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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA,
`" RICHMOND DIYISION
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`Civil Action No. 3 :14-cv-7 57-REP
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`SAMSLING ELECTRONICS CO., LTD. and
`SAMSUNG ELECTRONIC S AMERICA,
`INC.,
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`Plaintiffs,
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`-vs.-
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`NVIDIA CORPORATION, VELOCITY
`MICRO, INC. D/B/A VELOCITY MICRO
`AND VELOCITY HOLDINGS, LLC,
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`Defendants.
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`DECLARATION OF DAVID, LUEBKE IN SUPPORT OF
`DEFENDANT NVIDIA CORPORATION'S MOTION TO TRANSFER VENUE
`PURSUANT TO 28 U.S.C. $ 1404(a), SEVER" AND STAY
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`I, David Luebke, declare:
`1.
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`I am a full-time employee of NVIDIA Corporation ("NVIDIA"), where I hold the
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`position of Senior Director of Research Staff within the Computer Graphics Research Group. I
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`have held that position since March of 2012. I have been employed with NVIDIA since 2006.
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`The statements in this declaration are based upon my personal knowledge, corporate records,
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`information maintained by NVIDIA in the ordinary course of business, or reasonable
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`investigation, and I could and would testifu competently to these matters if called upon to do so.
`2.
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`I understand that Plaintiffs have sued NVIDIA and accused NVIDIA of infringing
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`U.S. Patent Nos. 5,860,158; 6,262,938; 6,287,902; 6,819,602;8,252,675; and 6,804,724 based on
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`its manufacture, use, sale, offer for sale, or importation of products, including without limitation
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`
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`Case 3:14-cv-00757-REP-DJN Document 47-5 Filed 01/12/15 Page 2 of 2 PageID# 1164
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`Graphic Processing Units ("GPUs"), system-on-a-chip units ("SOCs"), and graphics cards that
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`allegedly practice the inventions of the asserted patents.
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`3. NVIDIA has a small regional office located at 410 East Water Street, Suite 200
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`Charlottesville, VA 22902.
`4.
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`There are three employees, including myself, who work in the Charlottesville
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`office.
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`5. To my knowledge after a reasonable investigation, none of the NVIDIA
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`employees in the Charlottesville office do any substantive work related to the design,
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`development, or manufacture of the accused products, or has ever sold any of the accused
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`devices, or works on any marketing or financial reporting of the accused products.
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`6.
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`In addition to the employees who work in the Charlottesville office, there are nine
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`NVIDIA employees who work from home and reside in Virginia.
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`7.
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`To my knowledge after a reasonable investigation, none of the NVIDIA
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`employees who work from home and reside in Virginia do any substantive work related to the
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`design, development, or manufacture of the accused products, or has ever sold any of the accused
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`devices, or works on any marketing or financial reporting of the accused products.
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`I declare under the penalty of perjury that the forgoing is true and correct. Executed this
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`1lth day of January, 2015 in Charlottesville, Virginia.
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`David Luebke
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`2
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