A federal district court in California denied Sandisk Corporation and Western Digital Corporation’s motion to dismiss IPValue Management Inc. and Longitude Flash Memory Solutions Ltd.'s counterclaim alleging infringement of a patent directed to a method, circuit, and system for determining a reference voltage, in this action seeking a declaration of non-infringement of five patents. According to the court, IPValue provided factual allegations sufficient to articulate why it is plausible that the accused product infringes the patent claim.