Neural AI, LLC v. Tesla Inc. — Entry #11: Response in Opposition to Motion, filed by Tesla Inc., re 6 CORRECTED MOTION to Compel Compliance With Subpoena Served on Third Party Tesla, Inc

Case 7:26-mc-00318-LS   Document 11   Filed 08/24/26   Page 1 of 15


                   IN THE UNITED STATES DISTRICT COURT
                    FOR THE WESTERN DISTRICT OF TEXAS
                         MIDLAND/ODESSA DIVISION


NEURAL AI, LLC

     Petitioner,                    Misc. Case No. 7:26-mc-00318-LS
v.

TESLA, INC.,

     Respondent.


        NON-PARTY TESLA, INC.’S OPPOSITION TO NEURAL AI, LLC’S
         MOTION TO COMPEL COMPLIANCE WITH SUBPOENA AND
         CROSS MOTION TO QUASH NEURAL AI, LLC’S SUBPOENAS


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                                                  TABLE OF CONTENTS


I.        INTRODUCTION .............................................................................................................. 1
II.       FACTUAL BACKGROUND ............................................................................................. 2
       A. NAI’s Dilatory Third-Party Campaign and the Sweeping Subpoenas to Tesla ............... 2
       B. Tesla’s Objections, Meet-and-Confers, Investigation, and Declaration .......................... 2
III.      ARGUMENT ...................................................................................................................... 4
       A. Under NAI’s Own Theory, Customer Discovery Ends at Identification and As-Provided
          Use—Information Tesla Already Provided...................................................................... 4
       B. Tesla Fully Performed the Only Compromise NAI Actually Negotiated ........................ 6
       C. The Remaining Requests Are Overbroad, Unduly Burdensome, and Seek Trade Secrets
          Disproportionate to Any Need ......................................................................................... 6
       D. NAI Served Its Subpoenas Too Late and Filed Its Motion Out of Time ......................... 9
       E. NAI’s Motion Should Have Been Filed in Austin—the Place of Compliance .............. 10
IV.       CONCLUSION ................................................................................................................. 10


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                                                TABLE OF AUTHORITIES

Cases                                                                                                                            Page(s)
Burns v. Bank of America,
  No. 03-cv-1685 (RMB) (JCF), 2007 WL 1589437 (S.D.N.Y. June 4, 2007) ............................. 9
Days Inn Worldwide, Inc. v. Sonia Invs.,
 237 F.R.D. 395 (N.D. Tex. 2006) ......................................................................................... 9, 10
Hoeflein v. Crescent Drilling & Prod., Inc.,
 No. SA 19-CV-01194-FB, 2020 WL 7643122 (W.D. Tex. Dec. 23, 2020) ............................... 4
Thomas v. IEM, Inc.,
  No. 06-886-B-M2, 2008 WL 695230 (M.D. La. Mar. 12, 2008)................................................ 9


Rules
Fed. R. Civ. P., Rule 26 .............................................................................................................. 6, 9
Fed. R. Civ. P., Rule 29 ..................................................................................................................10
Fed. R. Civ. P., Rule 37 ................................................................................................................ 10
Fed. R. Civ. P., Rule 45 ......................................................................................................... passim


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I.     INTRODUCTION

       Neural AI, LLC (“NAI”) asks this Court to conscript Tesla, Inc. (“Tesla”), a non-party, into

proving NAI’s infringement case against NVIDIA. Far from typical of customer subpoenas, NAI

demands granular Tesla confidential trade secrets, including Tesla-specific: AI infrastructure,

source code, system architecture, memory management, data paths, buffer reuse, scheduling, and

related 30(b)(6) testimony—across essentially any Tesla system that touches an NVIDIA GPU.

Some document requests and deposition topics even implicate non-NVIDIA GPUs or software.

This is facially improper third-party discovery.

       Tesla responded exactly as Rule 45 contemplates. It timely served written objections; met

and conferred twice within two weeks; explained the basis for its objections; and agreed to

investigate NAI’s narrowed discovery despite the late hour: (1) identification of the NVIDIA GPUs

and software Tesla uses and (2) whether Tesla uses the software as provided. In reliance on NAI’s

narrowed scope, Tesla conducted a thorough investigation—through its supply chain, IT

infrastructure, and engineering departments—and produced a sworn declaration providing

precisely the facts NAI requested.

