China’s top DRAM maker CXMT sues Pentagon over its blacklisting — argues chips are standard civilian JEDEC spec, not defense hardware

China’s leading DRAM producer ChangXin Memory Technologies (CXMT) has filed a lawsuit against the U.S. Department of Defense in an attempt to overturn its classification as a company linked to China’s military, Reuters reports. CXMT claims that it has no connection to the Chinese People’s Liberation Army, and argues that the Pentagon’s decision lacks supporting evidence, violated due-process requirements, and has damaged both its business and reputation.

The Pentagon initially classified CXMT as a Chinese military company in January 2025, when Joe Biden was the president. The Trump administration subsequently maintained the designation when the Defense Department updated the list in June. CXMT says it spent more than a year supplying information to the Defense Department in an attempt to overturn the classification and remove itself from the list.

The company claims the DoD published a notice in February indicating that CXMT would be taken off the list but withdrew that notice later the same day without any explanation. In June, the Pentagon classified CXMT as ‘directly affiliated with MIIT and indirectly affiliated with SASAC and MIIT.’ MIIT is China’s Ministry of Industry and Information Technology, whereas SASAC is the State-owned Assets Supervision and Administration Commission of the State Council, an organization that formally owns the government’s stakes in non-financial state-owned enterprises.

While CXMT memory can certainly be found in systems used by the PLA or China’s secret services, this does not automatically make CXMT a direct supplier to these entities and therefore does not prove that CXMT is a Chinese military company.

CXMT points out the Pentagon’s original motivation to include the DRAM maker in its list was a remarkably weak-looking ‘military grade’ argument. According to the complaint, DoD’s 2024 report said CXMT contributed to China’s defense industrial base partly because its DRAM is dual-use and cited an advertisement describing CXMT products as ‘military grade.’ CXMT says that advertisement came from an unauthorized distributor, which later admitted the characterization was erroneous.

In addition, CXMT claims that its DRAM products conform to JEDEC commercial standards and lack the requirements imposed on Chinese military-grade semiconductor components involving areas such as temperature, packaging, testing, and military oversight. Also, it says that should its products be made in the U.S., they would be classified as for ‘purely civilian uses’ and that it ‘does not hold any licenses to manufacture products for military use.’

Inclusion on the Pentagon’s list of companies linked to the Chinese military can result in restrictions involving U.S. government contracts, something that CXMT barely seeks. But more importantly, it can affect a company’s commercial relationships (as many companies do not want to be affiliated with companies linked to the Chinese military) and reputation. Indeed, CXMT claims that since January 2025 the designation has continuously hurt it commercially and reputationally, and that the lawsuit is intended to protect its business interests.