Case 3:14-cv-00757-REP-DJN Document 81-9 Filed 04/10/15 Page 1 of 4 PageID# 10618
`Case 3:14-cv-00757-REP-DJN Document 81-9 Filed 04/10/15 Page 1 of 4 Page|D# 10618
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`EXHIBIT I
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`EXHIBIT I
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`Case 3:14-cv-00757-REP-DJN Document 81-9 Filed 04/10/15 Page 1 of 4 Page|D# 10618
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`EXHIBIT I
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`EXHIBIT I
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`Case 3:14-cv-00757-REP-DJN Document 81-9 Filed 04/10/15 Page 2 of 4 PageID# 10619
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`RICHMOND DIVISION
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`CIVIL ACTION NO. 3:14-CV-00757-REP
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`JURY TRIAL DEMANDED
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`SAMSUNG ELECTRONICS CO., LTD., and
`SAMSUNG ELECTRONICS AMERICA,
`INC.,
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`v.
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`NVIDIA CORPORATION, VELOCITY
`MICRO, INC. D/B/A VELOCITY MICRO,
`AND VELOCITY HOLDINGS, LLC
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`Plaintiffs,
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`Defendants.
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`FIRST SECOND AMENDED COMPLAINT
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`Plaintiffs Samsung Electronics Company, Ltd. (“SEC”) and Samsung Electronics
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`America, Inc. (“SEA”) (collectively “Samsung”), by and through their undersigned attorneys,
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`hereby file this First Second Amended Complaint1 against NVIDIA Corporation (“NVIDIA”),
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`Velocity Old Micro, Inc. d/b/aF/K/A Velocity Micro, Inc. and Velocity Holdings, LLC
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`(collectively “Velocity”). All defendants will be referred to collectively as “Defendants.”
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`Samsung states as follows:
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`THE PARTIES
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`1.
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`Plaintiff SEC is a multi-national corporation organized under the laws of Korea
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`with its principal place of business located at 416 Maetan-3dong, Yeongtong-gu, Suwon-City,
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`Gyeonggi-do, Korea 443-742.
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`1 The Second Amended Complaint amends the First Amended Complaint by changing the name of the
`defendant originally identified as “Velocity Micro, Inc. D/B/A Velocity Micro” to “Old Micro, Inc. F/K/A Velocity
`Micro, Inc.” The only portions of the Second Amended Complaint that differ from the First Amended Complaint
`are the introductory paragraph, paragraph 4, paragraph 5, and footnote 2. Exhibit I, attached hereto, shows
`Samsung’s changes to those portions of the Second Amended Complaint. The remainder of the Second Amended
`Complaint is unchanged from the First Amended Complaint.
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`Case 3:14-cv-00757-REP-DJN Document 81-9 Filed 04/10/15 Page 3 of 4 PageID# 10620
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`2.
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`Plaintiff SEA is a corporation organized and existing under the laws of the state of
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`New York with its principal place of business in Ridgefield Park, New Jersey and is a wholly-
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`owned subsidiary of SEC.
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`3.
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`Defendant NVIDIA is a Delaware corporation with its headquarters located at
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`2701 San Tomas Expressway, Santa Clara, California 95050. NVIDIA imports into the United
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`States, offers for sale, sells and/or uses in the United States graphics processing units (GPUs),
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`system on a chip (SOC) units, graphics cards, and mobile computing devices such as tablet
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`computers.
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`4.
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`Defendant Velocity Micro, Inc., which does business in Virginia as Velocity
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`Micro, is a corporation organized and existing under the laws of Delaware with its principal
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`place of business located at 7510 Whitepine Road, Richmond, Virginia 23237. The State
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`Corporation Commission of the Commonwealth of Virginia lists Velocity Micro, Inc.’s principal
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`office as 9030 Stony Point Parkway, Suite 400, Richmond, Virginia, 23235. Velocity Micro,
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`Inc. incorporates NVIDIA GPUs, SOCs, and/or graphics cards in products that it offers for sale,
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`sells and/or uses in the United States.
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`4.
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`Defendant Old Micro, Inc., which was formerly known as Velocity Micro, Inc., is
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`a corporation organized and existing under the laws of Virginia. The State Corporation
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`Commission of the Commonwealth of Virginia lists the location of Old Micro, Inc.’s registered
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`agent as 9030 Stony Point Parkway, Suite 400, Richmond, Virginia, 23235. At times relevant to
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`this action, Old Micro, Inc. manufacturered computers that it offered for sale, sold and/or used in
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`the United States.
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`5.
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`Defendant Velocity Holdings, LLC is a limited liability corporation organized and
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`existing under the laws of Virginia, which does business as Velocity Micro. Velocity Holdings,
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`Case 3:14-cv-00757-REP-DJN Document 81-9 Filed 04/10/15 Page 4 of 4 PageID# 10621
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`LLC has with its its principal place of business located at 825835 Grove Rd. Suite 3, Midlothian,
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`Virginia 23114. The members of Velocity Holdings, LLC reside in the Eastern District of
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`Virginia. Velocity Holdings, LLC is a manufacturer of computers that it offers for sale, sells
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`and/or uses in the United States.
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`SAMSUNG
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`6.
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`From its inception as a small business in Taegu, Korea, Samsung has grown to
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`become one of the world’s leading electronics companies, specializing in digital products,
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`semiconductors, memory, and system integration. Today, Samsung’s innovative consumer
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`products are widely recognized and appreciated across the globe. Samsung designs, develops,
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`manufacturers, and sells leading consumer electronics, including mobile phones, smartphones,
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`tablet computers, and laptop computers.
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`7.
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`Samsung has a long history of groundbreaking innovation across a wide range of
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`technologies. During the 1970s and 1980s, Samsung’s core technology businesses diversified
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`and expanded globally. For example, Samsung began production of personal computers in 1983
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`and selected telecommunications and semiconductors as core business lines in 1988. About
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`Samsung.2 During this period, Samsung additionally challenged itself to restructure old
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`businesses and enter new ones with the aim of becoming one of the world’s top five electronics
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`companies.
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`8.
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`Samsung’s commitment to innovation is demonstrated in part by the billions of
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`dollars in research and development expenditures incurred over the years. From 2005 through
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`2010 alone, Samsung invested more than $35 billion in research and development. More than a
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`2 Bolded terms or references are defined in the text of this First Second Amended Complaint or in the
`section entitled “References.”
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