Neural AI, LLC v. Tesla Inc. — Entry #6: CORRECTED MOTION to Compel Compliance With Subpoena Served on Third Party Tesla, Inc
Case: Neural AI, LLC v. Tesla Inc. txwd · 7:26-cv-00318
filed August 17, 2026
What this document is
Docket entry #6 · filed August 18, 2026
CORRECTED MOTION to Compel Compliance With Subpoena Served on Third Party Tesla, Inc. by Neural AI, LLC. (Attachments: # 1 Affidavit Declaration of Tanner Laiche, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit 15, # 17 Exhibit 16, # 18 Exhibit 17, # 19 Exhibit 18, # 20 Exhibit 19, # 21 Exhibit 20, # 22 Exhibit 21, # 23 Proposed Order)(Magni, Rocco) (Entered: 08/18/2026)
Who is involved
- Neural AI, LLC
- Tesla Inc.
Why we have it
We follow this case because it names a company we track, although that company is not a party:
- CoreWeave: its name “CoreWeave” appears in a filing in this case.
…following third- parties in this district: xAI, Meta, CoreWeave, Google, and Oracle. See, e.g., Case Nos. 7:26-mc-…
A free copy from the RECAP archive of federal court filings (mirrored at the Internet Archive), retrieved September 29, 2026. Federal court filings are public records.
Document text
27 page(s), 64,877 characters, converted from the PDF's text layer · plain text.
Full text
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 1 of 27
EXHIBIT
5
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 2 of 27
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
MIDLAND/ODESSA DIVISION
NEURAL AI, LLC,
Plaintiff, Civil Action No. 7:24-cv-00221-ADA-DTG
v. JURY TRIAL DEMANDED
NVIDIA CORPORATION,
Defendant.
PLAINTIFF NEURAL AI, LLC’S NOTICE OF SERVICE
OF SUBPOENA TO TESLA, INC.
PLEASE TAKE NOTICE that Plaintiff Neural AI, LLC (“Neural AI”) will serve (1) a
Subpoena to Produce Documents, Information, or Objects on Tesla, Inc. (“Tesla”), attached hereto
as Attachment 1, and (2) a Subpoena for Testimony on Tesla, attached as Attachment 2.
Dated: June 24, 2026
Respectfully submitted,
/s/ Emily Portuguese
Max L. Tribble
Texas State Bar 20213950
Brian D. Melton
Texas State Bar 24010620
Rocco Magni
Texas State Bar 24092745
Samuel Drezdzon
Texas State Bar 24117374
SUSMAN GODFREY L.L.P.
1000 Louisiana
Suite 5100
Houston, TX 77002
Telephone: (713) 651-9366
Facsimile: (713) 654-6666
mtribble@susmangodfrey.com
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 3 of 27
bmelton@susmangodfrey.com
rmagni@susmangodfrey.com
sdrezdzon@susmangodfrey.com
Tamar Lusztig
NY State Bar 5125174
Emily Portuguese
NY State Bar 5920327
One Manhattan West, 50th Floor
New York, NY 10001
tlusztig@susmangodfrey.com
eportuguese@susmangodfrey.com
Tanner Laiche
WA State Bar 5125174
401 Union Street, Suite 3000
Seattle, WA 98101
tlaiche@susmangodfrey.com
Mark D. Siegmund
Texas State Bar No. 24117055
CHERRY JOHSON SIEGMUND
JAMES PC
Bridgeview Center
7901 Fish Pond Road, 2nd Floor
Waco, Texas 76710
msiegmund@cjsjlaw.com
Max Ciccarelli
Texas State Bar No. 00787242
CICCARELLI LAW FIRM LLC
100 N. 6th Street, Suite 502
Waco, Texas 76701
Max@CiccarelliLawFirm.com
Attorneys for Plaintiff Neural AI, LLC
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 4 of 27
CERTIFICATE OF SERVICE
I certify that on June 24, 2026 true and correct copies of Neural AI’s Subpoena to
Produce Documents, Information, or Objects and Subpoena for Testimony on Tesla has been
served all counsel of record electronically.
/s/ Emily Portuguese
Emily Portuguese
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 5 of 27
Attachment 1
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 6 of 27
AO 88B (Rev. 06/09) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________
Western District of __________
Texas
Neural Al, LLC )
Plaintiff )
v. ) Civil Action No. 7:24-cv-00221-ADA-DTG
NVIDIA Corporation )
) (If the action is pending in another district, state where:
Defendant ) __________ District of __________ )
SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS
OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
Tesla,
To: Google Inc.
LLC
-
c/o C T Corporation
clo Corporation System, 1999
Service Company BryanLawyers
OBA CSC- St., Suite
Inc,900, Dallas,
211 E. TX 75201
7th Street, Suite 620, Austin, TX 78701
Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the
material: See Exhibit A
Place: Planet Depos- Downtown Austin clo Lexitas Legal, Date and Time:
100 Congress Ave, Ste. 2000, Austin, TX 78701
0711412026 11 :59 pm
0 Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.
Place: Date and Time:
The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule
45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are
attached.
Date: 06/24/2026
CLERK OF COURT
OR
Isl Emily Portuguese
Signature of Clerk or Deputy Clerk Attorney’s signature
The name, address, e-mail, and telephone number of the attorney representing (name of party)
Neural Al LLC , who issues or requests this subpoena, are:
Emily Portuguese, Susman Godfrey LLP, One Manhattan West, 50th Floor, New York, New York 10001
eportuguese@susmangodfrey.com, 212-729-2082
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 7 of 27
AO 88B (Rev. 06/09) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action (Page 2)
Civil Action No. 7:24-cv-00221-ADA-DTG
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)
This subpoena for (name of individual and title, if any)
was received by me on (date) .
0 I served the subpoena by delivering a copy to the named person as follows:
on (date) ; or
0 I returned the subpoena unexecuted because:
.
Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
tendered to the witness fees for one day’s attendance, and the mileage allowed by law, in the amount of
$ .
