Radian developed and patented its innovative Symphonic Cooperative Flash Management technology to improve flash solid-state drives ("SSDs"), particularly for enterprise and data-center operations. Despite Radian's best efforts to participate in the market, Samsung and others iced Radian out of the industry. They did so in part by coalescing around key concepts of Radian's technology, including some of its patented inventions, and incorporating them into standardized specifications. Samsung was a top-tier member of NVM Express ("NVMe"), the organization in which these specifications were developed. It is also the organization that others in the industry tried to pressure Radian to join. Radian refused because NVMe's policies would have required Radian to give royalty-free licenses to any of its patented technology that was incorporated into the specifications. Now, Samsung markets and sells infringing NVMe SSDs, causing irreparable harm to Radian.