       That should have ended the dispute. Instead, one day before the close of fact discovery,

NAI rejected Tesla’s declaration because Tesla refused to adopt NAI’s pre-written admissions

reciting claim language and filed this Motion six days after the written discovery deadline. NAI’s

dissatisfaction with a completed, good-faith compromise is not “non-compliance.”

       NAI’s Motion should be denied. First, under NAI’s own indirect infringement theory, only

product identification and as-provided use are relevant to its claims—and Tesla already provided

both. Second, Tesla complied in good faith and fully performed the compromise reached during

the meet-and-confers. Third, the remaining requests and topics are overbroad, unduly burdensome,

and seek trade secrets out of proportion to any legitimate need. Fourth, the Motion was belatedly


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filed after the written discovery deadline. Finally, it should have been filed in Austin, the place of

compliance, not Midland. In the alternative, the Court should modify the subpoenas to cover only

the information Tesla already produced and quash the remainder, including any testimony.

II.       FACTUAL BACKGROUND

      A. NAI’s Dilatory Third-Party Campaign and the Sweeping Subpoenas to Tesla

          NAI began third-party discovery against other NVIDIA customers as early as October 15,

2025. 1 Exs. 22-23. 2 Yet NAI waited until June 25, 2026 to serve Tesla. Mot. 3.

          The scope of NAI’s subpoenas is sweeping. Its twelve requests for documents (“RFPs”)

seek confidential information of any Tesla system that uses an NVIDIA GPU, including: all

software, frameworks, source code, configurations, and custom code used on NVIDIA GPUs

(RFPs 1, 5); whether and how Tesla uses or modifies NVDIA software, including details of Tesla-

written software (RFPs 4-5); Tesla’s software design, architecture, and data/control/execution flow

(RFP 5); neural-network structure (RFP 6); pointer/buffer reuse (RFP 7); internal input/output data

paths and memory management (RFPs 8-12); and scheduling/queueing/control of GPU

computations, including through “custom software” (RFP 11). Ex. 5 at 16-18. NAI’s five

deposition topics (“Topics”) mirror that scope. Ex. 5 at 27. Several RFPs and Topics even implicate

non-NVIDA GPUs or software. See, e.g., RFPs 1, 4-12; Topics 4-5.

      B. Tesla’s Objections, Meet-and-Confers, Investigation, and Declaration

          After an agreed extension, Tesla served its objections and responses on July 21, 2026,

objecting on relevance, overbreadth, undue burden, proportionality, trade secrets, and availability


1
 In addition to Amazon and Microsoft, NAI has moved to compel at least the following third-
parties in this district: xAI, Meta, CoreWeave, Google, and Oracle. See, e.g., Case Nos. 7:26-mc-
00319, 7:26-mc-00322, 7:26-mc-00323, 7:26-mc-00324, 7:26-mc-00325, 7:26-mc-00327.
2
    Tesla cites exhibits from NAI’s Motion, with additional exhibits numbered consecutively.


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from NVIDIA, and offering to confer. Ex. 9 (O&Rs). The parties conferred twice, on July 28 and

August 7, 2026. Fawzy Decl. ¶¶ 7, 15. At the first conference, Tesla explained that the subpoenas

swept far past NVIDIA hardware and software to reach Tesla’s own software and non-NVIDIA

GPUs, and that their unbounded categories made an investigation burdensome and time

consuming—particularly when NAI had served no infringement contentions or any other basis for

such broad technical discovery. Id. ¶¶ 7-9. NAI offered to reduce that burden and expedite

discovery by accepting a declaration in lieu of a document production, identifying what NVIDIA

hardware and software Tesla uses and whether Tesla uses that software “out of the box” (i.e., as

provided). Tesla agreed to consider the narrowed scope, and because Tesla’s counsel was on leave

and traveling abroad, the parties agreed Tesla would respond the following week. Id.

