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