My fees are $ for travel and $ for services, for a total of $ 0.00 .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 8 of 27
AO 88B (Rev. 06/09) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action(Page 3)
Federal Rule of Civil Procedure 45 (c), (d), and (e) (Effective 12/1/07)
(c) Protecting a Person Subject to a Subpoena. (d) Duties in Responding to a Subpoena.
(1) Avoiding Undue Burden or Expense; Sanctions. A party or (1) Producing Documents or Electronically Stored Information.
attorney responsible for issuing and serving a subpoena must take These procedures apply to producing documents or electronically
reasonable steps to avoid imposing undue burden or expense on a stored information:
person subject to the subpoena. The issuing court must enforce this (A) Documents. A person responding to a subpoena to produce
duty and impose an appropriate sanction — which may include lost documents must produce them as they are kept in the ordinary
earnings and reasonable attorney’s fees — on a party or attorney course of business or must organize and label them to correspond to
who fails to comply. the categories in the demand.
(2) Command to Produce Materials or Permit Inspection. (B) Form for Producing Electronically Stored Information Not
(A) Appearance Not Required. A person commanded to produce Specified. If a subpoena does not specify a form for producing
documents, electronically stored information, or tangible things, or electronically stored information, the person responding must
to permit the inspection of premises, need not appear in person at the produce it in a form or forms in which it is ordinarily maintained or
place of production or inspection unless also commanded to appear in a reasonably usable form or forms.
for a deposition, hearing, or trial. (C) Electronically Stored Information Produced in Only One
(B) Objections. A person commanded to produce documents or Form. The person responding need not produce the same
tangible things or to permit inspection may serve on the party or electronically stored information in more than one form.
attorney designated in the subpoena a written objection to (D) Inaccessible Electronically Stored Information. The person
inspecting, copying, testing or sampling any or all of the materials or responding need not provide discovery of electronically stored
to inspecting the premises — or to producing electronically stored information from sources that the person identifies as not reasonably
information in the form or forms requested. The objection must be accessible because of undue burden or cost. On motion to compel
served before the earlier of the time specified for compliance or 14 discovery or for a protective order, the person responding must show
days after the subpoena is served. If an objection is made, the that the information is not reasonably accessible because of undue
following rules apply: burden or cost. If that showing is made, the court may nonetheless
(i) At any time, on notice to the commanded person, the serving order discovery from such sources if the requesting party shows
party may move the issuing court for an order compelling production good cause, considering the limitations of Rule 26(b)(2)(C). The
or inspection. court may specify conditions for the discovery.
(ii) These acts may be required only as directed in the order, and (2) Claiming Privilege or Protection.
the order must protect a person who is neither a party nor a party’s (A) Information Withheld. A person withholding subpoenaed
officer from significant expense resulting from compliance. information under a claim that it is privileged or subject to
(3) Quashing or Modifying a Subpoena. protection as trial-preparation material must:
(A) When Required. On timely motion, the issuing court must (i) expressly make the claim; and
quash or modify a subpoena that: (ii) describe the nature of the withheld documents,
(i) fails to allow a reasonable time to comply; communications, or tangible things in a manner that, without
(ii) requires a person who is neither a party nor a party’s officer revealing information itself privileged or protected, will enable the
to travel more than 100 miles from where that person resides, is parties to assess the claim.
employed, or regularly transacts business in person — except that, (B) Information Produced. If information produced in response to a
subject to Rule 45(c)(3)(B)(iii), the person may be commanded to subpoena is subject to a claim of privilege or of protection as trial-
attend a trial by traveling from any such place within the state where preparation material, the person making the claim may notify any
the trial is held; party that received the information of the claim and the basis for it.
(iii) requires disclosure of privileged or other protected matter, if After being notified, a party must promptly return, sequester, or
no exception or waiver applies; or destroy the specified information and any copies it has; must not use
(iv) subjects a person to undue burden. or disclose the information until the claim is resolved; must take
(B) When Permitted. To protect a person subject to or affected by reasonable steps to retrieve the information if the party disclosed it
a subpoena, the issuing court may, on motion, quash or modify the before being notified; and may promptly present the information to
subpoena if it requires: the court under seal for a determination of the claim. The person
(i) disclosing a trade secret or other confidential research, who produced the information must preserve the information until
development, or commercial information; the claim is resolved.
(ii) disclosing an unretained expert’s opinion or information that
does not describe specific occurrences in dispute and results from (e) Contempt. The issuing court may hold in contempt a person
the expert’s study that was not requested by a party; or who, having been served, fails without adequate excuse to obey the
(iii) a person who is neither a party nor a party’s officer to incur subpoena. A nonparty’s failure to obey must be excused if the
substantial expense to travel more than 100 miles to attend trial. subpoena purports to require the nonparty to attend or produce at a
(C) Specifying Conditions as an Alternative. In the circumstances place outside the limits of Rule 45(c)(3)(A)(ii).
described in Rule 45(c)(3)(B), the court may, instead of quashing or
modifying a subpoena, order appearance or production under
specified conditions if the serving party:
(i) shows a substantial need for the testimony or material that
cannot be otherwise met without undue hardship; and
(ii) ensures that the subpoenaed person will be reasonably
compensated.
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 9 of 27
EXHIBIT A
DEFINITIONS AND INSTRUCTIONS
1. The term “NVIDIA GPUs” means the Hopper, Ada Lovelace, Ampere, Turing,
Volta, Pascal, Maxwell, Jetson, and Blackwell architectures of NVIDIA graphics processing units.
