VLSI Technology v. Patent Quality Assurance: Federal Court Remands Memory Voltage Patent Dispute
VLSI Technology, LLC brought an infringement action against Patent Quality Assurance, LLC and individual defendant Joseph Uradnik over US7523373B2, a patent covering minimum memory operating voltage techniques. After 330 days, the Virginia Eastern District Court granted VLSI’s motion to remand, sending the case back to the Circuit Court for the City of Alexandria where it will continue.
Memory Voltage Patent Dispute Returned to Virginia State Court
VLSI Technology, LLC initiated this infringement action on 20 March 2024 in the Virginia Eastern District Court, asserting US7523373B2 — a patent covering minimum memory operating voltage techniques — against Patent Quality Assurance, LLC (PQA) and individual defendant Joseph Uradnik. The case sits at the intersection of patent enforcement and questions of proper forum, with VLSI challenging the defendants’ removal of the action to federal court.
On 13 February 2025, Judge M. Hannah Lauck granted VLSI’s motion to remand, ordering the case returned to the Circuit Court for the City of Alexandria. The federal court denied as moot all pending motions — including two motions to dismiss filed by Uradnik and PQA under Rules 12(b)(2) and 12(b)(6), and a motion to file a revised financial disclosure under seal — meaning no merits determination was reached in the federal proceedings.
The 330-day federal phase ended without any adjudication of infringement or validity, which is consistent with a disputed removal that lacked a sufficient federal jurisdictional basis. The remand suggests the defendants’ grounds for removal were found wanting, though the accompanying Memorandum Opinion would contain the full reasoning. The merits of the underlying patent infringement claims remain live and will now be litigated in Virginia state court.
Filing to Case Remanded in 330 days
330-day federal phase before remand to state court
Federal court remands to Alexandria: what the ruling means for both parties
Remand returns the case to its original state court forum
A remand order transfers a case back to the state court from which it was removed. The federal court found — for reasons detailed in the accompanying Memorandum Opinion — that federal jurisdiction was not properly established. Removal to federal court requires a valid jurisdictional basis; where that basis is absent or defective, the plaintiff’s motion to remand must be granted. No merits ruling was issued.
No federal merits decisionVLSI wins the forum battle; infringement claims survive
VLSI’s successful remand motion means its infringement claims under US7523373B2 continue in the Circuit Court for the City of Alexandria, the forum VLSI originally chose. The defendants’ 12(b)(2) and 12(b)(6) dismissal motions were denied as moot — so no challenge to personal jurisdiction or the legal sufficiency of VLSI’s claims was resolved against VLSI at the federal level.
Claims survive; state court proceedsDefendants’ removal strategy failed; face state court proceedings
PQA and Uradnik’s attempt to litigate in federal court was unsuccessful. Their pending motions to dismiss — which could have ended the case without a merits finding — were denied as moot, leaving them to defend the infringement action in Virginia state court. The failure to establish a removal basis also typically signals exposure to potential attorneys’ fee sanctions under 28 U.S.C. § 1447(c), though none is confirmed from the public record.
Removal strategy unsuccessfulMemory operating voltage patent remains active enforcement risk
The remand preserves US7523373B2 as an active assertion vehicle. Companies developing or deploying minimum memory operating voltage techniques should note that this patent has not been invalidated or found unenforceable. The return to state court may affect discovery dynamics and procedural timelines, but the underlying infringement claims are fully intact and will advance toward a merits determination.
Patent enforcement risk continuesFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | VLSI Technology, LLC | Company | Patent licensing entity — holder of US7523373B2 covering memory voltage techniquesSearch in Eureka ↗ |
| Defendant | Patent Quality Assurance, LLC | Company | Patent Quality Assurance, LLC and individual Joseph Uradnik; removed action to federal courtSearch in Eureka ↗ |
| Co-Defendant | Joseph Uradnik | Individual | Search in Eureka ↗ |
| Plaintiff counsel | Ellen D. Marcus | Attorney | Counsel for VLSI Technology, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Joshua Louis Solomon | Attorney | Counsel for VLSI Technology, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Michael Steven Schachter | Attorney | Counsel for VLSI Technology, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Steven Joseph Ballew | Attorney | Counsel for VLSI Technology, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Holmes Costin & Marcus, PLLC | Law Firm | Representing VLSI Technology, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Pollack Solomon Duffy LLP (MA-NA) | Law Firm | Representing VLSI Technology, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Willkie Farr & Gallagher LLP (NY-NA) | Law Firm | Representing VLSI Technology, LLCSearch in Eureka ↗ |
| Defendant counsel | Craig Crandall Reilly | Attorney | Counsel for Patent Quality Assurance, LLCSearch in Eureka ↗ |
| Defendant law firm | Law Office of Craig C. Reilly | Law Firm | Representing Patent Quality Assurance, LLCSearch in Eureka ↗ |
| Presiding judge | Judge M. Hannah Lauck | Judge | Virginia Eastern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s order is procedural rather than substantive: it grants remand and denies all pending motions as moot, without reaching the merits of infringement or the defendants’ jurisdictional and sufficiency challenges. The phrase ‘for the reasons stated in the accompanying Memorandum Opinion’ indicates a detailed written analysis of the removal defect exists but is not reproduced in the order itself. For both parties, the operative effect is clear — federal jurisdiction is extinguished, all federal motions are terminated, and the Circuit Court for the City of Alexandria resumes authority over the dispute.
