Case 3:14-cv-00757-REP-DJN Document 49-1 Filed 01/22/15 Page 1 of 4 PageID# 1214
`Case 3:14-cv-00757-REP-DJN Document 49-1 Filed 01/22/15 Page 1 of 4 Page|D# 1214
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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
`SAMSUNG ELECTRONICS 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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`3
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`DECLARATION OF RANDALL COPELAND 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. § 14049), SEVER, AND STAY
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`I, Randall Copeland, declare:
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`l.
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`I am a full—time employee of Velocity Holdings, LLC (“Velocity”), where I hold
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`the position of Managing Director and Chief Executive Officer. Velocity is a limited liability
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`corporation organized and existing under the laws Of Virginia.
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`I have personal knowledge of the
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`matters stated herein, and I could and would testify competently to these matters if called upon to
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`do so.
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`2.
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`I work at Velocity’s sole Office, located at 835 Grove Rd. Midlothian, Virginia
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`23114. The office is located in Chesterfield County, Virginia. Velocity Micro, Inc. was a
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`Virginia corporation.
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`It ceased operations when its assets were foreclosed on and seized by
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`creditors on December 31, 2013. Velocity Micro, Inc.’s principal office is listed as 9030 Stony
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`

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`Point Parkway, Suite 400, Richmond, Virginia, 23235, which is the law office of its creditors’
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`attorney.
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`3.
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`Velocity is an assembly company. It purchases components parts and then builds
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`its products to order for its customers. Velocity is not an engineering or a design company.
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`Velocity does not design memory controllers or do any semiconductor manufacturing. Velocity
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`is not a foundry.
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`4.
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`Velocity currently employs 11 employees. All of the Velocity employees work
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`out of the Midlothian office.
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`5.
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`6.
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`7.
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`Velocity’s annual revenue is approximately-
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`Velocity sells its products across the United States.
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`Based on the Amended Complaint, it is my understanding that Samsung accuses
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`NVIDIA Corporation of infringing U.S. Patent Nos. 5,860,158; 6,262,938; 6,287,902; 6,819,602;
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`8,252,675; and 6,804,724 based on NVIDIA’S manufacture, use, sale, offer for sale, or
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`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 (“SOCs”), and graphics cards that allegedly practice the inventions of the
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`asserted patents.
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`I also understand that Samsung has alleged that Velocity infringes those same
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`six patents based on its alleged import, offer to sell, sale, or use of the NVIDIA products.
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`Velocity does not design, develop, or manufacture any of the accused technology.
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`8.
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`Velocity does not make any direct purchases from NVIDIA Corporation.
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`Velocity purchases graphics cards from third parties, including EVGA Corporation, located in
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`Brea, California. EVGA Corporation incorporates NVIDIA components into its graphics cards.
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`9.
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`Samsung has accused Velocity of infringing U.S. Patent No. 5,860,158 based on
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`its alleged sale of the Cruz Tablet L510 incorporating the NVIDIA Tegra 250 processor.
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`Velocity has never sold the Cruz Tablet L510 or any other Tegra product of any kind. Nor does
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`Velocity know anything about the design of any Tegra processors.
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`10.
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`Samsung has also accused Velocity of infringing U.S. Patent Nos. 5,860,158;
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`6,262,938; 6,819,602; 6,287,902; 8,252,675; and 6,804,724 based on its sales of computers
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`allegedly incorporating NVIDIA graphics processors and graphics cards. Velocity purchases
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`graphics cards for desktop computers from third parties, including EVGA Corporation. EVGA
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`Corporation incorporates NVIDIA components into its graphics cards. Velocity purchases shells
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`for laptops that have the graphics cards built into the shell from third parties, including Sager
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`Midern Computer, Inc, located in City of Industry, California.
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`11.
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`Velocity does not have any capability or expertise to design or manufacture
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`graphics cards or graphics processors, nor does it advise, consult, or instruct any third parties on
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`the design or manufacture of graphics cards and processors.
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`12.
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`Samsung has also accused Velocity of infringing US. Patent No. 7,073,054 based
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`on its alleged sale of computers, such as the NoteMagiX M15 laptop, that include a hybrid hard
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`disk drive incorporating a solid state storage unit. Velocity has never sold a single unit of the
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`accused product with a hybrid hard drive.
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`13.
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`Samsung has additionally accused Velocity of infringing US. Patent No.
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`5,777,854 based on its alleged sales of the Velocity Vector Z25, which incorporates the “SX”
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`desktop computer chassis and based on its sales of computers that incorporate the “GK-2”
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`chassis. Velocity has sold approximately-units of computers which incorporate the “SX”
`chassis. Velocity has sold approximately-units of computers which incorporate the “GX-2”
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`chassis. Velocity does not design or manufacture the accused products. Rather, it purchases the
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`accused “SX” computer chassis from a third party in Harrisburg, Pennsylvania.
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`It purchases the
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`“GK—2” chassis from a third party in Keelung, Taiwan. Velocity lacks any information about the
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`design or manufacture of the accused computer chassis.
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`14.
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`In the last year, the accused products related to the two patents asserted solely
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`against Velocity have generated less than $20,000 of revenue for Velocity.
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`I declare under the penalty of perjury that the forgoing is true and correct. Executed this
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`11thday ofJanuary, 2015 inMidlothian, Virginia. %9(Q
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`Randall Copeland
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