For avoidance of doubt, those architectures include the following devices: DGX line of
supercomputers and servers (including at least DGX B300, DGX B200, DGX GB200, DGX
GB300, DGX Spark, DGX Station, DGX SuperPOD with GB300, DGX SuperPOD with GB200,
DGX H200, DGX H100, DGX BasePOD, DGX SuperPOD with H200, DGX A100), HGX line of
supercomputers and servers (including at least HGX B300, HGX B200, HGX H100, HGX H200,
Eos SuperPOD), OVX line of supercomputers and servers (including at least OVX L40S), EGX
line of supercomputers and servers (including at least EGX Server with Quadro RTX A6000, EGX
Server with A40, EGX Server with Quadro RTX 8000, EGX Server with Quadro RTX 6000),
GB300 NVL72, GB200 NVL72; Nvidia’s GPU accelerators and superchips, including those with
NVIDIA’s Blackwell, Hopper, Ada Lovelace, Ampere, Turing, Volta, Pascal, and Maxwell GPU
architectures, including at least, RTX PRO 6000 Server Edition, RTX PRO 6000 Workstation,
RTX PRO 6000 Max-Q Workstation, RTX PRO 5000, RTX PRO 4500, RTX PRO 4000, RTX
PRO 3000, RTX PRO 2000, RTX PRO 1000, RTX PRO 500, GB300, GB200, H100, H200,
GH200, GH100, L40, L40S, L4, RTX 6000, RTX 6000 Ada, RTX 5000, Ada, RTX 4500 Ada,
RTX 4000 Ada, RTX 4000 SFF, RTX 3500, RTX 3000, RTX 2000, RTX 1000, RTX 500, RTX
4090, RTX 4080 SUPER, RTX 4070 Ti SUPER, RTX 4070 SUPER, RTX 4070, RTX 4060 Ti,
and RTX 4060, GeForce RTX 4090 Laptop GPU, GeForce RTX 4080 Laptop GPU, GeForce RTX
4070 Laptop GPU, GeForce RTX 4060 Laptop GPU, GeForce RTX 4050 Laptop GPU, A100,
A40, A30, A16, A10, A2, A800 40GB Active, RTX A6000, RTX A5500, RTX A5000, RTX
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 10 of 27
A4500, RTX A4000, RTX A2000, RTX A2000 12GB, RTX A1000, RTX A400, RTX A5500,
RTX A4500, RTX A3000 12GB, RTX A2000 8GB, RTX A1000 6GB, RTX A500, GeForce RTX
3090 Ti, GeForce RTX 3090, GeForce RTX 3080 Ti, GeForce RTX 3080, GeForce RTX 3070 Ti,
GeForce RTX 3070, GeForce RTX 3060 Ti, GeForce RTX 3060, GeForce RTX 3050 (8 GB),
GeForce RTX 3050 (6 GB), GeForce RTX 3080 Ti Laptop GPU, GeForce RTX 3080 Laptop
GPU, GeForce RTX 3070 Ti Laptop GPU, GeForce RTX 3070 Laptop GPU, GeForce RTX 3060
Laptop GPU, GeForce RTX 3050 Ti Laptop GPU, GeForce RTX 3050 Laptop GPU, GeForce
MX570 Laptop GPU, Tesla T4 GPUs, Quadro RTX 8000, Quadro RTX 6000, Quadro RTX 8000,
Quadro RTX 6000, Quadro RTX 5000, Quadro RTX 4000, Quadro RTX 3000, Quadro T2000,
T1000 8GB, T1200, Quadrio T1000, T1000 (4GB), T600, T550, T500 T400, T400 4GB, Titan
RTX, GeForce RTX 2080 Ti, GeForce RTX 2080, Super, GeForce RTX 2080, GeForce RTX 2070
Super, GeForce RTX 2070, GeForce RTX 2060 Super, GeForce RTX 2060, GeForce RTX 2500,
GeForce GTX 1660 Ti, GeForce GTX 1660 Super, GeForce GTX 1660, GeForce GTX 1650 Ti,
GeForce GTX 1650 Super, GeForce GTX 1650 (G5), GeForce GTX 1650 (G6), GeForce GTX
1650, GeForce GTX 1630, GeForce MX550, GeForce MX450, GeForce MX430, Tesla V100,
Quadro GV100, Titan V GPU, Tesla P100, P40, P4, Quadro GP100, Quadro P6000, Quadro
P5200, Quadro P5000, Quadro P4200, Quadro P4000, Quadro P3200, Quadro P3000, Quadro
P2200, Quadro P2000, Quadro P1000, Quadro P620, Quadro P600, Quadro P520, Quadro P500,
Quadro P400, Titan Xp, Titan X, GeForce GTX 1080 Ti, GeForce GTX 1080, GeForce GTX 1070
Ti, GeForce GTX 1070, GeForce GTX 1060, GeForce GTX 1050 Ti, GeForce GTX 1050,
GeForce MX300, GeForce MX200, GeForce MX150, Tesla M60, M40, M10, Quadro M6000
24GB, Quadro M6000 (12GB), Quadro M5000, Quadro M5000M, Quadro M5500, Quadro
M4000, Quadro M4000M, Quadro M3000M, Quadro M2200, Quadro M2000, Quadro M2000M,
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 11 of 27
Quadro M1200, Quadro M1000M, Quadro M620, Quadro M600M, Quadro M520, Quadro
M500M, NVS 810, Tesla M6, GTX Titan X, GeForce GTX 980Ti, GeForce GTX 980, GeForce
GTX 970, GeForce GTX 960, GeForce GTX 980M, GeForce GTX 970M, GeForce GTX 965M,
GeForce GTX 960M, GeForce GTX 950M, GeForce GTX 750 Ti, GeForce GTX 750, GeForce
MX130, and GeForce MX110; and Jetson modules, including at least the Jetson Thor Series,
Jetson Thor, Jetson T5000, Jetson T4000, Jetson AGX Orin Series, Jetson AGX Orin Developer
Kit, Jetson AGX Orin 64GB, Jetson AGX Orin Industrial, Jetson AGX Orin 32GB, Jetson Orin
NX Series, Jetson Orin NX 16GB, Jetson Orin NX 8GB, Jetson Orin Nano Series, Jetson Orin
Nano Super Developer Kit, Jetson Orin Nano 8GB, Jetson Orin Nano 4GB, Jetson AGX Xavier
Series, Jetson AGX Xavier Industrial, Jetson AGX Xavier 64GB, Jetson AGX Xavier 32GB,
Jetson Xavier NX Series, Jetson Xavier NX 16GB, Jetson Xavier NX 8GB, Jetson TX2 Series,
Jetson TX2i, Jetson TX2, Jetson TX2 4GB, Jetson TX2 NX, Jetson Nano, any and all variations
of the aforementioned products (including at least products having different options for number of
GPUs).
