Micron Technology v. Rambus Inc.

What happened

Rambus Inc. developed and licensed DRAM memory interface technology and anticipated that patent licensing disputes with manufacturers were likely. Between 1998 and 2000, Rambus conducted an internal document shredding programme, dubbed "Shred Days", that systematically destroyed internal documents that it knew would be relevant to anticipated litigation. The destruction included engineering notebooks, internal communications and technical records. When the patent disputes ultimately materialised, Micron Technology and other manufacturers argued that the deliberate destruction of evidence rendered Rambus's patents unenforceable under the doctrine of spoliation. After seven years of litigation across multiple courts, the Federal Circuit found Rambus's conduct sufficient to support an unenforceability finding. A $250 million sanction was imposed in the Hynix proceedings. The case is the canonical example of how a systematic records destruction programme, even one executed years before litigation commenced, can ultimately undermine the entire patent portfolio it was designed to protect.