       In reliance, Tesla conducted a reasonable investigation, including through supply chain, IT

infrastructure, and engineering teams. Id. ¶ 10. On August 4—while that investigation was

ongoing—NAI sent a technical questionnaire (“Questionnaire”) and a pre-written draft declaration

(“Draft Decl.”), stating that it was intended to “guide [Tesla’s] investigation” and that Tesla “may

revise to ensure its accuracy.” Ex. 10 at 1. NAI also threatened Tesla that an August 11 discovery

deadline “leaves [NAI] no practical alternative but to move to compel by the end of this week or,

at the latest, August 10, to preserve its rights.” Id. NAI’s Draft Decl. and Questionnaire went far

beyond any scope discussed in the meet-and-confer or information Tesla agreed to investigate.

They sought sworn admissions reciting language of asserted patent claims and encompassed broad

technical information sought in NAI’s sweeping subpoenas. Ex. 12 (Draft Decl.) ¶¶ 7–15; Ex. 11.

       At the August 7 conference, Tesla declined to commit to NAI’s overbroad Draft Decl. and

reiterated that it would investigate what it had agreed to at the first conference: the NVIDIA

hardware and software Tesla uses and whether that software is used off the shelf. Ex. 21 at 2. NAI


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agreed that would satisfy its subpoenas, “subject to any material gaps.” Fawzy Decl. ¶ 13. Working

through the weekend, Tesla served the Declaration of Alon Daks on August 10, identifying (1) the

NVIDIA GPUs and software Tesla uses and (2) which software it uses as provided. Id. ¶ 14; Ex.

20; Ex. 21 at 2. Nothing was missing from the scope discussed on August 7 and confirmed in

Tesla’s post-conference email. Ex. 21 at 2.

          On August 11 (i.e., one day after service of the Daks Decl. and the last day of document

discovery), NAI responded by unilaterally declaring the Daks Decl. “materially insufficient” and

demanding further information never discussed during either meet-and-confer, including

paragraphs 7–15 of the Draft Decl. which were written by NAI, document production as to all

RFPs, and a 30(b)(6) deposition. Ex. 21 at 1. Without any further meet-and-confer, NAI filed this

Motion on August 17—six days after the written-discovery deadline.

III.      ARGUMENT

          Tesla opposes NAI’s Motion and also moves to quash NAI’s subpoenas for undue burden,

as shown below. Fed. R. Civ. P. 45(d)(3)(A) (requiring a court to quash or modify a subpoena that

imposes an undue burden); Hoeflein v. Crescent Drilling & Prod., Inc., No. SA 19-cv-01194-FB,

2020 WL 7643122, at *3 (W.D. Tex. Dec. 23, 2020) (Undue burden may be determined based on

factors such as relevance, overbreadth, need, time period, specificity, and burden.).

       A. Under NAI’s Own Theory, Customer Discovery Ends at Identification and As-
          Provided Use—Information Tesla Already Provided

          NAI’s Motion confirms the limited role of customer discovery—only real-world

deployment is relevant to NAI’s allegation that NVIDIA induces or contributes to infringement by

encouraging others to use the accused products. Mot. 2. The only Tesla facts with a potential nexus

are (1) NVIDIA GPUs and software Tesla uses, and (2) whether Tesla uses them as provided. Tesla

has provided both under oath. Ex. 20 (Daks Decl.) ¶¶ 3–5. Everything else NAI seeks is irrelevant


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and NAI has never provided Tesla any information to substantiate further discovery:

       Tesla custom software, software identity, and modification mechanics (RFPs 1, 4;

Topics 3–4). Tesla’s proprietary software and wrappers are not NVIDIA products. Once Tesla has

confirmed as-provided use of the identified NVIDIA libraries, “how” Tesla builds around them is

a Tesla design choice, unrelated to NVIDIA or to any claim between NAI and NVIDIA. Deep

customization discovery is, if anything, the opposite of NAI’s own “as provided” theory: the more

Tesla has customized, the less Tesla’s systems prove about what NVIDIA may have induced.

       Architecture, neural-net design, memory, data paths, and scheduling (RFPs 5–12;

Topic 5). NAI admits its requests “track the accused computation … to establish infringement.”

Mot. 7. That is a method-claim chart aimed at Tesla’s systems. If, under its purported infringement

theory, NAI is entitled to discovery into the functionality of NVIDIA’s provided stack, then it

should obtain that information from NVIDIA’s documents and party discovery. It should not

burden a customer, nor can it force a non-party to sign a declaration that tracks the language of the

asserted patent claims. Ex. 12 ¶¶ 7–15.