2. The terms “and” and “or” are not intended to be read disjunctively but rather
conjunctively unless the context of a particular request clearly indicates otherwise. “Or” should be
understood to include and encompass “and”; and “and” should be understood to include and
encompass “or.”
3. The terms “any” or “each” should be understood to include and encompass “all.”
4. The terms “concerning,” “related to” or “relating to”, and “regarding” and any
variation of these terms mean analyzing, alluding to, concerning, considering, commenting on,
consulting, comprising, containing, contradicting, describing, dealing with, discussing,
establishing, evidencing, identifying, involving, noting, recording, reporting on, relating to,
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 12 of 27
reflecting, referring to, regarding, stating, showing, studying, mentioning, memorializing, or
pertaining to, directly or indirectly, in whole or in part.
5. The term “CPU(s)” means Central Processing Unit(s).
6. The term “Document(s)” shall have the broadest meaning possible under Federal
Rules 26 and 34 and shall include without limitation: documents, Electronically Stored
Information, communications in written, electronic, and recorded form, and tangible things. A
draft or non-identical copy of a document shall be considered a separate document within the
meaning of the term “document.” Any comment, notation, or other marking shall be sufficient to
distinguish documents that are otherwise similar in appearance and to make them separate
documents for purposes of your response. Any preliminary form, intermediate form, superseded
version, or amendment of any document is to be considered a separate document.
7. The term “GPU(s)” means Graphics Processing Unit(s).
8. The terms “include” and “including” mean including without limitation.
9. The term “NVIDIA” means Defendant NVIDIA Corporation, its predecessors,
present and former directors, officers, accountants, affiliates, attorneys, partners, managers, agents,
employees, representatives, in-house and outside counsel, and any other person or entity acting on
behalf of or under control of Defendant NVIDIA Corporation.
10. The term “person(s)” means and includes natural persons and formal or informal
entities and organizations, including public and private corporations, partnerships, professional
corporations, limited liability companies, business trusts, banking institutions, associations, firms,
joint ventures, commissions, bureaus, departments, and any other legal entity, including
any divisions, subsidiaries, departments, and other units thereof.
11. The term “Source Code” means human-readable instructions written in a
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 13 of 27
programming language, including all comments, annotations, declarations, functions, classes, and
other components used to define the behavior of a software program. For purposes of these
requests, “Source Code” includes all associated files necessary to understand, compile, and execute
the code, such as scripts, header files, makefiles, configuration files, and documentation. Unless
otherwise stated, “Source Code” includes all versions and revisions relevant to the time periods
and subject matter described in each interrogatory.
12. The terms “You” or “Your” refer to Tesla, Inc., including but not limited to its
predecessors, successors, parents, subsidiaries, divisions, affiliates, and all past or present
directors, officers, partners, managers, employees, contractors, agents, representatives,
accountants, consultants, in-house and outside counsel, and any other person or entity acting or
purporting to act on its behalf or subject to its control. This definition expressly includes, without
limitation, any Tesla parent, subsidiary, affiliate, or other related entity that has used, licensed,
deployed, evaluated, or integrated NVIDIA GPUs or software.
13. The use of the singular form of any word includes the plural and vice versa.
14. These Requests seek the production of all documents, electronically stored
information (“ESI”), and tangible things in your possession, custody, or control, as that phrase is
used in Federal Rule of Civil Procedure 34, as of the date of compliance with this subpoena and
that come into your possession, custody, or control at any time prior to production. This includes
materials held by You directly, as well as by Your affiliates, subsidiaries, agents, representatives,
or any other person or entity acting on Your behalf.
15. If You are aware of the existence (past or present) of any responsive documents,
ESI, or tangible items that are not in Your current possession, custody, or control, You must
identify such materials and provide:
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 14 of 27
a. A description of the item(s);
b. The name and contact information of the person or entity currently believed
to have possession, custody, or control; and
c. The reason You are unable to produce the material(s).
16. If You believe that no responsive documents, ESI, or tangible things exist in
response to a particular request, You must state so in writing with respect to that request.
17. If You withhold any document, ESI, or portion thereof based on a claim of attorney-
client privilege, work product doctrine, or any other legal protection, You must produce a privilege
log that complies with Federal Rule of Civil Procedure 26(b)(5).
18. You must produce all documents and ESI: as they are kept in the usual course of
business or organized and labeled to correspond to the categories in this subpoena, as required
under FRCP 34(b)(2)(E); in their native electronic format (with original metadata intact) wherever
possible, or as searchable, OCR-scanned PDFs with corresponding load files; with complete
family groupings (e.g., attachments must be produced with their parent emails/documents); and in
the same folders or directories in which they were maintained, preserving original file structures
and naming conventions.
19. You must maintain and produce a record of the source of each document or ESI
item produced, including:
a. The file path or directory location;
b. The name of the custodian (individual, team, or department) from whose
files the document was collected;
c. The system or platform (e.g., email server, shared drive, cloud service) from
which the document was obtained.
This information may be provided in metadata load files, a source log, or other mutually agreed
format. This instruction is consistent with Federal Rule of Civil Procedure 34(b)(2)(E) and
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 15 of 27
proportional discovery principles under Rule 26(b)(1). If any of the above information is not
reasonably available or unduly burdensome to collect, You must so state and explain the basis for
that assertion.
20. For all ESI, You must preserve and produce standard metadata fields, including but
not limited to: filename, filepath, author, date created, date last modified, recipients, sender,
subject line (for emails), and document type. You must not degrade or alter metadata through
processing or production.
21. You are under a continuing obligation to supplement or correct Your production if
You discover or obtain additional responsive materials prior to the close of discovery or the
resolution of this matter.
22. Unless otherwise stated, the relevant period is from September 13, 2018 to the
present.
