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`Case 3:14-cv-OO757-REP-DJN Document 47-6 Filed 01/12/15 Page 1 of 3 Page|D# 1165
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE EASTERN DISTRICT OF VIRGINIA,
`RICHMOND DIVISION
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`Civil Action No. 3:14-cv-757-REP
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`SAMSUNG ELECTRONICS co, LTD. and
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`SAMSUNG ELECTRONICS AMERICA,
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`rNC.,
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`Plaintiffs,
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`-VS . _
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`NVIDIA CORPORATION, VELOCITY
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`MICRO, INC. BIB/A VELOCITY MICRO
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`AND VELOCITY HOLDINGS, LLC,
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`Defendants.
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`vvvvvvvvvvvvvvv
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`DECLARATION OF PHILIP DECKER IN SUPPORT OF DEFENDANT NVIDIA
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`CORPORATION’S MOTION TO TRANSFER VENUE PURSUANT
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`TO 28 U.S.C.
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`1404 a SEVER AND STAY
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`I, Philip Decker, declare:
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`I.
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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 Information Security.
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`2.
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`I work at NVIDIA’S headquarters located at 2701 San Tomas
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`Expressway, Santa Clara, California 95050.
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`3.‘
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`4.
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`I reside in Santa Clara, California.
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`I joined NVIDIA as an employee in 2000 in the Information Technology
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`Department.
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`I assumed the position of Director of Information Security in 2002.
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`In 2006, I
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`assumed my current position as Senior Director of Information Security.
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`In that role, I am a
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`member of the Legal organization, and am involved in creating, reviewing and managing
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`Case 3:14-cv-00757-REP-DJN Document 47-6 Filed 01/12/15 Page 2 of 3 PageID# 1166
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`Case 3:14-cv-OO757-REP-DJN Document 47-6 Filed 01/12/15 Page 2 of 3 Page|D# 1166
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`NVIDIA’S policies and practices regarding information. security and the retention, back-up and
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`storage of documents relating to its business, including documents related to the matters referred
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`to in the Amended Complaint. I also am involved in coordinating NVIDIA’s responses to gather
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`and preserve documents in a litigation context.
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`5.
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`NVIDIA’S document retention, backup, and storage policies and practices are
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`formulated and managed by the legal and IT organizations, which are based at NVIDIA’S
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`headquarters in Santa Clara, California.
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`6.
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`Together with other members of my organization, I expect to be involved in
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`NVIDIA’s obligations to gather and produce evidence in this matter, as I am in other
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`substantially similar lawsuits filed against NVIDIA.
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`7.
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`Based on the Amended Complaint, it is my understanding that Plaintiffs accuse
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`NVIDIA of infringing U.S. Patent Nos. 5,860,158; 6,262,938; 6,287,902; 6,819,602; 8,252,675;
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`and 6,804,724 based on its manufacture, use, sale, offer for sale, or importation of products,
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`including without
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`limitation Graphic Processing Units (“GPUS”),
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`system-on-a—chip units
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`(“SOCS”), and graphic cards that allegedly practice the inventions of the asserted patents.
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`I also
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`understand that another defendant, Velocity, is accused of infringing these patents based on its
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`use, sale, offer for sale, or importation of products that empioy components that allegedly
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`practice the inventions of the asserted patents, such as NVIDIA’S GPUs and SOCs. Based on
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`these facts, I expect the universe of documents from which NVIDIA may potentially have to
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`produce to be extremely voluminous.
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`8.
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`To my knowledge, almost all of the evidence and/or documents relevant to the
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`matters described in the Amended Complaint are located in Northern California. To my
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`knowledge, no such evidence is maintained in Virginia.
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`
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`r
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`Case 3:14-cv-00757-REP-DJN Document 47-6 Filed 01/12/15 Page 3 of 3 PageID# 1167
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`Case 3:14-cv-00757-REP-DJN Document 47-6 Filed 01/12/15 Page 3 of 3 Page|D# 1167
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`9.
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`To my knowledge, all of NVIDIA’S electronic evidence relevant to the matters
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`described in the Amended Complaint will be downloaded at, and produced by, NVIDIA’S Santa
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`Clara headquarters.
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`10.
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`Pre—trial proceedings and trial in Northern California would be more convenient
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`and less disauptive to my business and personal affairs than litigation in Virginia.
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`It would also
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`be disruptive to my organization to have people under my supervision and with whom I work
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`coordinating document management issues on the other side of the country when all relevant
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`documents and resources for obtaining them are in Northern California.
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`I declare under the penalty of perjury that the forgoing is true and correct. Executed this
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`9th day of January, 2015 in Santa Clara, California. f_
` "/15hilip D cker
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