The alleged co-conspirators, Samsung, Micron, and Hynix, are the three companies that control nearly one-hundred percent of the DRAM market. Defendants1 are the world’s largest manufacturers of DRAM, collectively controlling 96% of worldwide DRAM market share as of mid2017.

Defendants combined and contracted to fix, raise, maintain, or stabilize the prices at which DRAM was sold in the United States from at least June 1, 2016 to February 1, 2018 (the “Class Period”). Defendants’ conspiracy artificially inflated prices for DRAM throughout the supply chain that were ultimately passed through to Plaintiffs and the Class, causing them to pay more for DRAM Products than they otherwise would have absent Defendants’ conspiracy.

Prior to entering into the conspiracy, Defendants acted independently in deciding how to balance supply (and capacity) to meet industry demand for DRAM. Acting independently, firms sought to gain market share though increases in their supply.

Class action lawsuit - https://www.hbsslaw.com/uploads/case_downloads/dram2/2018-04-27_dram_class_action_complaint.pdf