Radian Memory Systems v. Samsung: 7 Flash Storage Patents, Dismissed Without Prejudice
Radian Memory Systems LLC filed a 7-patent infringement action against Samsung Electronics in the Eastern District of Texas, targeting NAND flash management technologies including cooperative flash management, bad block handling, and geometry emulation. After 364 days of litigation, the parties jointly stipulated to dismiss all claims without prejudice — leaving every dispute legally unresolved.
Seven NAND Patents, One Joint Exit: Reading Radian v. Samsung
On 23 December 2024, Radian Memory Systems LLC filed suit against Samsung Electronics Co., Ltd. in the Eastern District of Texas (Case No. 2:24-cv-01073) before Judge Rodney Gilstrap, asserting infringement of seven U.S. patents covering advanced NAND flash memory management. The asserted patents span cooperative flash management, subdivision-based addressing, geometry emulation, bad block remapping, and host-address-space management — technologies central to how modern SSDs and NAND controllers handle write, erase, and maintenance operations.
Exactly 364 days after filing, on 22 December 2025, the parties filed a Joint Stipulation and Motion to Dismiss All Claims and Defenses. Judge Gilstrap granted the motion in full. All claims and defenses were dismissed without prejudice, meaning no infringement finding, no invalidity ruling, and no damages determination entered against either side. The dismissal without prejudice preserves Radian’s right to refile the same claims, subject to any applicable statutes of limitations.
The speed and joint nature of the resolution — just under one year, well before any Markman hearing or trial date — suggests the parties may have reached a confidential commercial arrangement, though the public record is silent on any licensing terms. No fee-shifting motion was filed, consistent with an amicable resolution. What drove Samsung and Radian to this exit point, and whether Radian’s flash management portfolio has now been licensed to Samsung, remains undisclosed.
Filing to Dismissed without Prejudice in 364 days
364 days — near the median E.D. Tex. first-instance lifespan before trial
Dismissed without prejudice: what the joint exit means for both parties
Without prejudice dismissal keeps every door open
A dismissal without prejudice under Federal Rule of Civil Procedure 41 means no merits determination was made. The court entered no infringement finding, no invalidity ruling, and no damages award. Radian retains the legal right to reassert all seven patents against Samsung or any other defendant, provided the applicable six-year damages window under 35 U.S.C. § 286 allows it. The patents remain in force and fully enforceable.
No merits ruling enteredRadian’s portfolio survives intact — refiling remains possible
Radian Memory Systems exits with its seven-patent flash management portfolio legally unimpaired. No claim was invalidated, no prosecution history disclaimer was created by litigation positions, and no adverse claim construction ruling binds future proceedings. Radian could refile against Samsung or assert the same patents against other NAND manufacturers. The public record does not confirm whether a licensing deal was reached, but the joint nature of the dismissal is consistent with that outcome.
Portfolio legally intactSamsung avoids an adverse ruling — but faces no preclusion shield
Samsung Electronics avoids any finding of infringement and any damages exposure from this case. However, the without-prejudice dismissal provides no estoppel protection: Samsung cannot rely on this outcome as a defense if Radian refiles. Samsung also did not obtain invalidity rulings on any of the seven asserted patents. If no license was secured, Samsung’s NAND products remain potentially exposed to the same IP claims in a future action.
No invalidity ruling obtainedFlash storage IP enforcement risk persists across the sector
Radian’s portfolio covers foundational NAND flash management concepts — cooperative management, geometry emulation, bad block remapping — that are broadly relevant to SSD controllers and NAND-based storage products. The without-prejudice outcome means these patents remain live enforcement tools. Other NAND manufacturers — including those whose products implement similar flash translation layer and subdivision management architectures — should treat this portfolio as an active risk and consider FTO analysis.
