nonpublic information within Google’s exclusive possession. It is for these reasons that Netlist’s
discovery requests are directed at Google memory modules that have relevant claimed features, in
order to ensure that Google is not able to hide infringement by classifying its products as not
standards compliant and therefore not “covered” by the infringement contentions. No better
evidence of this disconnect exists than Google’s representation to the Court that(Redacted Portion)
.” This statement flatly contradict the discovery it produced under
threat of sanctions motions that (Redacted Portion). And it flatly
contradicts the infringement contentions, WHICH ARE EXPRESSLY NOT LIMITED TO 4 RANK:
The memory modules incorporated in Google’s servers include, without limitation,
memory modules compliant with certain portions of the JEDEC Solid State
Technology Association (“JEDEC”) standards and specifications for Double Data
Rate 4 (“DDR4”) Synchronous DRAM (“SDRAM”) Registered Dual In-Line
Memory Modules (“RDIMMs”), DDR4 SDRAM Load Reduced Dual In-Line
Memory Modules (“LRDIMMs”) and DDR4 SDRAM Non-Volatile Dual In-Line
Memory Modules (“NVDIMMs”), and products that operate in substantially
similar manner.
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