ChangXin Memory Technologies (CXMT), China’s largest producer of dynamic random-access memory (DRAM) chips, has taken legal action to overturn its classification by the U.S. Department of Defense as a company that aids the Chinese military. In a complaint filed in the U.S. District Court for the District of Columbia, CXMT asked the court to set aside the designation and to remove the company from the Pentagon list that can prompt government contracting limitations and damage to corporate standing.
In its filing, CXMT asserted that it is not affiliated with the Chinese military and that its DRAM products are developed, manufactured, and sold for civilian and commercial applications rather than military use. The company said that since the initial designation in January 2025 it has experienced ongoing reputational and commercial harm, and that it is pursuing the suit to protect its business interests.
The lawsuit names the Department of Defense and three senior officials as defendants: Defense Secretary Pete Hegseth, Deputy Defense Secretary Steve Feinberg, and Assistant Secretary of Defense for Industrial Base Policy Michael Cadenazzi. CXMT argues the Pentagon acted arbitrarily, failed to provide evidentiary support for the classification, and deprived the company of due process.
According to the complaint, the company spent more than a year furnishing the Pentagon with information intended to rebut the designation and to secure removal from the list. CXMT alleges that the Defense Department published a notice in February indicating the company would be removed but then withdrew that notice on the same day, and that the department failed to adequately explain the reversal when CXMT was relisted.
The Department of Defense declined to comment on the litigation, stating it does not provide commentary on pending or ongoing cases as a matter of policy. The initial designation was made under the Biden administration, and the Trump administration retained CXMT on the list in a June update, according to the complaint.
CXMT is a major supplier of DRAM chips, components widely used across smartphones, personal computers, servers, artificial intelligence systems, and other electronics. The company reported a sharp revenue increase, with sales rising 874% in the first half, and has stated ambitions to enter the U.S. market over the longer term.
The company’s legal move follows similar litigation by other Chinese firms challenging their inclusion on the Pentagon’s list. In June, Alibaba filed suit contesting its placement on the same list. Xiaomi previously pursued removal through U.S. courts and succeeded in having its designation rescinded in 2021.
In its court papers, CXMT maintained that none of the Pentagon’s determinations are supported by the factual record or applicable law, and that the department’s decision-making lacked reasoned explanation. The complaint asks the court to set aside the designation and to compel the Defense Department to remove CXMT from the list.
Contextual note: The suit centers on the administrative process used by the Defense Department to designate companies and the commercial consequences that flow from such listings, including potential contracting restrictions and reputational effects for companies operating in global technology supply chains.