U.S. International Trade Commission Receives Complaint About DRAM Devices
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On November 17, 2025, the U.S. International Trade Commission (USITC) received a complaint about certain DRAM (Dynamic Random Access Memory) devices, products containing DRAM, and DRAM components. The complaint is known as Docket No. 3854.
The complaint was filed by Netlist, Inc. on September 30, 2025. Netlist, Inc. claims there have been violations of section 337 of the Tariff Act of 1930 (19 U.S.C. 1337). This law deals with unfair trade practices related to imported products.
The complaint names the following companies as respondents:
- Samsung Electronics Co., Ltd. of South Korea
- Samsung Electronics America, Inc. of Plano, TX
- Samsung Semiconductor, Inc. of Plano, TX
- Google LLC of Mountain View, CA
- Super Micro Computer, Inc. of San Jose, CA
Netlist, Inc. is asking the Commission to issue a limited exclusion order and cease and desist orders. It also requests that a bond be imposed on the respondents’ products during the 60-day Presidential review period under 19 U.S.C. 1337(j).
The USITC is asking for comments from the public, other interested parties, and government agencies about public interest issues related to the complaint. Some questions the Commission raised include:
- How are the DRAM devices and related products used in the United States?
- Are there any health, safety, or welfare concerns if the requested orders are issued?
- Are there similar products made in the United States that could replace the imported products?
- Can Netlist, its licensees, or others make enough of these products to meet the demand if imports are stopped?
- How would these orders impact U.S. consumers?
People who want to send written comments must do so within eight days after the notice is published in the Federal Register. Netlist, Inc. can reply to these comments within three days after the first comments are due. Comments must not be more than five pages, including attachments.
All filings must be electronic using the Commission’s Electronic Document Information System (EDIS) at https://edis.usitc.gov. No paper filings will be accepted at this time.
Anyone who wants to keep their submission confidential must request this in writing and follow the rules in 19 CFR 201.6. Confidential information may still be shared with certain government employees and contractors for official use.
This action follows the authority given by section 337 of the Tariff Act of 1930 and related rules.
Lisa Barton, Secretary to the Commission, issued this notice on November 13, 2025. The public version of the complaint is available online at https://edis.usitc.gov.
To contact the Commission with questions, call (202) 205-2000. For electronic filing help, email the Secretary as provided in the official notice.
All nonconfidential information will be available to the public on the EDIS website.
This notice provides all details for parties interested in participating in the investigation or submitting comments about the public interest.
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