Live enforcement risk remainsFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | RADIAN MEMORY SYSTEMS LLC | Company | NAND flash IP licensing entity — holder of US11347656B1 and 6 related storage patentsSearch in Eureka ↗ |
| Defendant | Samsung Electronics Co., Ltd. | Company | Samsung Electronics Co., Ltd. — global semiconductor and SSD manufacturerSearch in Eureka ↗ |
| Plaintiff counsel | Adrienne Roberts Dellinger | Attorney | Counsel for RADIAN MEMORY SYSTEMS LLCSearch in Eureka ↗ |
| Plaintiff counsel | Alexander Joseph Gras | Attorney | Counsel for RADIAN MEMORY SYSTEMS LLCSearch in Eureka ↗ |
| Plaintiff counsel | Andrea Leigh Fair | Attorney | Counsel for RADIAN MEMORY SYSTEMS LLCSearch in Eureka ↗ |
| Plaintiff counsel | Andrew Thomas Langford | Attorney | Counsel for RADIAN MEMORY SYSTEMS LLCSearch in Eureka ↗ |
| Plaintiff counsel | Austin Curry | Attorney | Counsel for RADIAN MEMORY SYSTEMS LLCSearch in Eureka ↗ |
| Plaintiff counsel | Bradley Wayne Caldwell | Attorney | Counsel for RADIAN MEMORY SYSTEMS LLCSearch in Eureka ↗ |
| Plaintiff counsel | Hamad M. Hamad | Attorney | Counsel for RADIAN MEMORY SYSTEMS LLCSearch in Eureka ↗ |
| Plaintiff counsel | Jason Dodd Cassady | Attorney | Counsel for RADIAN MEMORY SYSTEMS LLCSearch in Eureka ↗ |
| Plaintiff law firm | Caldwell Cassady Curry PC | Law Firm | Representing RADIAN MEMORY SYSTEMS LLCSearch in Eureka ↗ |
| Plaintiff law firm | Miller Fair Henry PLLC | Law Firm | Representing RADIAN MEMORY SYSTEMS LLCSearch in Eureka ↗ |
| Defendant counsel | Arian Joseph Koochesfahani | Attorney | Counsel for Samsung Electronics Co., Ltd.Search in Eureka ↗ |
| Defendant counsel | Kevin Hardy | Attorney | Counsel for Samsung Electronics Co., Ltd.Search in Eureka ↗ |
| Defendant counsel | Lance Lin Yang | Attorney | Counsel for Samsung Electronics Co., Ltd.Search in Eureka ↗ |
| Defendant counsel | Melissa Richards Smith | Attorney | Counsel for Samsung Electronics Co., Ltd.Search in Eureka ↗ |
| Defendant counsel | Sean S. Pak | Attorney | Counsel for Samsung Electronics Co., Ltd.Search in Eureka ↗ |
| Defendant law firm | Gillam & Smith, LLP | Law Firm | Representing Samsung Electronics Co., Ltd.Search in Eureka ↗ |
| Defendant law firm | Quinn Emanuel Urquhart & Sullivan LLP (San Francisco) | Law Firm | Representing Samsung Electronics Co., Ltd.Search in Eureka ↗ |
| Defendant law firm | Quinn Emanuel Urquhart & Sullivan, LLP | Law Firm | Representing Samsung Electronics Co., Ltd.Search in Eureka ↗ |
| Defendant law firm | Quinn Emanuel Urquhart & Sullivan, LLP (DC) | Law Firm | Representing Samsung Electronics Co., Ltd.Search in Eureka ↗ |
| Defendant law firm | Quinn Emanuel Urquhart & Sullivan LLP (LA) | Law Firm | Representing Samsung Electronics Co., Ltd.Search in Eureka ↗ |
| Presiding judge | Judge Rodney Gilstrap | Judge | Texas Eastern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s order reflects a purely procedural grant of a joint stipulation — no infringement finding, no claim construction, and no validity ruling were issued. The phrase ‘dismissed without prejudice’ is legally significant: it resets the docket entirely, leaving Radian free to refile the same seven patents against Samsung or any other party. The joint nature of the motion, with both plaintiff and defendant as co-movants, is procedurally unusual and typically indicates that the commercial dispute underlying the litigation has been resolved privately, though the record provides no confirmation of this.
US11347656B1 — Cooperative NAND Flash Management & Subdivision Addressing
The seven asserted patents — US11347656B1, US11740801B1, US11307995B1, US11681614B1, US11709772B1, US11347657B1, and US11544183B1 — collectively cover a range of NAND flash memory management innovations filed between 2020 and 2022. The portfolio addresses core SSD controller challenges: how a storage device’s controller coordinates write, erase, and maintenance operations across subdivisions of NAND flash, how bad blocks are remapped transparently to the host, and how geometry emulation allows a storage device to present a logical address space that abstracts underlying physical NAND organisation.
