Neural AI, LLC v. Tesla Inc. — Entry #6: CORRECTED MOTION to Compel Compliance With Subpoena Served on Third Party Tesla, Inc

Case 7:26-mc-00318-LS   Document 6-12   Filed 08/18/26   Page 1 of 3


                EXHIBIT

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      Case 7:26-mc-00318-LS         Document 6-12       Filed 08/18/26    Page 2 of 3


General Deployment
   • Do you have architecture diagrams for your hardware and software systems that use
      NVIDIA GPUs?
   • Do you use PyTorch or TensorRT?
   • Which of the following, if any, top-layer applications do you use: Modulus, Maxine,
      cuQuantum, Merlin, Aerial, Monai, Triton, Nemo, VSS Blueprint, Riva, Metropolis,
      Holoscan, Clara Parabricks, Rapids, Isaac, Isaac Lab, Drive, DriveWorks, and
      Morpheus?
   • For each NVIDIA software product identified, in the ordinary course, do you download
      and use it locally, use it via a cloud-based solution offered by NVIDIA, or through a
      third-party cloud provider?
   • Do you make modifications to the source code for PyTorch, TensorRT, or other
      NVIDIA-provided software when its deployed on NVIDIA GPUs?
   • In the ordinary course, approximately how frequently do you run computations utilizing
      PyTorch or TensorRT on NVIDIA GPUs (e.g., many times per day, every day, every
      week, or every month)?
   • Are the relevant systems operated in the United States or used to support U.S.-directed
      operations?

Input Data Path
   • In the ordinary course, do you use GPUDirect Storage (GDS) to load input data directly
      from storage into GPU memory, bypassing CPU main memory? Or do you use CPU
      main memory?
   • In the ordinary course, do you use GPUDirect RDMA or any direct NIC-to-GPU memory
      path for receiving live input data?
   • In the ordinary course, do you use unified memory (cudaMallocManaged), Unified
      Virtual Memory (UVM), or a coherent CPU/GPU memory architecture (e.g., DGX Spark
      UMA, Grace Hopper coherent memory) for the input data path?
   • In the ordinary course, do you use the PyTorch function torch.cuda.gds.GdsFile or any
      GDS-enabled data loader (e.g., DALI GDS, KvikIO) to load data?

Output Data Path and Memory Transfers
  • In the ordinary course, are outputs of GPU computations copied back to CPU/main
      memory? If so, what data is copied (e.g., transcripts, generated tokens, logits,
      embeddings)?
  • In the ordinary course, do GPU-to-CPU (D2H) or CPU-to-GPU (H2D) data transfers
      occur during or in parallel with GPU computations, or only after each computation
      completes?
  • In the ordinary course, how are your memory partitions configured for GPU
      computations? Are there separate memory regions for input data, output data, workspace,
      and intermediate results?
  • In the ordinary course, are output buffers from one GPU computation reused as input
      buffers for a subsequent computation?
  • Do you use torch.compile, TorchDynamo, Triton, TensorRT-LLM compilation, NVRTC,
      or PTX JIT to generate GPU programs at runtime, or do you use only precompiled
      kernels?


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TensorRT Usage
   • If you use TensorRT or TensorRT-LLM, how do you populate the input buffers and
      retrieve the outputs? Do you use CPU-side request processing and H2D/D2H copies?
   • Are TensorRT engines built by your organization, provided pre-built by NVIDIA, or
      obtained from another source?


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