23. Unless otherwise stated, all requests herein are limited to documents, electronically
stored information, and tangible things that relate to NVIDIA GPU-Acceleration Hardware or
NVIDIA GPU-Acceleration Software that were:
a. purchased, acquired, licensed, used, implemented, deployed, tested, or
evaluated within the United States, or
b. purchased, acquired, licensed, or used for the purpose of supporting,
enabling, or operating any facility, system, team, data center, personnel,
product, service, customer, or business activity located in or directed toward
the United States.
This instruction is intended to encompass both U.S.-based activity and non-U.S. activity that
directly supports or enables U.S. operations or usage.
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 16 of 27
REQUESTS FOR PRODUCTION OF DOCUMENTS
1. Documents sufficient to identify all software, frameworks, libraries, APIs, scripts, Source
Code, configuration files, and custom code You use to perform computations on NVIDIA
GPUs.
2. Documents sufficient to show whether You use NVIDIA’s Aerial, Clara Parabricks, cuBLAS,
cuDNN, cuFFT, cuQuantum, cuSOLVER, cuSPARSE, Drive, DriveWorks, Holoscan, Isaac,
Isaac Lab, Maxine, Memory Map, Merlin, Metropolis, Modulus, Monai, Morpheus, NeMo,
PyTorch, RAPIDS, Riva, Runtime Driver, TensorFlow, TensorRT, Triton, VSS (Deepstream),
or any other NVIDIA software as part of computations You perform using NVIDIA GPUs.
3. Documents sufficient to show whether You use sample Source Code provided by NVIDIA as
part of computations You perform using NVIDIA GPUs.
4. Documents sufficient to show whether and how any software You use to perform
computations on NVIDIA GPUs calls, invokes, interfaces with, wraps, depends on, sits on top
of, modifies, extends, or implements functionality provided by CUDA, cuDNN, TensorRT,
CUDA libraries, CUDA drivers, CUDA runtime, CUDA applications or frameworks or any
other NVIDIA software.
5. Documents sufficient to show the architecture, design, data flow, control flow, and execution
flow of any system in which You use NVIDIA GPUs to perform computations, including
diagrams, technical specifications, design documents, Powerpoints, slide decks, internal and
external presentations, Source Code, configuration files, build files, deployment files, runtime
logs, and profiler traces.
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 17 of 27
6. Documents sufficient to show whether computations You performed using NVIDIA GPUs
involved artificial neural networks, neural-network computational layers or computations with
outputs as inputs for other neurons or layers.
7. Documents sufficient to show whether You use a pointer to data stored in memory (e.g.
memory bank or partition), using as an input to a subsequent computational layer the pointer
to output data from a GPU computation, using pointers in neural network computations,
swapping an input pointer with the pointer to data output from a GPU computation, pointer
swapping, pointer rotation, buffer swapping, ping-pong buffers, double or triple buffering,
alternating input/output buffers, or any other technique in which output data from one
computation, layer, iteration, time step, or cycle becomes input data for a later computation,
layer, iteration, time step, or cycle.
8. Documents sufficient to show whether You store input data, output data, intermediate results,
tensors, activations, weights, parameters, internal variables, GPU programs, kernels, textures,
shaders, or other GPU-computation-related data in separate, partitioned, logical, physical,
first/second, input/output, texture, shader, shared, global, device, host, pinned, GPU RAM,
GPU cache(s), or unified memory regions (shared by CPU and GPU) when performing
computations using NVIDIA GPUs.
9. Documents sufficient to show how input data is received, acquired, stored, transferred, copied,
streamed, prefetched, staged, queued, or loaded from CPU memory, host memory, system
memory, storage, sensors, cameras, or other input sources to NVIDIA GPU memory—
including GPU RAM (e.g. GPU HBM, GDDR) and/or GPU cache(s)—before, during, or in
parallel with computations You perform using NVIDIA GPUs.
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 18 of 27
10. Documents sufficient to show how output data from a GPU computation(s), intermediate
results of GPU computations, tensors, buffers, activations, variables, or other computation
results are stored, transferred, copied, streamed, written back, returned, accumulated, reused,
or made available including asynchronously from NVIDIA GPU memory to CPU memory,
host memory, system memory, storage, display, network, or another memory location before,
during, or in parallel with computations You perform using NVIDIA GPUs—and also
including in the opposite direction, copying data from CPU or host or other memory to a queue
for GPU computation while other GPU computations are occurring.
11. Documents sufficient to show how computations You perform using NVIDIA GPUs are
scheduled, ordered, controlled, queued, synchronized, parallelized, launched, interrupted,
resumed, or executed, including through kernels, CUDA streams, CUDA graphs, events,
threads, controllers, schedulers, compilers, runtimes, inference engines, run lists, run engines,
or custom software.
12. Documents sufficient to show whether and how user inputs, user commands, configuration
changes, parameter changes, model changes, computational-element changes, input changes,
interruptions, or display/output changes affect computations You perform using NVIDIA
GPUs and/or queue them for GPU computation.
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 19 of 27
Attachment 2
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 20 of 27
AO 88A (Rev. 02/14) Subpoena to Testify at a Deposition in a Civil Action
UNITED STATES DISTRICT COURT
for the
Western District of __________
__________ Texas
NeuralAl,
Nerual AI,LLC
LLC )
Plaintiff )
v. ) Civil Action No. 7:24-cv-00221-ADA-DTG
NVIDIA Corporation )
)
Defendant )
SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
To: Tesla, Inc. Google LLC
c/o
c/o C T Corporation
Corporation System,
Service 1999 Bryan
Company St., Suite
DBA CSC- 900, Inc,
Lawyers Dallas,
211 TX 75201
E. 7th Street, Suite 620, Austin, TX 78701
(Name of person to whom this subpoena is directed)
Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a
deposition to be taken in this civil action. If you are an organization, you must designate one or more officers, directors,
or managing agents, or designate other persons who consent to testify on your behalf about the following matters, or
those set forth in an attachment:
See Exhibit A.
