On August 28, 2026, local time, China's DRAM chip manufacturer CXMT formally filed a lawsuit with the U.S. District Court for the District of Columbia, accusing the Department of Defense of erroneously placing it on the "Chinese Military Company" list (i.e., the 1260H List), and requesting the court to overturn the decision and remove it from the list. In its complaint, CXMT explicitly stated that the company has no affiliation with the Chinese military, and its DRAM chips are designed, produced, and sold exclusively for civilian and commercial purposes; the U.S. side's inclusion of the company on the military-related list constitutes an erroneous determination.

List Reversals and Due Process Controversy

CXMT's entanglement with the 1260H List began in January 2025, when the company was first placed on the list by the Department of Defense. The list originates from Section 1260H of the U.S. National Defense Authorization Act for Fiscal Year 2021, which requires the Department of Defense to identify and publicly disclose companies it deems "Chinese military companies." While inclusion on this list does not directly trigger trade sanctions, it restricts companies from participating in certain federal government procurement activities and accessing specific government financial support, while also causing severe reputational damage and business uncertainty.

In February 2026, the Department of Defense briefly issued a notice to remove CXMT from the list, but withdrew it on the same day. In the June 2026 updated version of the list, CXMT was once again included. This capricious determination, combined with the fact that the company had continuously submitted supporting materials for over a year without receiving a fair response, ultimately prompted it to seek judicial recourse.

Judicial Recourse and Impact

This lawsuit makes CXMT the seventh Chinese company, following Xiaomi, AMEC, Hesai, WuXi AppTec, Alibaba, and YMTC, to challenge the 1260H List through the U.S. judicial system.

CXMT contends that the Department of Defense's decision was "arbitrary," lacked evidentiary support, and violated due process. The U.S. Department of Defense responded that, per internal policy, it does not comment on pending or ongoing litigation. As the world's fourth-largest DRAM manufacturer, CXMT has demonstrated strong growth momentum in recent years. And its parent company, Changxin Technology, listed on the STAR Market in July 2026.

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