Micron Tech., Inc. v. Rambus, Inc., No. 09-1263 (Fed. Cir. 2011)
Annotate this CasePatents issued to Rambus covered various aspects of dynamic random access memory (DRAM)to minimize the bottleneck in the ability of computers to process data through memory. Rambus initially believed the patents broad enough to encompass synchronous dynamic random access memory (SDRAM), the other type of new memory technology, but later amended its applications to cover SDRAM. Micron claimed that its production of SDRAM products did not infringe Rambus’s patents and that Rambus’s patents were invalid and violated antitrust laws. The district court held that the patents were unenforceable against Micron because Rambus had engaged in spoliation by intentionally destroying relevant, discoverable documents in derogation of a duty to preserve them and did not reach the validity of the patents. The Federal Circuit affirmed with respect to spoiliation, vacated in part, and remanded. The district did not explain why only dismissal would vindicate the aims of deterring future spoliation; protecting the defendants' interests; and remedying the prejudice defendants suffered as a result of Rambus’s actions.
The court issued a subsequent related opinion or order on May 16, 2011.
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