       NAI’s Draft Decl. ¶¶ 7–15 and Questionnaire. In its August 11 email, NAI claims there

are “material gaps” in the Daks Declaration because it doesn’t swear that Tesla’s systems:

“function … as designed and intended by NVIDIA” (¶ 8); freeze pretrained model and network

structure (¶ 9); avoid GDS/UVM/unified memory and use certain memory management (¶¶ 10-

12); use a single default data path without custom code (¶ 13), and are in use daily (¶ 15). Ex. 21

at 1; Ex. 12 (Draft Decl.) ¶¶ 7–15. This is not product identification or as-provided use evidence.

Knowledge of NVIDIA’s designs and intent should be sought from NVIDIA.

       NAI’s argument that the information is uniquely in Tesla’s possession is misplaced. Mot.

7. That Tesla possesses knowledge of its own confidential trade secrets (such as its own memory


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topology and compiler choices) does not make it relevant or discoverable. Rule 26 asks whether

the matter bears on claims and defenses, which is not the case here.

   B. Tesla Fully Performed the Only Compromise NAI Actually Negotiated

       NAI portrays Tesla as a non-party that hid behind objections (Mot. 9), but the opposite is

true. See supra § II.B. Tesla explained at the July 28 conference why the subpoena’s unbounded

scope reached far beyond NVIDIA hardware and software; NAI never answered that point and

never identified why such broad Tesla technical information mattered to its claims or defenses

against NVIDIA. NAI instead agreed to narrow its requests, acknowledging it was short on time

before the close of fact discovery. Fawzy Decl. ¶ 8. Despite its counsel being on leave and out of

the country, Tesla committed to investigate which NVIDIA GPUs and software it uses and whether

it uses them as provided. Id. ¶ 9. It consulted its supply chain, IT infrastructure, and software

engineering teams, conferred again on August 7, and served a sworn declaration on August 10

supplying precisely those facts. Id. ¶¶ 10, 13; Ex. 20 (Daks Decl.). That is good-faith compliance

and full performance of Tesla’s end of the bargain. NAI’s dissatisfaction with Tesla’s refusal to

adopt its Draft Decl. does not justify compelling Tesla’s trade secrets.

       NAI’s oversimplification that Tesla provided “a five-paragraph declaration” is misleading.

Mot. 4. Length is not the test; substance is. The Daks Decl. provided the narrowed scope of

information that NAI requested and Tesla agreed to investigate, i.e., which NVIDIA GPUs and

software Tesla uses and which ones were used as provided. Ex. 20. Indeed, NAI invited a

declaration “in lieu of” broader discovery. It cannot later manufacture unilateral “material gaps.”

Ex. 10 at 1; Ex. 21 at 1. Tesla should not be penalized for pursuing a reasonable compromise.

   C. The Remaining Requests Are Overbroad, Unduly Burdensome, and Seek Trade
      Secrets Disproportionate to Any Need

       Contrary to Neural AI’s assertion, its subpoenas are not limited to customer-deployment


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discovery. Rather, as explained above, RFPs 1–12 and deposition Topics 1–5 demand a full

technical autopsy of any Tesla system that touches an NVIDIA GPU and even non-NVIDIA GPU

in certain requests, including source code, custom code, architecture, memory topology, data paths,

and scheduling. Ex. 5. That is overbroad, unduly burdensome on a non-party under Rule 45(d),

and seeks trade secrets far beyond what is proportional to NAI’s infringement claims.

       For example, RFP 7 asks Tesla to disclose any use of “a pointer” and its use in buffer

management—a fundamental concept used in almost all computer programming, without any

meaningful limitations. 3 Ex. 5 at 17. It potentially implicates any Tesla system that uses GPUs,

including non-NVIDIA GPUs. Similarly, RFPs 5, 8-12 and Topics 3-5 make sweeping requests for

Tesla’s confidential information about its software architecture, input/output data paths design,

memory management, and computations scheduling. Ex. 5 at 16-18. Simply put, these RFPs and

Topics either seek the functionality of NVIDIA software, in which case, NAI must obtain that

information from NVIDIA, or it seeks the functionality of Tesla software, which is irrelevant,

overbroad, and overly burdensome to allegations of infringement by NVIDIA software.

