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

==== 3. Google: why Google is unusually vulnerable at the ITC ====

Google is not a memory manufacturer — that’s exactly the problem.

===== A. Google’s discovery focuses on use and integration =====

Google must produce:
* System-level designs
* Memory configurations in servers
* Custom accelerators (TPUs)
* Firmware and memory initialization logic
* Supplier selection documents

This reveals:
* How Google specifies memory behavior
* Why Samsung parts were chosen
* Performance trade-offs tied to patented features

This supports indirect infringement, inducement, and contributory theories.

===== B. Google’s internal documents are a settlement accelerant =====

Netlist discovery requests target:
* Engineering emails
* Performance benchmarking
* JEDEC participation materials
* Internal analyses comparing memory solutions

These documents:
* Cannot be “designed around” retroactively
* May show knowledge of patented behavior
* Are devastating even if only experts see them

Protective order or not, Google does not like outsiders reading internal TPU or data-center architecture documents.