Case 7:26-mc-00324-LS Document 7-1 Filed 08/25/26 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS MIDLAND/ODESSA DIVISION NEURAL AI, LLC, ) ) Petitioner, ) ) v. ) MISC. CASE NO.: 7:26-mc-00324-LS ) GOOGLE, LLC, ) Underlying Case: Texas Western District ) Court, Civil Action No. 7:24-cv-00221- Respondent. ) ADA-DTG ) DECLARATION OF JORDAN R. JAFFE IN SUPPORT OF RESPONDENT’S MEMORANDUM IN RESPONSE TO PETITIONER’S MOTION TO COMPEL COMPLIANCE WITH SUBPOENAS SERVED ON NON-PARTY GOOGLE LLC Case 7:26-mc-00324-LS Document 7-1 Filed 08/25/26 Page 2 of 5 I, Jordan R. Jaffe, declare on personal knowledge as follows: 1. I am an attorney at Wilson Sonsini Goodrich & Rosati, P.C., counsel for Google LLC (“Google”) in this matter. This declaration is based on personal knowledge and if called, I could and would testify competently to the facts herein. 2. Since Neural AI, LLC (“Neural”) issued its third-party subpoena to Google, I have been involved in each meet-and-confer between the parties. 3. Attached as Exhibit A is a true and correct copy of the parties’ email communications related to the subpoenas. 4. Attached as Exhibit B are excerpts from Form 10-K filed by Alphabet Inc. with the U.S. Securities and Exchange Commission (“SEC”).1 5. According to Ex. B, Alphabet Inc. had 190,820 employees as of December 31, 2025. Ex. B at 13. Google is Alphabet’s largest business, id. at 50, and includes business segments that include Google Services and Google Cloud, id. at 7. “Google Services’ core products and platforms include ads, Android, Chrome, devices, Gmail, Google Drive, Google Gemini, Google Maps, Google Photos, Google Play, Search, and YouTube.” Id. at 7–8. 6. According to Ex. B, “[a]t the foundation of [Google’s]w full-stack approach is our AI-optimized infrastructure—a key differentiator enabling us to power our own products, such as Search and YouTube, and support the services we provide to our Google Cloud customers.” Id. at 7. This “technical infrastructure allows us to use and offer our customers a range of AI accelerator options, including specialized Graphics Processing Units (GPUs) and our own custom-built Tensor Processing Units (TPUs), such as Ironwood, our seventh-generation TPU.” 1 The full Form 10-K is available at: https://www.sec.gov/Archives/edgar/data/1652044/000165204426000018/goog-20251231.htm. 1 Case 7:26-mc-00324-LS Document 7-1 Filed 08/25/26 Page 3 of 5 Id. at 7. This further includes “world-class research, including models and tooling; and [its] products and platforms that bring AI to billions of people, developers, and enterprises,” id. Google’s “AI-optimized infrastructure” enabled Google to embed “the power of generative AI and Gemini into [its] products and platforms.” Id. For example, Google provides “AI Overviews” and “AI Mode in Search” along with “enterprise AI solutions on [its] Google Cloud Platform,” id. at 50, which includes the Vertex AI platform and Gemini Enterprise, id. at 54. 7. According to Ex. B, Google invests large sums in capital expenditure as it scales its infrastructure, expending $91.4 billion in 2025, which was up from $52.5 billion in 2024. Id. at 68. This included investments in “servers and network equipment, and data centers.” Id 8. Neural’s Subpoenas include a definition for “NVIDIA GPUs” that lists approximately 240 products. See, e.g., Dkt. 1-6 at 6–8. As described above, Google broadly uses AI and has vast amounts of AI technical infrastructure. As also described above, Google uses AI across many products and features at Google. Based on that information, tracking down each of the requested “NVIDIA GPUs” across all Google products and services, determining how each GPU is used, and how each GPU and associated software are configured, would be unduly burdensome, if not impossible. This would further require consulting any number of thousands of Google employees and related documentation regarding their use of AI infrastructure, which would likely take months, if not longer. See supra ¶¶ 5–6. Further, even after identifying the requested “NVIDIA GPUs,” cataloguing this information would require the collection and production of voluminous records, adding to the unduly burdensome requests. 2 Case 7:26-mc-00324-LS Document 7-1 Filed 08/25/26 Page 4 of 5 I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on August 25, 2026, at Pittsburgh, Pennsylvania. /s/ Jordan R. Jaffe Jordan R. Jaffe 3 Case 7:26-mc-00324-LS Document 7-1 Filed 08/25/26 Page 5 of 5 CERTIFICATE OF SERVICE The undersigned certifies that, on August 25, 2026, all counsel of record are being served with a copy of this document and exhibits attached hereto via CM/ECF to the following: Susman Godfrey Brian D. Melton 1000 Louisiana St. Suite 5100 Houston, TX 77002 bmelton@susmangodfrey.com Max L. Tribble , Jr. 1000 Louisiana Suite 5100 Houston, TX 77002-5096 mtribble@susmangodfrey.com 713-653-7820 Rocco Magni 1000 Louisiana, Suite 5100 Houston, TX 77002-5096 rmagni@susmangodfrey.com Tanner H. Laiche 401 Union St., Suite 3000 Seattle, WA 98101 tlaiche@susmangodfrey.com 206-516-3880 Attorneys for Petitioner Neural AI, LLC /s/ Jason M. Storck Jason M. Storck 4