       The burden of searching for and collecting this information would be substantial.

Compliance with RFPs 5–12 and Topics 3–5 could encompass an investigation, across nearly

seven years and company-wide operations, including across systems, workflows, and codebases

that use NVIDIA GPUs “to perform computations”; locating the engineers and custodians

knowledgeable about each such system; collecting architecture, design, data-flow, control-flow,

and execution-flow materials; and reviewing highly sensitive source code and internal technical

documents for responsiveness and privilege. Fawzy Decl. ¶ 4. That effort would cut across multiple


3
 See, e.g., https://www.geeksforgeeks.org/dsa/pointer-in-programming/ (“Pointer is a variable
which stores the memory address of another variable as its value. . . Pointers allows low-level
memory access, dynamic memory allocation, and many other functionality.”).


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organizations and product areas and would divert engineers from ordinary business to potentially

reconstruct implementations, memory layouts, buffer strategies, data-transfer paths, and

scheduling behavior. Id. It is a multi-team technical investigation into core AI infrastructure, with

the attendant costs of collection, review, redaction, confidentiality designations, and potential

source-code logistics. Id. Rules 45(d)(1) and (d)(3) require the Court to protect a non-party from

precisely this kind of significant expense and disruption.

       Further, NAI cannot show “substantial need” for the information it seeks in RFPs 5–12 and

Topics 3–5 that “cannot be otherwise met” under Rule 45(d)(3)(C), given discovery from NVIDIA,

public information, and Tesla’s Daks Decl. This is especially so because NAI’s subpoenas ask for

confidential Tesla trade secrets about the company’s AI operations, including regarding source

code and related internal architecture, design, and data flow, input/output data handling, memory

layout, buffer strategies, and scheduling strategies. But NAI has not shown, during the meet-and-

confers or in its Motion, that it is entitled to so such highly confidential trade secret information

without violating Rule 45(d)(3)(B)(i).

       Finally, NAI’s pre-written Draft Decl. and Questionnaire are not “focused” as it alleges.

Rather, they require Tesla to map—and swear to—its GPU memory hierarchy, input/output data

paths, buffer reuse, compilation toolchain, model structure, and supposed conformity with

“NVIDIA’s design.” Those topics are the same trade-secret, overbroad demands embodied in RFPs

4–12 and Topics 3–5. See Ex. 12 (Draft Decl.), ¶¶ 9-13; Ex. 11 (sections re “Input Data Path” and

“Output Data Path and Memory Transfers”). NAI’s Draft Decl. even asks Tesla to make legal

conclusions and speculations, such as declaring that “the hardware and NVIDIA software function

together as designed and intended by NVIDIA.” Ex. 12, ¶ 8. Rule 45 allows proportionate third-

party discovery. It does not allow a plaintiff to conscript a non-party into proving its infringement


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case. Tesla’s declaration already provided the former; the Court should refuse the latter.

   D.      NAI Served Its Subpoenas Too Late and Filed Its Motion Out of Time

        NAI’s subpoenas are dilatory. A subpoenaing party must pursue third-party discovery with

diligence; merely serving a subpoena before the deadline is not enough where the requests could

not reasonably be answered, narrowed, collected, and produced before discovery closed. Fed. R.

Civ. P. 45(d)(1). Courts refuse to enforce last-minute third-party subpoenas that leave no realistic

path to complete discovery by the cutoff. Indeed, Rule 45 is a discovery device, not an “end-run”

around the discovery process. See Thomas v. IEM, Inc., No. 06-886-B-M2, 2008 WL 695230 (M.D.

La. Mar. 12, 2008); Burns v. Bank of America, No. 03-cv-1685, 2007 WL 1589437 (S.D.N.Y. June

4, 2007); Fed. R. Civ. P. 26(b)(2)(C)(ii), 45(d)(1). NAI began subpoenaing NVIDIA customers

such as Amazon and Microsoft in October 2025, but waited until June 25, 2026, to serve Tesla—

a publicly known NVIDIA customer. See Mot. 3, 7 (noting “Tesla is a significant [NVIDIA]

customer”); Exs. 22-23. NAI’s August 4 email admitted it was racing that deadline and threatened

a motion “to preserve its rights.” Ex. 10 at 1. By the July 28 meet-and-confer, NAI knew it was

too late to seek twelve deep technical RFPs and corporate testimony. Fawzy Decl. ¶¶ 7-8. NAI’s

own delay left no realistic time for meaningful non-party investigation, trade-secret review, meet-

and-confers, or production of the vast scope of materials sought in RFPs 5–12.

