Samsung and Taiwan Semiconductor filed separate actions for declaratory judgment against Keranos [NPE] and United Module [NPE] over three patents related to flash memory and split-gate EPROM.  These cases are transfers from the Northern District of California.  The patents-in-suit are owned by United Module, but Keranos owns exclusive enforcement rights.  In 2010, Keranos filed suit over these patents against 28 defendants including Intel, NEC, Qualcomm, and Freescale. Since then, Keranos and United Module have been the subject of several declaratory judgment actions.  Keranos is controlled by Nicholas and Anthony Gross, who also manage Media Queue, LLC and WordCheck Tech, LLC. 7/21, Eastern District of Texas, 2:2011cv00331; 2:2011cv00333.