Place: Planet Depos - Downtown Austin c/o Lexitas Legal, Date and Time:
100 Congress Ave, Ste. 2000, Austin, TX 78701 07/21/2026 9:00 am
The deposition will be recorded by this method: audio, video, and stenographic means
0 Production: You, or your representatives, must also bring with you to the deposition the following documents,
electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the
material:
The following provisions of Fed. R. Civ. P. 45 are attached – Rule 45(c), relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date: 06/24/2026
CLERK OF COURT
OR
/s/ Emily Portuguese
Signature of Clerk or Deputy Clerk Attorney’s signature
The name, address, e-mail address, and telephone number of the attorney representing (name of party)
Neural Al, LLC , who issues or requests this subpoena, are:
Emily Portuguese, Susman Godfrey LLP, One Manhattan West, 50th Floor, New York, New York 10001
eportuguese®susmangodfi'ey.com, 212-729-2082
Notice to the person who issues or requests this subpoena
If this subpoena commands the production of documents, electronically stored information, or tangible things before
trial, a notice and a copy of the subpoena must be served on each party in this case before it is served on the person to
whom it is directed. Fed. R. Civ. P. 45(a)(4).
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 21 of 27
AO 88A (Rev. 02/14) Subpoena to Testify at a Deposition in a Civil Action (Page 2)
Civil Action No. 7:24-cv-00221-ADA-DTG
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)
I received this subpoena for (name of individual and title, if any)
on (date) .
0 I served the subpoena by delivering a copy to the named individual as follows:
on (date) ; or
0 I returned the subpoena unexecuted because:
.
Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
tendered to the witness the fees for one day’s attendance, and the mileage allowed by law, in the amount of
$ .
My fees are $ for travel and $ for services, for a total of $ 0.00 .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc.:
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 22 of 27
AO 88A (Rev. 02/14) Subpoena to Testify at a Deposition in a Civil Action (Page 3)
Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13)
(c) Place of Compliance. (i) disclosing a trade secret or other confidential research, development,
or commercial information; or
(1) For a Trial, Hearing, or Deposition. A subpoena may command a (ii) disclosing an unretained expert’s opinion or information that does
person to attend a trial, hearing, or deposition only as follows: not describe specific occurrences in dispute and results from the expert’s
(A) within 100 miles of where the person resides, is employed, or study that was not requested by a party.
regularly transacts business in person; or (C) Specifying Conditions as an Alternative. In the circumstances
(B) within the state where the person resides, is employed, or regularly described in Rule 45(d)(3)(B), the court may, instead of quashing or
transacts business in person, if the person modifying a subpoena, order appearance or production under specified
(i) is a party or a party’s officer; or conditions if the serving party:
(ii) is commanded to attend a trial and would not incur substantial (i) shows a substantial need for the testimony or material that cannot be
expense. otherwise met without undue hardship; and
(ii) ensures that the subpoenaed person will be reasonably compensated.
(2) For Other Discovery. A subpoena may command:
(A) production of documents, electronically stored information, or (e) Duties in Responding to a Subpoena.
tangible things at a place within 100 miles of where the person resides, is
employed, or regularly transacts business in person; and (1) Producing Documents or Electronically Stored Information. These
(B) inspection of premises at the premises to be inspected. procedures apply to producing documents or electronically stored
information:
(d) Protecting a Person Subject to a Subpoena; Enforcement. (A) Documents. A person responding to a subpoena to produce documents
must produce them as they are kept in the ordinary course of business or
(1) Avoiding Undue Burden or Expense; Sanctions. A party or attorney must organize and label them to correspond to the categories in the demand.
responsible for issuing and serving a subpoena must take reasonable steps (B) Form for Producing Electronically Stored Information Not Specified.
to avoid imposing undue burden or expense on a person subject to the If a subpoena does not specify a form for producing electronically stored
subpoena. The court for the district where compliance is required must information, the person responding must produce it in a form or forms in
enforce this duty and impose an appropriate sanction—which may include which it is ordinarily maintained or in a reasonably usable form or forms.
lost earnings and reasonable attorney’s fees—on a party or attorney who (C) Electronically Stored Information Produced in Only One Form. The
fails to comply. person responding need not produce the same electronically stored
information in more than one form.
(2) Command to Produce Materials or Permit Inspection. (D) Inaccessible Electronically Stored Information. The person
(A) Appearance Not Required. A person commanded to produce responding need not provide discovery of electronically stored information
documents, electronically stored information, or tangible things, or to from sources that the person identifies as not reasonably accessible because
permit the inspection of premises, need not appear in person at the place of of undue burden or cost. On motion to compel discovery or for a protective
production or inspection unless also commanded to appear for a deposition, order, the person responding must show that the information is not
hearing, or trial. reasonably accessible because of undue burden or cost. If that showing is
(B) Objections. A person commanded to produce documents or tangible made, the court may nonetheless order discovery from such sources if the
things or to permit inspection may serve on the party or attorney designated requesting party shows good cause, considering the limitations of Rule
in the subpoena a written objection to inspecting, copying, testing, or 26(b)(2)(C). The court may specify conditions for the discovery.
sampling any or all of the materials or to inspecting the premises—or to
producing electronically stored information in the form or forms requested. (2) Claiming Privilege or Protection.
The objection must be served before the earlier of the time specified for (A) Information Withheld. A person withholding subpoenaed information
compliance or 14 days after the subpoena is served. If an objection is made, under a claim that it is privileged or subject to protection as trial-preparation
the following rules apply: material must:
(i) At any time, on notice to the commanded person, the serving party (i) expressly make the claim; and
may move the court for the district where compliance is required for an (ii) describe the nature of the withheld documents, communications, or
order compelling production or inspection. tangible things in a manner that, without revealing information itself
(ii) These acts may be required only as directed in the order, and the privileged or protected, will enable the parties to assess the claim.
order must protect a person who is neither a party nor a party’s officer from (B) Information Produced. If information produced in response to a
significant expense resulting from compliance. subpoena is subject to a claim of privilege or of protection as
trial-preparation material, the person making the claim may notify any party
(3) Quashing or Modifying a Subpoena. that received the information of the claim and the basis for it. After being
notified, a party must promptly return, sequester, or destroy the specified
(A) When Required. On timely motion, the court for the district where information and any copies it has; must not use or disclose the information
compliance is required must quash or modify a subpoena that: until the claim is resolved; must take reasonable steps to retrieve the
information if the party disclosed it before being notified; and may promptly
(i) fails to allow a reasonable time to comply; present the information under seal to the court for the district where
(ii) requires a person to comply beyond the geographical limits compliance is required for a determination of the claim. The person who
specified in Rule 45(c); produced the information must preserve the information until the claim is
(iii) requires disclosure of privileged or other protected matter, if no resolved.
exception or waiver applies; or
(iv) subjects a person to undue burden. (g) Contempt.
