`
`Case 3:14-cv-OO757-REP-DJN Document 47-9 Filed 01/12/15 Page 1 of 3 Page|D# 1177
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE EASTERN DISTRICT OF VIRGINIA,
`RICHMOND DIVISION
`
`Civil Action NO. 3:14—cv—757-REP
`
`)
`
`i
`)
`
`) i
`
`) l
`
`3
`
`)
`)
`)
`
`SAMSUNG ELECTRONICS CO., LTD. and
`SAMSUNG ELECTRONICS AMERICA,
`INC,
`
`Plaintiffs,
`
`”VS.—
`
`NVIDIA CORPORATION, VELOCITY
`MICRO, INC. D/B/A VELOCITY MICRO
`AND VELOCITY HOLDINGS, LLC,
`
`Defendants.
`
`.
`DECLARATION OF STEPHANIE LUCK IN SUPPORT OF
`DEFENDANT NVIDIA CORPORATION’S MOTION TO TRANSFER VENUE
`PURSUANT TO 28 U.S.C.
`1404 a SEVER AND STAY
`
`1, Stephanie Luck, declare:
`
`1.
`
`I am a full—time employee of NVIDIA Corporation (“NVIDIA”), where I hold the
`
`position of Director, Human Resources CHR”) I have personal knowledge of the matters stated
`
`herein, and I could and would. testify competently to these matters if called upOn to do so.
`
`2.
`
`I work at NVIDIA’S headquarters located at 2701 San Tomas
`
`Expressway, Santa Clara, California 95050. NVIDIA has been continuously Operating in the
`
`Santa Clara area since 1993.
`
`3.
`
`4.
`
`I reside in Santa Cruz, California.
`
`I joined NVIDIA as an employee in 1998.
`
`I have held a number of positions in
`
`
`
`Case 3:14-cv-00757-REP-DJN Document 47-9 Filed 01/12/15 Page 2 of 3 PageID# 1178
`
`Case 3:14-cv-OO757-REP-DJN Document 47-9 Filed 01/12/15 Page 2 of 3 Page|D# 1178
`
`NVIDIA’s HR department, and assumed my current position as Director of Human Resources in
`
`2014. In that role, I am responsible for HR Operations, HR Business Partner Programs, Learning
`
`and Development, and Employee Events.
`
`5.
`
`Based on the Amended Complaint, it is my understanding that Samsung accuses
`
`NVIDIA of infringing US. 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 Graphic 13rocessing Units (“GPUs”),
`
`system—on—a—chip units
`
`(“SOCs”), and graphic cards that allegedly practice the inventions of the asserted patents.
`
`6.
`
`The vast majority of NVIDIA’S employees are invotved with some aspect of
`
`engineering, sale, or marketing of NVIDIA’S GPUs, SOCs, and graphic cards.
`
`7.
`
`As of November 2014, NVlDIA had approximately 9,103 US. employees. Of
`
`those, over 4,580 work at NVIDIA’S Santa Clara headquarters. Only 12 employees work in
`
`Virginia.
`
`8.
`
`NVIDIA has several groups that are involved with the engineering of its graphics
`
`processing and related technology. 2,300 of those employees work at NVlDIA’s Santa Clara
`
`headquarters in the Northern District of California.
`
`9.
`
`NVIDIA has Operations groups that primarily work with and manage the outside
`
`vendors who manufacture NVIDIA GPUS and SOCs. These groups also test the chips that are
`
`produced, and coordinate shipping of chips to customers. As of November 2014, NVIDIA had
`
`approximately 891 employees in these groups; 49% of those employees work at NVIDIA’S Santa '
`
`Clara headquarters in the Northern District of California.
`
`10.
`
`, NVIDIA has groups of employees who are tasked with marketing its GPUs and
`
`SOCs to electronics manufacturers and end consumers. As of November 2014, NVIDIA had
`
`
`
`Case 3:14-cv-00757-REP-DJN Document 47-9 Filed 01/12/15 Page 3 of 3 PageID# 1179
`
`Case 3:14-cv-00757-REP-DJN Document 47-9 Filed 01/12/15 Page 3 of 3 Page|D# 1179
`
`approximately 115 employees in these groups; over 80% of those employees work at NVIDIA’S
`
`Santa Clara headquarters in the Northern District of California.
`
`ll.
`As of November 2014, NVIDIA’S U.S. IT department comprised approximately
`178 employees; over 92% of those employees work at NVIDIA’S Santa Clara headquarters in the
`
`Northern District of California.
`
`12.
`
`As of November
`
`2014, NVIDIA’S U.S.
`
`legal
`
`department
`
`comprised
`
`approximately 37 employees; 92% of those employees work at NVIDIA’S Santa Clara
`
`headquarters in the Northern District of California.
`
`I declare under the penalty of perjury that the forgoing is true and correct. Executed this
`
`9th day of January, 2015 in Santa Clara, Califomia.
`
`
`
`Stephai’jée Luck
`
`'
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
