The complaint alleges that a number of Toshiba flash memory chips infringe upon three Lexar patents, and asks the ITC to investigate these claims.

Lexar has requested the ITC to issue an order prohibiting import into the US of a number of Toshiba NAND flash memory chips, and instructing retailers and distributors to remove from shelves and destroy products containing the chips.

NAND flash is the type of memory found in memory cards for use in products like digital still cameras. Its ability to retain data when there is no power means it is being increasingly employed in all kinds of digital electronics products.

This has sparked intense competition between the handful of companies that produce NAND flash chips.

Lexar's ITC complaint comes a year after a court in California found Toshiba guilty of a number of actions, including theft of trade secrets.

The court ordered Toshiba to pay Lexar about $465m in compensation. In December last year Toshiba succeeded in winning a reconsideration of the damages claim, and filed an appeal seeking to overturn the original guilty verdict.

Toshiba could not immediately be reached for comment.