DRAM Antitrust Price Fixing Suit Alleges Memory Chip Supply Restrictions Amid AI Memory Boom

Complaint says decisions made in the AI memory market affected supply available to traditional computing markets.

A proposed class action filed by consumers and small business in the Northern District of California accuses Samsung Electronics, SK Hynix, and Micron Technology of conspiring to restrict supply in the market for conventional DRAM, or dynamic random access memory chips, allegedly causing dramatic price increases for consumers, businesses, and manufacturers. 

The lawsuit is the latest chapter in a market that has attracted antitrust scrutiny before. Plaintiffs note that Samsung, SK Hynix, and Micron collectively account for roughly 90% of global DRAM revenue and operate in a highly concentrated market with substantial barriers to entry. According to the complaint, the three firms generated approximately 91.5% of DRAM revenue as of the third quarter of 2025. 

Why is this DRAM antitrust suit focused on commodity memory and not HBM?

The complaint focuses on conventional or commodity DRAM, the standardized memory used in personal computers, servers, smartphones, gaming devices, and countless other electronic products. Plaintiffs distinguish this market from High Bandwidth Memory (HBM), a specialized form of memory used in artificial intelligence accelerators and other high-performance computing applications. 

According to the pleading, HBM and conventional DRAM draw from the same underlying manufacturing resources. Plaintiffs allege that the defendants collectively shifted manufacturing capacity toward HBM while restricting output of conventional DRAM products such as DDR4 and DDR5 memory. 

The complaint alleges that this shift was significant because HBM requires substantially more wafer capacity than conventional memory. Plaintiffs cite statements suggesting that production of one bit of HBM can displace the production of multiple bits of conventional DRAM. 

What is the conspiracy theory alleged in the DRAM antitrust litigation?

Unlike earlier DRAM litigation that focused primarily on rising prices, the new complaint attempts to identify a series of actions that plaintiffs characterize as evidence of a coordinated supply-restriction scheme.

According to the complaint, the alleged conspiracy began in late 2022 when all three manufacturers implemented production cuts during a market downturn. SK Hynix announced significant reductions in capital expenditures and production. Micron announced reductions in wafer starts. Samsung initially appeared poised to maintain output but subsequently announced what the complaint describes as a substantial production cut of its own. 

Plaintiffs contend that the alleged coordination continued through:

• Simultaneous production reductions beginning in 2022.
• A collective shift of manufacturing resources toward HBM products.
• The phased withdrawal from DDR3 and DDR4 production.
• A refusal to significantly expand conventional DRAM supply despite sharply rising prices.
• Similar customer-vetting practices allegedly adopted by all three manufacturers. 

The complaint repeatedly argues that these actions “taken together” demonstrate agreement rather than independent decision making. 

What is the most significant allegation in the proposed DRAM antitrust class action?

The most significant allegation may be what happened after demand recovered.

According to the complaint, DRAM prices increased approximately 171.8% year-over-year by the third quarter of 2025, rose another roughly 50% in the fourth quarter of 2025, and increased an additional 93%-98% quarter-over-quarter in the first quarter of 2026. Plaintiffs estimate a cumulative increase approaching 697% from the third quarter of 2024 through the first quarter of 2026. 

The complaint argues that, in a competitive market, such price increases would ordinarily stimulate additional production. Instead, plaintiffs allege that all three major suppliers continued to constrain conventional DRAM supply while directing investment toward HBM and other higher-value products. 

As the complaint puts it, “not one of the three Defendants expanded or announced plans to meaningfully expand commodity DRAM production capacity” despite what plaintiffs describe as unprecedented pricing signals. 

Why does finding the existence of an “agreement” versus “parallel conduct” matter in antitrust?

The central legal issue is likely to be whether the complaint plausibly alleges an agreement among competitors.

Antitrust law generally does not prohibit companies from responding in similar ways to similar market conditions. Firms operating in the same industry often make comparable business decisions when demand, costs, or technology change.

The challenge for plaintiffs is therefore not simply to show that Samsung, SK Hynix, and Micron behaved similarly. Rather, they must establish facts supporting the existence of concerted action rather than lawful parallel conduct. 

The complaint attempts to meet that burden by pointing to the combination of production cuts, capacity reallocations, DDR4 and DDR3 exits, alleged customer-order restrictions, and the defendants’ shared history in prior DRAM antitrust litigation. Plaintiffs also emphasize that all three firms continued to limit conventional DRAM supply even as prices rose dramatically. 

Whether those allegations are sufficient remains to be seen.

Why does the DRAM antitrust suit matter?

The lawsuit arrives at a time when demand for memory products is being reshaped by artificial intelligence, cloud infrastructure, and data-center expansion. The complaint itself portrays HBM and conventional DRAM as competing for scarce manufacturing resources and argues that decisions made in the AI memory market affected supply available to traditional computing markets. 

As a result, the case presents a question that extends beyond memory chips: when firms operating in a concentrated market make similar decisions in response to major technological shifts, at what point do those decisions become evidence of coordination rather than competition?

That question will likely determine whether the complaint survives the early stages of litigation.

Source: Garciaguirre et al. v. Samsung Electronics Co., Ltd., SK Hynix Inc., and Micron Technology, Inc., No. 5:26-cv-06345 (N.D. Cal. filed June 25, 2026). 

Edited by Tom Hagy, Editor-in-Chief, Mogin Law Blog. Send comments or questions to Info@MoginLawLLP.com.