Editing Openai/69569a57-79cc-8000-bf7e-5d4a3e894d0c (section)

==== 2. Samsung: why discovery is existentially sensitive ====

===== A. Samsung’s exposure is architectural, not product-specific =====

In an ITC case, Samsung is not just producing:
* Product datasheets
* Marketing materials

They must produce:
* DRAM controller designs
* Rank multiplication logic
* Load-reduction mechanisms
* Command/address buffering
* Timing coordination logic

These are core architectural trade secrets — not easily compartmentalized.

Once disclosed (even under HC-AEO):
* Netlist’s experts understand exactly how infringement scales
* It becomes clear whether infringement spans: - DDR4 - DDR5 - LRDIMM - RDIMM - HBM-adjacent designs

This creates portfolio-wide exposure, not “one bad SKU.”

===== B. Samsung’s supply-chain discovery problem =====

Netlist subpoenas inevitably reach:
* Foundries
* Controller IP vendors
* Module assemblers
* OEM customers (directly or indirectly)

Even if Samsung itself complies perfectly:
* Third-party documents can corroborate infringement
* Or expose design intent, which is devastating

Protective orders do not stop corroboration.

===== C. Why Samsung settles early (historically) =====

Samsung’s calculus often becomes:

: “Do we want multiple outside experts to permanently understand how our memory architecture works?”

Even if sealed forever, the answer is often no.