(B) When Permitted. To protect a person subject to or affected by a The court for the district where compliance is required—and also, after a
subpoena, the court for the district where compliance is required may, on motion is transferred, the issuing court—may hold in contempt a person
motion, quash or modify the subpoena if it requires: who, having been served, fails without adequate excuse to obey the
subpoena or an order related to it.
For access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013).
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 23 of 27
EXHIBIT A
DEFINITIONS AND INSTRUCTIONS
24. The term “NVIDIA GPUs” means the Hopper, Ada Lovelace, Ampere, Turing,
Volta, Pascal, Maxwell, Jetson, and Blackwell architectures of NVIDIA graphics processing units.
For avoidance of doubt, those architectures include the following devices: DGX line of
supercomputers and servers (including at least DGX B300, DGX B200, DGX GB200, DGX
GB300, DGX Spark, DGX Station, DGX SuperPOD with GB300, DGX SuperPOD with GB200,
DGX H200, DGX H100, DGX BasePOD, DGX SuperPOD with H200, DGX A100), HGX line of
supercomputers and servers (including at least HGX B300, HGX B200, HGX H100, HGX H200,
Eos SuperPOD), OVX line of supercomputers and servers (including at least OVX L40S), EGX
line of supercomputers and servers (including at least EGX Server with Quadro RTX A6000, EGX
Server with A40, EGX Server with Quadro RTX 8000, EGX Server with Quadro RTX 6000),
GB300 NVL72, GB200 NVL72; Nvidia’s GPU accelerators and superchips, including those with
NVIDIA’s Blackwell, Hopper, Ada Lovelace, Ampere, Turing, Volta, Pascal, and Maxwell GPU
architectures, including at least, RTX PRO 6000 Server Edition, RTX PRO 6000 Workstation,
RTX PRO 6000 Max-Q Workstation, RTX PRO 5000, RTX PRO 4500, RTX PRO 4000, RTX
PRO 3000, RTX PRO 2000, RTX PRO 1000, RTX PRO 500, GB300, GB200, H100, H200,
GH200, GH100, L40, L40S, L4, RTX 6000, RTX 6000 Ada, RTX 5000, Ada, RTX 4500 Ada,
RTX 4000 Ada, RTX 4000 SFF, RTX 3500, RTX 3000, RTX 2000, RTX 1000, RTX 500, RTX
4090, RTX 4080 SUPER, RTX 4070 Ti SUPER, RTX 4070 SUPER, RTX 4070, RTX 4060 Ti,
and RTX 4060, GeForce RTX 4090 Laptop GPU, GeForce RTX 4080 Laptop GPU, GeForce RTX
4070 Laptop GPU, GeForce RTX 4060 Laptop GPU, GeForce RTX 4050 Laptop GPU, A100,
A40, A30, A16, A10, A2, A800 40GB Active, RTX A6000, RTX A5500, RTX A5000, RTX
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 24 of 27
A4500, RTX A4000, RTX A2000, RTX A2000 12GB, RTX A1000, RTX A400, RTX A5500,
RTX A4500, RTX A3000 12GB, RTX A2000 8GB, RTX A1000 6GB, RTX A500, GeForce RTX
3090 Ti, GeForce RTX 3090, GeForce RTX 3080 Ti, GeForce RTX 3080, GeForce RTX 3070 Ti,
GeForce RTX 3070, GeForce RTX 3060 Ti, GeForce RTX 3060, GeForce RTX 3050 (8 GB),
GeForce RTX 3050 (6 GB), GeForce RTX 3080 Ti Laptop GPU, GeForce RTX 3080 Laptop
GPU, GeForce RTX 3070 Ti Laptop GPU, GeForce RTX 3070 Laptop GPU, GeForce RTX 3060
Laptop GPU, GeForce RTX 3050 Ti Laptop GPU, GeForce RTX 3050 Laptop GPU, GeForce
MX570 Laptop GPU, Tesla T4 GPUs, Quadro RTX 8000, Quadro RTX 6000, Quadro RTX 8000,
Quadro RTX 6000, Quadro RTX 5000, Quadro RTX 4000, Quadro RTX 3000, Quadro T2000,
T1000 8GB, T1200, Quadrio T1000, T1000 (4GB), T600, T550, T500 T400, T400 4GB, Titan
RTX, GeForce RTX 2080 Ti, GeForce RTX 2080, Super, GeForce RTX 2080, GeForce RTX 2070
Super, GeForce RTX 2070, GeForce RTX 2060 Super, GeForce RTX 2060, GeForce RTX 2500,
GeForce GTX 1660 Ti, GeForce GTX 1660 Super, GeForce GTX 1660, GeForce GTX 1650 Ti,
GeForce GTX 1650 Super, GeForce GTX 1650 (G5), GeForce GTX 1650 (G6), GeForce GTX
1650, GeForce GTX 1630, GeForce MX550, GeForce MX450, GeForce MX430, Tesla V100,
Quadro GV100, Titan V GPU, Tesla P100, P40, P4, Quadro GP100, Quadro P6000, Quadro
P5200, Quadro P5000, Quadro P4200, Quadro P4000, Quadro P3200, Quadro P3000, Quadro
P2200, Quadro P2000, Quadro P1000, Quadro P620, Quadro P600, Quadro P520, Quadro P500,
Quadro P400, Titan Xp, Titan X, GeForce GTX 1080 Ti, GeForce GTX 1080, GeForce GTX 1070
Ti, GeForce GTX 1070, GeForce GTX 1060, GeForce GTX 1050 Ti, GeForce GTX 1050,
GeForce MX300, GeForce MX200, GeForce MX150, Tesla M60, M40, M10, Quadro M6000
24GB, Quadro M6000 (12GB), Quadro M5000, Quadro M5000M, Quadro M5500, Quadro
M4000, Quadro M4000M, Quadro M3000M, Quadro M2200, Quadro M2000, Quadro M2000M,
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 25 of 27
Quadro M1200, Quadro M1000M, Quadro M620, Quadro M600M, Quadro M520, Quadro
M500M, NVS 810, Tesla M6, GTX Titan X, GeForce GTX 980Ti, GeForce GTX 980, GeForce
GTX 970, GeForce GTX 960, GeForce GTX 980M, GeForce GTX 970M, GeForce GTX 965M,
GeForce GTX 960M, GeForce GTX 950M, GeForce GTX 750 Ti, GeForce GTX 750, GeForce
MX130, and GeForce MX110; and Jetson modules, including at least the Jetson Thor Series,
Jetson Thor, Jetson T5000, Jetson T4000, Jetson AGX Orin Series, Jetson AGX Orin Developer
Kit, Jetson AGX Orin 64GB, Jetson AGX Orin Industrial, Jetson AGX Orin 32GB, Jetson Orin
NX Series, Jetson Orin NX 16GB, Jetson Orin NX 8GB, Jetson Orin Nano Series, Jetson Orin
