Radian Memory Systems LLC (RMS), a plaintiff tied to Fortress Investment Group LLC, has sued Samsung (2:24-cv-01073) over the provision of solid state drives and related products that support Zoned Namespaces (ZNS) technology. In the new Eastern District of Texas complaint, RMS asserts seven memory technology patents developed at Radian Memory Systems Inc. (RMSI), which it characterizes as having "pioneered a new paradigm for managing flash storage media that it called Cooperative Flash Management ('CFM')" but as having been "cast out by the industry".
RMS speculates that this reaction occurred, despite the company having been "recognized and praised in the industry", in potential "retaliation for Radian's refusal to join the NVMe industry standard organization and associated Technical Working Groups". Samsung is further alleged to have been a "key participant in the industry, serving not only as a member of the NVMe industry standard organization, but also as a member of the specific Technical Working Group for the Zoned Namespaces Specification".
To the court, RMS discloses that it is a Texas LLC wholly owned by Radian Memory Systems Holdings LLC—and that no publicly held corporation owns ten percent or more "of its stock". State records confirm RMS's formation in Texas, on April 9, 2024, but identify FIP II UST LP, an apparent Fortress entity, as its managing member. RMSH was also formed in Texas, three days later (on April 12, 2024), also identifying FIP II UST LP as its managing member. FIP II UST LP was formed in Delaware on February 24, 2021; its listed address corresponds to Fortress.
On May 2, 2024, RMSI assigned over 80 US patents to RMS "C/O FORTRESS INVESTMENT GROUP, 1345 AVENUE OF THE AMERICAS, 46TH FLOOR, NEW YORK, NEW YORK, 10105, US", including the seven patents now in suit (11,307,995; 11,347,656; 11,347,657; 11,544,183; 11,681,614; 11,709,772; 11,740,801) are broadly directed to various aspects of memory technologies. RMSI was formed in California in March 2011 as "Radian Memory Systems, LLC" (with a comma), converting to a California corporation in April 2013. Michael ("Mike") Jadon, a named inventor, is currently identified as "Board Director, CEO & Co-Founder" of "Radian Memory Systems" on a webpage with copyright notice listing "Radian Memory Systems LLC".
Robert Lercari is there identified as the company's "Vice President of Technology & Co-Founder"; Shival Virmani, "EVP, Chief IP and Licensing Officer". Lercari is also a named inventor. The Radian Memory website describes Virmani as having "held senior licensing positions at [InterDigital, Inc.], where he was VP and Head of Mobile Licensing, and Western Digital, where he was Assistant General Counsel, IP and Licensing". Parallel Jadon and Lercari work histories on social media suggest that they have worked together since 1995, at Micro Memory, through an August 2007 acquisition by "industry partner" VMEtro, and through a later acquisition of VMETRO by Curtiss Wright Controls, in 2008.
The plaintiff pleads extensively concerning the development of memory technologies used in data centers, including Radian Memory's purported place in that development, RMS pleading that "[e]ventually, the industry converged on Radian's solutions" for providing "storage solutions that were deterministic, had low latency, and were cost-effective", without the "expensive overhead, unpredictable latency spikes, suboptimal performance, and premature wear-out of the flash media" within then-conventional "flash translation layers (or 'FTLs')—the foundation of most flash memory solid-state drive (or flash 'SSD') ever produced before".
The last event listed on a timeline of news provided on the Radian Memory website occurred in late 2020. However, RMS, the Texas entity formed this past April and the plaintiff in this litigation, did register to conduct business in California, on October 9, 2024. The assignment history of the patents-in-suit does not contain a recorded security interest granted to Fortress, the acquisition of which by Mubadala Investment Company from SoftBank was completed this past May. Fortress has become embroiled in long-running, multi-front litigation, through VLSI Technology LLC (holding former NXP patents), against Intel; since the Mubadala acquisition, though, other Fortress litigation matters have seen a spike in activity (here and here).
RMS is represented by Caldwell Casady & Curry P.C. and Miller Fair Henry, PLLC. The new case has been assigned to Chief Judge Rodney Gilstrap. 12/23, Eastern District of Texas.
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