Last week, an Eastern District of Texas jury returned a verdict awarding Netlist a combined $445M for the infringement of two memory patents by Micron Technology in one of several cases between these two parties. The jury also found the infringement to have been willful, but the bulk of its award corresponds to a patent claim that the Patent Trial and Appeal Board (PTAB) canceled last month through inter partes review (IPR). Meanwhile, a Central District of California jury has found both that a provision of a November 2015 Joint Development and License Agreement (JDLA) between Netlist and Samsung required the latter to supply certain products to Netlist “without limitation to” a joint development project between the two and that Samsung’s breach of that provision is material. These findings are key to a multifront patent infringement battle between Netlist and Samsung because the JDLA grants them cross-licenses to each other’s patent portfolios.