Exactojoin LLC v. OnePlus Technology Shenzhen Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ExactoJoin LLC (New Mexico)
  • Defendant: OnePlus Technology (Shenzhen) Co., Ltd. (China)
  • Plaintiff's Counsel: Rabicoff Law LLC
• Case Identification: 2:26-cv-00241, E.D. Tex., 03/24/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because the defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to compact semiconductor memory devices featuring a reduced number of contacts.
• Technical Context: The technology concerns the physical architecture of semiconductor memory cells, aiming to increase storage density by reducing the physical footprint of components.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or other procedural events related to the patent-in-suit.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 9,001,581 - "Compact semiconductor memory device having reduced number of contacts, methods of operating and methods of making,"

The Invention Explained

• Problem Addressed: The patent describes a need for semiconductor memory devices that are smaller and more compact than existing designs, such as conventional Dynamic Random-Access Memory (DRAM) which often relies on a one-transistor, one-capacitor (1T/1C) structure that is difficult to scale down '581 Patent, col. 1:55-65
• The Patented Solution: The invention proposes an integrated circuit comprising a "string or link" of multiple semiconductor memory cells connected in series '581 Patent, abstract Each cell uses a "floating body region" to store data as an electrical charge '581 Patent, col. 2:5-7 The key innovation is a structural design where the number of electrical contacts needed to connect the string of cells to a control line is less than the total number of memory cells, which serves to reduce the overall size of the memory array '581 Patent, abstract '581 Patent, col. 17:1-15
• Technical Importance: This architecture aims to improve memory density, a persistent goal in semiconductor design, by creating more compact memory arrays that require fewer physical connections.

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" but does not identify any specific asserted claims in the body of the complaint, instead incorporating them by reference from an unprovided exhibit Compl. ¶11 Compl. ¶16 For illustrative purposes, independent claim 1 is analyzed below.
• Independent Claim 1 includes the following essential elements:
  • A semiconductor memory device comprising a plurality of semiconductor memory cells.
  • At least one contact configured to electrically connect the memory cells to at least one control line.
  • The number of contacts is less than the number of memory cells.
  • The memory cells are configured to be electrically connected in series.
  • The memory cells are configured to perform injection or extraction of charge to maintain a state.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name Compl. ¶11 It refers to "Exemplary Defendant Products" that are purportedly identified in an exhibit that was not filed with the complaint Compl. ¶11 Compl. ¶16

Functionality and Market Context

The complaint does not provide any description of the functionality or features of the accused products. It alleges only that the "Exemplary Defendant Products practice the technology claimed by the '581 Patent" Compl. ¶16

IV. Analysis of Infringement Allegations

The complaint does not contain specific infringement allegations or claim charts. It states that "Exhibit 2 includes charts comparing the Exemplary '581 Patent Claims to the Exemplary Defendant Products" Compl. ¶16 As this exhibit was not provided, a detailed analysis of the infringement theory is not possible. The complaint's narrative theory is that the unspecified "Exemplary Defendant Products" satisfy all elements of the unspecified "Exemplary '581 Patent Claims" Compl. ¶16 No probative visual evidence provided in complaint.

• Identified Points of Contention: Given the lack of specific factual allegations, the initial points of contention will likely be procedural and foundational.
  • Evidentiary Questions: The primary question is which specific products are accused of infringement and what their internal semiconductor architecture is. The complaint's reliance on an unprovided exhibit leaves this entirely open.
  • Scope Questions: Once products are identified, a central issue may be whether their memory architecture constitutes cells "electrically connected in series" with a number of "contacts" that is "less than the number of said memory cells," as required by the patent.

V. Key Claim Terms for Construction

Because the complaint does not specify asserted claims, the following analysis is based on representative terms from independent claim 1 of the '581 Patent.

The Term: "at least one contact ... less than the number of said memory cells"

• Context and Importance: This limitation is the structural heart of the claim, defining the basis for the invention's claimed compactness. The interpretation of what constitutes a "contact" in this context and how the ratio is calculated will be critical to the infringement analysis.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is purely structural and quantitative. A party might argue that any electrical terminal connecting a string of cells to a control line that meets the numerical ratio falls within the claim's plain meaning.
  • Evidence for a Narrower Interpretation: The specification repeatedly illustrates this concept with specific "end-of-link" configurations where a single contact serves an entire string of cells '581 Patent, Fig. 16A '581 Patent, col. 17:7-15 A party may argue the term should be limited to these disclosed embodiments, where a contact is a discrete physical structure at the end of a series of memory cells.

The Term: "electrically connected in series"

• Context and Importance: This term defines the fundamental circuit layout of the memory cells. Whether an accused device's architecture meets this requirement will be a primary infringement question.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue this term encompasses any arrangement where the output of one cell effectively becomes the input for the next, allowing current to flow sequentially through the plurality of cells.
  • Evidence for a Narrower Interpretation: The detailed description and figures show memory cells formed adjacent to one another, sharing common conductive regions that link them in series '581 Patent, col. 17:7-12 A defendant might argue that the term requires this specific type of direct, physically adjacent series connection, rather than a more complex or indirect electrical arrangement.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users" to use the accused products in an infringing manner Compl. ¶14 The basis for this allegation is referenced in the unprovided Exhibit 2 Compl. ¶14

Willful Infringement

The complaint does not use the term "willful infringement." However, it asserts that service of the complaint provides Defendant with "Actual Knowledge of Infringement" Compl. ¶13 This allegation may form the basis for a claim of post-suit willful infringement. Plaintiff also requests that the case be declared "exceptional" under 35 U.S.C. § 285 Compl., Prayer E.i.

VII. Analyst's Conclusion: Key Questions for the Case

The complaint is minimal and relies on an unprovided exhibit, deferring nearly all substantive factual allegations. Consequently, the case will initially turn on fundamental discovery and definitional issues.

• A core issue will be one of identification: which of the Defendant's products are actually being accused of infringement, and what is their precise physical and electrical architecture? Without this information, which must be established through discovery, no substantive infringement analysis is possible.
• A second key question will be one of claim construction: how will the court define the structural limitations at the center of the invention, such as a "contact" and memory cells "electrically connected in series"? The outcome of claim construction will likely determine whether the architecture of the yet-to-be-identified accused products can be read on by the patent.
• A final evidentiary question will relate to scienter: can the Plaintiff develop evidence of pre-suit knowledge or specific intent to induce infringement, or will its claims for enhanced damages and fees be limited to conduct occurring after the filing of the lawsuit?