Rambus has filed a complaint with the U.S. International Trade Commission (ITC) requesting the commencement of an investigation pertaining to Nvidia products. The complaint seeks an exclusion order barring the importation, sale for importation, or sale after importation of products that infringe nine Rambus patents from the Ware and Barth families of patents. The accused products include NVIDIA products that incorporate DDR, DDR2, DDR3, LPDDR, GDDR, GDDR2, and GDDR3 memory controllers, including graphics processors, and media and communications processors.

The complaint names Nvidia as a proposed respondent, as well as companies whose products incorporate accused Nvidia products and are imported into the United States. These respondents include: Asustek Computer Inc. and Asus Computer International, BFG Technologies, Biostar Microtech and Biostar Microtech International Corp., Diablotek Inc., EVGA Corp., G.B.T. Inc. and Giga-Byte Technology Co., Hewlett-Packard, MSI Computer Corp. and Micro-Star International Co., Palit Multimedia Inc. and Palit Microsystems Ltd., Pine Technology Holdings, and Sparkle Computer Co.

"We believe this action is necessary given Nvidia's continued willful infringement of our patents," said Tom Lavelle, senior vice president and general counsel at Rambus. "Rambus engineers and scientists have made tremendous contributions to the industry, and we need to protect our patented inventions on behalf of our shareholders and in fairness to our paying licensees."

Nvidia denies that it has infringed any of Rambus? patents and plans to cooperate with the ITC. The ITC is expected to decide whether to initiate an investigation under this complaint within 30 days.

In a separate action, Rambus filed a patent infringement suit against Nvidia in July 2008.