Judge Albright Grants Stay Pending Resolution of Inter Partes Review in Sonrai Memory Ltd. v. Western Digital Techs., Inc.

On August 4, 2022, Judge Albright granted stay pending resolution of the inter partes review in the case of Sonrai Memory Limited v. Western Digital Technologies, Inc. This action alleges that Western Digital Technologies, Inc. (Western Digital) infringed three patents belonging to Sonrai Memory Limited (Sonrai). Less than two months after Sonrai filed this action, Western Digital began petitioning the Patent Trial and Appeal Board for IPRs of the three patents.

In its analysis, the Court considered three factors. The Court found that the stage of the proceedings factor weighed against granting a stay because this action was at an advanced stage. The Court also found that the second factor–undue prejudice upon non-movant–weighed against granting a stay. However, the Court concluded that the simplification-of-issues factor overwhelmed the other two factors. In its analysis of this factor, the Court emphasized the PTAB decision, which concluded that Western Digital sufficiently demonstrated a reasonable likelihood of success of prevailing in its invalidity contentions. Therefore, after reiterating that the simplification-of-issues is the most important factor to consider, the Court granted a stay.