        Further, NAI’s Motion was untimely. Courts measure the timeliness of a motion to compel

against the deadline for completion of discovery, not against a later motion deadline. In Days Inn

Worldwide, Inc. v. Sonia Invs., the N.D. Texas court denied a motion to compel filed two weeks

after the discovery deadline even though it was filed before the “deadline for other motions.” 237

F.R.D. 395, 396 (N.D. Tex. 2006). In ruling so, the court noted that there was a consensus among

the 10th, 7th, 6th, and 1st Circuits and various district courts that “courts generally looked to the

deadline for completion of discovery in considering whether a motion to compel has been timely


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filed.” Id. at 397 (collecting cases). NAI filed the Motion six days after written discovery closed—

seeking post-deadline production from a non-party. NAI’s lack of diligence in launching third-

party discovery cannot justify a lack of diligence in enforcing it—and neither supports reopening

written discovery against Tesla after the deadline. The Motion should be denied as untimely. 4

      E. NAI’s Motion Should Have Been Filed in Austin—the Place of Compliance

         NAI’s Motion was improperly filed in Midland. Rule 45 requires compliance within 100

miles of where the subpoenaed person resides, works, or regularly conducts business, Fed. R. Civ.

P. 45(c)(2)(A), and any motion to compel must be filed where compliance is required. Fed. R. Civ.

P. 45(d)(2)(B)(i); see also Fed. R. Civ. P. 37(a)(2). NAI’s subpoenas designated Austin as the place

of compliance. See Ex. 5; Mot. 5. NAI, however, filed in Midland, more than 300 miles from

Tesla’s Austin headquarters. The underlying case’s location does not override Rule 45, and district-

wide jurisdiction does not satisfy Rule 45’s location requirement. Further, because the written

discovery deadline has passed, the Court should deny the Motion without leave to re-file.

IV.      CONCLUSION

         For the foregoing reasons, Tesla respectfully requests that the Court (1) deny NAI’s

Motion in its entirety, and (2) quash NAI’s document and deposition subpoenas. Alternatively, if

the Court does not deny the Motion in full, it should: (1) hold that the Daks Decl. satisfies Tesla’s

obligations as to identification and as-provided use; and (2) modify the subpoenas to those

subjects only and quash RFPs 1 and 3–12 and Topics 1–5.


4
 NAI relies on a stipulation with NVIDIA permitting motions to compel third parties through
August 18, 2026. Mot. 3. But Tesla was not a party to that stipulation, and it was never adopted by
court order. Fed. R. Civ. P. 29 (stipulations regulate procedure between parties, not non-party
burdens).


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Dated: August 24, 2026               Respectfully submitted,

                                         /s/ Jun Zheng

                                         Jun Zheng
                                         TX Bar No. 24102681
                                         zhengjun@tesla.com
                                         Tesla, Inc.
                                         1 Tesla Rd
                                         Austin, TX 78725
                                         (512) 417-3528

                                         Ashraf Fawzy
                                         DC Bar No. 989132
                                         afawzy@tesla.com
                                         Tesla, Inc.
                                         800 Connecticut Ave. NW
                                         Washington, DC 20006
                                         (202) 905-9221

                                         Gina H. Cremona
                                         CA Bar No. 305392
                                         gcremona@tesla.com
                                         Tesla, Inc.
                                         1501 Page Mill Rd.
                                         Palo Alto, CA 94304
                                         (650) 647-0015

                                         Counsel for Tesla, Inc.


      Case 7:26-mc-00318-LS        Document 11       Filed 08/24/26    Page 15 of 15


                              CERTIFICATE OF SERVICE

       The undersigned hereby certifies that all counsel of record who are deemed to have

consented to electronic service are being served with a copy of this document via the Court’s

CM/ECF system when it is filed with the system.


                                                  /s/ Jun Zheng
                                                  Jun Zheng