A US federal appeal court has reversed rulings from a Virginia trial court against Rambus in its case against Infineon Technologies.

A US federal appeal court has reversed rulings from a Virginia trial court
against Rambus in its case against Infineon Technologies. The ruling
concludes that the US company abided by JEDEC rules and did not commit
fraud. In particular, the original trial court decision on fraud relating to
JEDECs synchronous DRAM (SDRAM) standard was reversed. A post trial motion
set aside a finding of fraud relating to double data rate (DDR) SDRAM.
According to the decision, Rambus alleges that Infineon admitted at trial
that the disputed patents were not related to the SDRAM standard. "If Rambus
is correct, this assertion further shows that no SDRAM manufacturer
following the JEDEC standard would need a license under any of Rambuss
undisclosed patents or applications," according to the decision. Despite
this argument, Infineon did not directly address Rambuss arguments. Rather
than deny Rambuss assertions, Infineon only responded that "Rambus
argument is, at best, disingenuous, since . . . documents amply demonstrate
that Rambus believed its pending patents covered the SDRAM standard."
The decision comments: "In effect, Infineon argues that Rambuss mistaken
belief that its claims read on the SDRAM standard made its actions
fraudulent. In other words, Infineon would expand the EIA/JEDEC patent
policy to add a subjective belief component to the disclosure duty." The
appeals court did not accept such a duty premised on subjective beliefs.

JEDECs disclosure duty is an objective standard, "otherwise the standard
would exempt a member from disclosure, if it truly, but unreasonably,
believes its claims do not cover the standard".
"The record shows that Rambuss claimed technology did not fall within the
JEDEC disclosure duty. The record shows at most that Rambus wanted to obtain
claims covering the SDRAM standard. Some of that evidence does not put
Rambus in the best light. Rambus thought it could cover the SDRAM standard
and tried to do so while a member of an open standards-setting committee.
While such actions impeach Rambuss business ethics, the record does not
contain substantial evidence that Rambus breached its duty under the
EIA/JEDEC policy.

"If evidence of Rambus violating its duty to disclose exists, Infineon did
not place it in the record or provide it to this court. Infineon bore the
burden of proving the existence of a disclosure duty and a breach of that
duty by clear and convincing evidence. Infineon did not meet that burden."