`
`Case 3:14-cv-00757-REP-DJN Document 106 Filed 04/24/15 Page 1 of 3 PageID# 15419
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE EASTERN DISTRICT OF VIRGINIA
`
`RICHMOND DIVISION
`
`SAMSUNG ELECTRONICS CO., LTD., and
`
`CIVIL ACTION NO. 3: l4—CV—00757—REP
`
`SAMSUNG ELECTRONICS AMERICA,
`
`INC,
`
`Plaintiffs,
`
`JURY TRIAL DEMANDED
`
`NVIDIA CORPORATION, OLD MICRO,
`
`INC. F/K/A VELOCITY MICRO, INC. AND
`
`VELOCITY HOLDINGS, LLC
`
`Defendants.
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`DECLARATION OF SARAH K. MCCONAUGHY IN SUPPORT OF SAMSUNG’S
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`MOTION TO SEVER NVIDIA’S PATENT INFRINGEMENT COUNTERCLAIMS
`
`1, Sarah K. McConaughy, declare as follows:
`
`1.
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`I am a member of the Bar of the Commonwealth of Virginia and am admitted to
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`the United States District Court for the Eastern District of Virginia.
`
`I am an attorney at the
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`law firm of McGuireWoods, LLP, attorneys of record for Plaintiffs Samsung Electronics Co.,
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`Ltd, and Samsung Electronics America, Inc., (collectively “Samsung”) in this case.
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`I submit
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`this declaration in support of Samsung’s Opposition to Defendants’ Motion for Extension of
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`Time to Answer or Otherwise Respond to the Complaint.
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`I have personal knowledge of the
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`facts set forth in this declaration and, if called to testify as a witness, could and would do so
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`under oath.
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`2. Attached hereto as Exhibit 1 is a true and correct copy of a webpage titled, “Two
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`Latest Developments in Our Patent Dispute with Samsung,” which can be accessed at
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`http://blogs.nvidia.comfblog/2015/04/16/update—patent—samsung/ (last accessed on April 24,
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`2015).
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`3. Attached hereto as Exhibit 2 is a true and correct copy of Order 18: Granting
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`
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`Case 3:14-cv-00757-REP-DJN Document 106 Filed 04/24/15 Page 2 of 3 PageID# 15420
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`Case 3:14-cv-00757-REP-DJN Document 106 Filed 04/24/15 Page 2 of 3 Page|D# 15420
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`Electronics and Display Devices with Graphics Processing and Graphics Processing Units
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`Therein, International Trade Commission, Inv. No. 337—TA—932, Order No. 18 at 2, dated
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`March 27, 2015.
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`4. Attached hereto as Exhibit 3 is a true and correct copy of a webpage titled,
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`“NVIDIA Receives Favorable Ruling from ITC in Patent Dispute with Samsung, Qualcomm,”
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`which can be accessed at htt
`
`
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`://blo s.nvidia.com/blo I2015i04/06/itc—‘favorable—1‘ulin / (last
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`accessed on April 24, 2015).
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`5. Attached hereto as Exhibit 4 is a true and correct cepy of NVIDIA’s Second Set
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`of Requests for Production of Documents and Things to Samsung (Nos. 48—1 10), dated April
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`14, 2015.
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`6. Attached hereto as Exhibit 5 a true and correct copy of NVIDIA’s Second Set of
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`Interrogatories to Samsung (Nos. 3-6), dated April 14, 2015.
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`7. Attached hereto as Exhibit 6 is a true and correct copy of an April 14, 2009 Order
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`in, ROY—G-BIV Corp. v. FANUC Lid, er al., Case No. 2:07-CV-418 (ED. Tex).
`
`I declare under penalty of perjury under the laws of the United States that the
`
`foregoing is true and correct.
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`Executed April 24, 2015 in Norfolk, Virginia.
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` . McConaughy (VSB V0. 80674
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`
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`Case 3:14-cv-00757-REP-DJN Document 106 Filed 04/24/15 Page 3 of 3 PageID# 15421
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`CERTIFICATE OF SERVICE
`
`
`I hereby certify that on April 24, 2015, a true and correct copy of the foregoing was filed
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`electronically using the CM/ECF system. As such, this document was served on all counsel who
`have consented to electronic service, including as follows:
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`Dabney Jefferson Carr, IV
`
` Troutman Sanders LLP
` 1001 Haxall Point
` Richmond, VA 23219
` Telephone: 804-697-1238
` Facsimile: 804-698-5119
` Email: Dabney.carr@troutmansanders.com
`
` Clement Joseph Naples
` Latham & Watkins LLP
` 885 third Avenue, 25th Floor
` New York, NY 10022
` Telephone: 212-906-1200
` Facsimile: 212-906-1201
` Email: clement.naples@lw.com
`
`
`Maximillian Grant
`Latham & Watkins LLP
`555 Eleventh Street, NW, suite 1000
`Washington, DC 20004
`Telephone: 202-637-2200
`Facsimile: 202-637-2201
`Email: max.grant@lw.com
` Counsel for NVIDIA Corporation, Old Micro, Inc.
` f/k/a Velocity Micro, Inc., and Velocity Holdings, LLC
`
`
`
`
`/s/ Robert W. McFarland
`Robert W. McFarland (VSB No. 24021)
`Sarah K. McConaughy (VSB No. 80674)
`MCGUIREWOODS LLP
`101 West Main Street, Suite 9000
`Norfolk, Virginia 23510
`Telephone: (757) 640-3716
`Facsimile: (757) 640-3966
`E-mail: rmcfarland@mcguirewoods.com
`Attorneys for PLAINTIFFS Samsung Electronics
`Co., Ltd., and Samsung Electronics America, Inc.
`
`
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