Membership in Standards Setting Organization Did Not Restrict Pending or Future Patent Rights

Plaintiff's infringement claims were not barred by equitable estoppel, based on plaintiff's participation in industry standards setting organization. "Although [defendants] did offer some evidence supporting an obligation by JEDEC members to make disclosures concerning their patents relevant to any standard being considered, the evidence was not persuasive that there was any understanding among members that they had to disclose pending patent applications or the intent to file such applications. The jury specifically found that JEDEC members did not share a clearly defined expectation that such disclosures would be made."

Rambus Inc. v. Micron Technology Inc., 5-06-cv-00244 (CAND March 3, 2009, Findings of Fact & Conclusions of Law)