Palisade Technologies, LLP v. Micron Technology, Inc.
7:24-cv-00262
W.D. Tex.Jul 24, 2025Background
- Palisade Technologies, LLP sued Micron Technology, Inc. and related entities for alleged direct, willful, and induced infringement of five patents related to semiconductor technology.
- Micron moved to dismiss certain infringement claims under Fed. R. Civ. P. 12(b)(6), arguing that Palisade's amended complaint failed to sufficiently plead direct infringement of one patent ('962), as well as all pre- and post-suit willful and induced infringement claims.
- Palisade argued its pleadings were sufficient but requested leave to amend if additional detail was required to meet the legal standard.
- The magistrate judge reviewed both parties’ briefing and considered applicable pleading standards for patent infringement claims, including requirements for alleging knowledge and intent.
- The court ultimately recommended granting in part and denying in part the motion to dismiss, ordered Palisade to file a redacted second amended complaint, and dismissed certain claims (pre-suit willful and induced infringement) without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of direct '962 patent claim | Complex tech, thus less detail required at pleading stage | Complaint merely parrots patent language; no specific mapping | Claim insufficient; leave to amend granted |
| Pre-suit willful infringement | Knowledge established by USPTO examiner citation | Citation during unrelated patent prosecution is insufficient | Insufficient; dismissed without prejudice |
| Post-suit willful infringement | Complaint provides notice required for post-suit claims | No egregious conduct shown | Sufficient at pleading stage; motion denied |
| Pre-suit induced infringement | Knowledge based on examiner citation | No pre-suit knowledge adequately alleged | Insufficient; dismissed without prejudice |
| Post-suit induced infringement | Sufficiently alleges inducement by subsidiaries/customers | Generic sales/marketing do not establish required intent | Sufficient; motion denied |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for plausibility under Rule 12(b)(6))
- Halo Elecs. Inc. v. Pulse Elecs. Inc., 579 U.S. 93 (requirement to plausibly allege subjective willfulness for enhanced patent damages)
- Bowlby v. City of Aberdeen, 681 F.3d 215 (allegations must go beyond conclusory assertions at the motion to dismiss stage)
- Kaiser Aluminum & Chem. Sales v. Avondale Shipyards, Inc., 677 F.2d 1045 (facts must be viewed in light most favorable to plaintiff when ruling on motion to dismiss)
- Lifetime Indus., Inc. v. Trim-Lok, Inc., 869 F.3d 1372 (notice pleading and intent standards for patent infringement and inducement claims)