Strategically, this portfolio targets the flash translation layer (FTL) and NAND management stack — the software and firmware layer inside virtually every modern SSD and embedded flash storage device. Patents in this space carry broad potential relevance across enterprise SSDs, mobile NAND storage, and cloud storage infrastructure. For NAND controller vendors and SSD OEMs, the cooperative flash management and subdivision-addressing claims are particularly significant, as these concepts are foundational to achieving high endurance and performance in multi-plane NAND architectures.
Should your team run an FTO against Radian Memory Systems’ flash portfolio?
Any organisation designing or procuring SSD controllers, NAND flash firmware, or embedded storage devices that implement subdivision-based addressing, cooperative flash management, bad block remapping, or geometry emulation should treat these seven patents as a priority FTO target. The portfolio is actively enforced — this case confirms Radian’s willingness to litigate in E.D. Tex. — and the without-prejudice dismissal means the patents remain live. NAND manufacturers, SSD OEMs, and hyperscalers with custom storage silicon are all in scope.
PatSnap Eureka’s FTO Search Agent can map each of Radian’s seven asserted patents against your product’s NAND management architecture, flagging claim elements most likely to read on your implementation. Eureka’s claim-by-claim analysis surfaces design-around options and identifies prior art that may support validity challenges — giving your IP and engineering teams a defensible position before any enforcement action reaches your docket.
Run a freedom-to-operate analysis on US11347656B1 to assess your product’s exposure
Run FTO in Eureka →Similar NAND Flash Patent Infringement Cases in E.D. Texas
Browse comparable flash memory and SSD patent infringement actions litigated before Judge Gilstrap in the Eastern District of Texas.
What Radian v. Samsung signals for the NAND flash IP landscape
A joint exit after 364 days with no merits ruling typically signals a licensing resolution — or a strategic pause before renewed enforcement.
Joint without-prejudice exits in E.D. Tex. often mask licensing deals
When both parties jointly move to dismiss without prejudice this early in litigation — before claim construction — it strongly suggests a confidential commercial resolution. Patent monetisation entities like Radian routinely structure settlements as non-exclusive licences, preserving the portfolio for future enforcement against other industry players. Competitors should not interpret this dismissal as a signal that the patents are weak.
Seven-patent assertion scope signals a licensing programme, not a single dispute
Asserting seven patents across multiple flash management architectures in a single complaint is consistent with a licensing-programme strategy. Radian’s portfolio breadth — spanning addressing, bad block management, geometry emulation, and cooperative management — suggests a systematic effort to capture royalties across the NAND SSD supply chain. NAND controller vendors, SSD OEMs, and hyperscalers sourcing NAND-based storage should assess exposure.
RADIAN v Samsung — key questions answered
The without-prejudice dismissal means no merits determination was made. No infringement finding, invalidity ruling, or damages award was entered. Radian retains the right to refile the same seven patents against Samsung or other defendants. Samsung received no estoppel protection or invalidity ruling. The dismissal was joint, suggesting a private resolution, though no licensing terms appear in the public record.
Radian asserted seven U.S. patents: US11347656B1, US11740801B1, US11307995B1, US11681614B1, US11709772B1, US11347657B1, and US11544183B1. The patents cover NAND flash management technologies including cooperative flash management, subdivision-based addressing, geometry emulation, bad block remapping, and host-address-space management for non-volatile storage devices.
The case was dismissed after 364 days — before any Markman hearing on record — by joint stipulation of both parties. Early joint dismissals in E.D. Tex. patent cases typically indicate a confidential licensing or settlement agreement, though the public record does not confirm this. No fee motions or sanctions were filed, which is consistent with an amicable commercial resolution rather than a procedural failure by either side.
Yes, the risk persists. The without-prejudice dismissal means all seven patents remain enforceable. The portfolio targets fundamental NAND flash management techniques — cooperative flash management, subdivision addressing, geometry emulation — that are broadly implemented across the SSD industry. Other NAND manufacturers including SK Hynix, Micron, and Kioxia, as well as SSD OEMs and custom silicon designers, should assess their exposure through FTO analysis.
Radian Memory Systems was represented by Caldwell Cassady Curry PC and Miller Fair Henry PLLC, with attorneys including Bradley Wayne Caldwell, Jason Dodd Cassady, and Austin Curry. Samsung was represented by Quinn Emanuel Urquhart & Sullivan LLP across multiple offices and Gillam & Smith LLP, with attorneys including Sean S. Pak, Lance Lin Yang, and Melissa Richards Smith.
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