Nano Super Developer Kit, Jetson Orin Nano 8GB, Jetson Orin Nano 4GB, Jetson AGX Xavier
Series, Jetson AGX Xavier Industrial, Jetson AGX Xavier 64GB, Jetson AGX Xavier 32GB,
Jetson Xavier NX Series, Jetson Xavier NX 16GB, Jetson Xavier NX 8GB, Jetson TX2 Series,
Jetson TX2i, Jetson TX2, Jetson TX2 4GB, Jetson TX2 NX, Jetson Nano, any and all variations
of the aforementioned products (including at least products having different options for number of
GPUs).
25. The terms “and” and “or” are not intended to be read disjunctively but rather
conjunctively unless the context of a particular request clearly indicates otherwise. “Or” should be
understood to include and encompass “and”; and “and” should be understood to include and
encompass “or.”
26. The terms “any” or “each” should be understood to include and encompass “all.”
27. The terms “concerning,” “related to” or “relating to”, and “regarding” and any
variation of these terms mean analyzing, alluding to, concerning, considering, commenting on,
consulting, comprising, containing, contradicting, describing, dealing with, discussing,
establishing, evidencing, identifying, involving, noting, recording, reporting on, relating to,
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 26 of 27
reflecting, referring to, regarding, stating, showing, studying, mentioning, memorializing, or
pertaining to, directly or indirectly, in whole or in part.
28. The term “CPU(s)” means Central Processing Unit(s).
29. The term “GPU(s)” means Graphics Processing Unit(s).
30. The terms “include” and “including” mean including without limitation.
31. The term “NVIDIA” means Defendant NVIDIA Corporation, its predecessors,
present and former directors, officers, accountants, affiliates, attorneys, partners, managers, agents,
employees, representatives, in-house and outside counsel, and any other person or entity acting on
behalf of or under control of Defendant NVIDIA Corporation.
32. The term “person(s)” means and includes natural persons and formal or informal
entities and organizations, including public and private corporations, partnerships, professional
corporations, limited liability companies, business trusts, banking institutions, associations, firms,
joint ventures, commissions, bureaus, departments, and any other legal entity, including
any divisions, subsidiaries, departments, and other units thereof.
33. The term “Source Code” means human-readable instructions written in a
programming language, including all comments, annotations, declarations, functions, classes, and
other components used to define the behavior of a software program. For purposes of these topics,
“Source Code” includes all associated files necessary to understand, compile, and execute the
code, such as scripts, header files, makefiles, configuration files, and documentation. Unless
otherwise stated, “Source Code” includes all versions and revisions relevant to the time periods
and subject matter described in each interrogatory.
34. The terms “You,” or “Your” refer to Tesla, Inc., including but not limited to its
predecessors, successors, parents, subsidiaries, divisions, affiliates, and all past or present
Case 7:26-mc-00318-LS Document 6-6 Filed 08/18/26 Page 27 of 27
directors, officers, partners, managers, employees, contractors, agents, representatives,
accountants, consultants, in-house and outside counsel, and any other person or entity acting or
purporting to act on its behalf or subject to its control. This definition expressly includes, without
limitation, any Tesla parent, subsidiary, affiliate, or other related entity that has used, licensed,
deployed, evaluated, or integrated NVIDIA Hardware and/or NVIDIA Software.
35. The use of the singular form of any word includes the plural and vice versa.
DEPOSITION TOPICS
1. The NVIDIA software and libraries You use to perform computations, including but not
limited to NVIDIA’s Aerial, Clara Parabricks, cuBLAS, cuDNN, cuFFT, cuQuantum,
cuSOLVER, cuSPARSE, Drive, DriveWorks, Holoscan, Isaac, Isaac Lab, Maxine, Memory
Map, Merlin, Metropolis, Modulus, Monai, Morpheus, NeMo, PyTorch, RAPIDS, Riva,
Runtime Driver, TensorFlow, TensorRT, Triton, VSS (Deepstream).
2. The NVIDIA sample Source Code You use, in whole or in part, to conduct computations.
3. Your customizations and/or data inputs to NVIDIA software that alter the way in which
NVIDIA software performs computations and/or a description of the data input to NVIDIA
software on which computations are run.
4. Identification of Your software that uses NVIDIA GPUs to perform computations.
5. Using Your software, the ways in which output data from a GPU computation(s), including
intermediate results of GPU computations are stored, referenced by a pointer, transferred,
copied, streamed, written back, returned, accumulated, reused, or made available including
asynchronously from NVIDIA GPU memory to CPU memory, host memory, system memory,
storage, display, network, or another memory location before, during, or in parallel with
computations performed using NVIDIA GPUs.