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Memory Integrity, LLC v. Intel Corp.

Citations: 178 F. Supp. 3d 1022; 2016 U.S. Dist. LEXIS 48875; 2016 WL 1441655Docket: Case No. 3:15-cv-00262-SI

Court: District Court, D. Oregon; April 12, 2016; Federal District Court

Narrative Opinion Summary

This case involves a dispute between Intel Corporation and Memory Integrity, LLC over patent infringement claims related to cache coherence technologies in multiprocessor systems. The conflict arises from a covenant not to sue, originally established between Intel and Sanmina-SCI Corporation, which Memory Integrity assumed after purchasing patents from Sanmina. The central legal issue revolves around the enforceability of this covenant under Delaware law, which governs the agreement. Intel moved for summary judgment, asserting the covenant bars Memory Integrity's claims. The court addressed the potential ambiguity of the term 'CSI Patent Claim' within the agreement and determined it was unambiguous and enforceable. Furthermore, the court evaluated whether the disclosed information qualified as confidential 'CSI Enabling Information' at the time of disclosure, concluding it did and thus upheld the covenant's applicability. The court granted Intel's motion for summary judgment, finding no genuine disputes of material fact, thus preventing Memory Integrity from pursuing its infringement claims. Consequently, the court ruled in favor of Intel, affirming the protection offered by the covenant not to sue against Memory Integrity's assertions.

Legal Issues Addressed

Confidentiality and Disclosure Obligations

Application: Intel's disclosures to Sanmina were deemed confidential at the time, maintaining the covenant not to sue's enforceability despite claims of public knowledge.

Reasoning: Intel maintains that even if the information became public later, the covenant not to sue applies as long as it was confidential when disclosed.

Covenant Not to Sue under Contract Law

Application: The covenant not to sue, assumed by Memory Integrity from Sanmina, prohibits infringement claims against Intel for disclosed technologies.

Reasoning: Intel contends that the covenant not to sue, which Memory Integrity assumed from Sanmina, prohibits the claims.

Interpretation of Contractual Ambiguity under Delaware Law

Application: The court examines whether the ISA is ambiguous regarding the term 'CSI Patent Claim' and concludes it is not, thus enforceable.

Reasoning: The Court concludes that the term is unambiguous and thus does not render the ISA unenforceable.

Objective Theory of Contracts

Application: The ISA must be interpreted based on what an objective, reasonable third party would understand, confirming its enforceability.

Reasoning: The objective theory of contracts applies—interpretations should reflect what an objective, reasonable third party would understand.

Summary Judgment Standards

Application: Summary judgment is appropriate as Intel has demonstrated no genuine dispute of material facts regarding the enforceability of the covenant not to sue.

Reasoning: The court notes that summary judgment is appropriate when there is no genuine dispute of material fact.