US7523373B2 — Minimum Memory Operating Voltage Technique
US7523373B2, filed under application number US11/468458, covers a minimum memory operating voltage technique — a method or system for determining and applying the lowest reliable operating voltage for memory components. This class of technology is commercially significant in semiconductor design, where power efficiency and voltage margin optimisation directly affect device performance and battery life. The patent’s claims define boundaries around voltage management approaches that are foundational to modern memory subsystem design.
For semiconductor IP portfolios, memory operating voltage patents occupy a strategically valuable position: they sit at the intersection of power management and memory architecture, two areas subject to continuous competitive pressure. VLSI Technology’s assertion of this patent against PQA and Uradnik — rather than a product manufacturer — suggests a complex enforcement or counterclaim dynamic that the state court proceedings will need to resolve. Companies designing low-power memory controllers or SoC memory interfaces should assess their exposure against this patent’s claim scope.
Should you run an FTO against US7523373B2?
Any R&D team developing products that implement minimum memory operating voltage techniques — including low-power DRAM controllers, embedded memory subsystems, or voltage-scaling memory interfaces — should evaluate whether their implementations fall within the claim scope of US7523373B2. The patent remains enforceable and is actively asserted. With no invalidity ruling on record at the federal level, the risk profile has not diminished from the public proceedings.
PatSnap Eureka’s FTO Search Agent can map the claim language of US7523373B2 against your product architecture, identify prior art that could support a design-around or IPR petition, and flag related family members or continuation applications. Given that this dispute is now proceeding in Virginia state court — where patent-specific procedural tools are less standardised — a proactive FTO analysis conducted before any licensing demand or litigation posture solidifies is strongly advisable.
Run a freedom-to-operate analysis on US7523373B2 to assess your product’s exposure
Run FTO in Eureka →Similar Memory Voltage Patent Infringement Cases in US District Courts
Cases involving memory operating voltage patents and removal/remand disputes in Virginia federal courts, with comparable non-practicing entity enforcement dynamics.
What this case signals for the semiconductor memory IP landscape
A successful remand preserves VLSI’s chosen forum and keeps a key memory voltage patent in active play.
Forum selection remains a live battleground in patent enforcement
Defendants in patent cases frequently remove to federal court to access Article III judges and federal patent law procedures. When removal is successfully challenged — as here — the case returns to state court with no merits decided. Companies asserting patents should anticipate removal attempts and prepare remand arguments proactively, particularly where the defendant’s jurisdictional basis is thin.
US7523373B2 has survived federal proceedings without validity challenge
Neither an IPR nor a federal invalidity ruling has resolved the status of this patent. The mootness of the 12(b)(6) motion means the legal sufficiency of VLSI’s infringement theory was never tested at the federal level. Competitors working with minimum memory operating voltage techniques should treat this patent as an active enforcement risk pending the state court outcome.
VLSI v Patent — key questions answered
The court granted VLSI Technology’s motion to remand, returning the case to the Circuit Court for the City of Alexandria. It denied all pending motions — including two 12(b)(6)/12(b)(2) motions to dismiss — as moot. No merits determination on patent infringement or validity was reached in the federal proceedings.
US7523373B2 is a US patent covering a minimum memory operating voltage technique. It relates to methods or systems for determining and applying the lowest reliable operating voltage for memory components — a technology relevant to low-power semiconductor and memory subsystem design. Application number is US11/468458.
The court found that the defendants had not established a sufficient basis for federal jurisdiction to sustain their removal of the action. The detailed reasoning is contained in the accompanying Memorandum Opinion referenced in the order. Without a valid removal basis, the case was required to return to its original state court forum in Alexandria, Virginia.
The infringement claims under US7523373B2 remain live and will proceed in the Circuit Court for the City of Alexandria. The defendants’ motions to dismiss were denied as moot — meaning no challenge to personal jurisdiction or claim sufficiency was resolved — so VLSI’s infringement theory advances without federal-level dismissal.
Patent Quality Assurance, LLC is a named defendant alongside individual Joseph Uradnik. The entity’s name and structure are consistent with a patent assertion or quality-review entity. Its exact role — whether as an accused infringer, a challenger to VLSI’s patent, or another participant — will be more fully resolved in the ongoing state court proceedings. The public federal record does not disclose its business operations.
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