The US Court of Appeals for the DC Circuit overturns an FTC’s ruling in the computer memory market for failing to prove unlawful monopolization (Rambus)

The Court of Appeals for the District of Columbia Circuit has overturned the Federal Trade Commission’s ruling against Rambus, Inc. (“Rambus”), finding that the Commission did not prove that Rambus’s failure to disclose certain intellectual property interests to a standard-setting organization (“SSO”) allowed Rambus to monopolize the relevant technology markets. The court also expressed concerns about the sufficiency of the FTC’s evidence regarding the SSO’s disclosure policies and Rambus’s alleged violation of those policies. Background Rambus is a developer of computer memory that licenses intellectual property rights to manufacturers. In 1990, Rambus filed a patent application for a faster architecture for dynamic random access memory (“DRAM”), and thereafter filed various