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
3 page(s), 1,975 characters, read from page images by OCR, so expect some character errors · plain text.
Full text
EXHIBIT Case 7:26-mc-00318-LS Document 6-21 Filed 08/18/26 Page 2 of3 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS MIDLAND/ODESSA DIVISION NEURAL AI, LLC Plaintiff, Case No. 7:24-cv-00221-ADA-DTG V. JURY TRIAL DEMANDED NVIDIA CORPORATION Defendant. I, Alon Daks, hereby declare as follows: 1. I am a Senior Staff Software Engineer at Tesla Inc. (“Tesla”). I am over the age of eighteen and competent to make this declaration. I make this declaration based on my personal knowledge, including my general familiarity with Tesla’s technical infrastructure, software deployments, use of NVIDIA products, as well as the on the basis of a reasonably diligent investigation. 2. I understand that this declaration is submitted in connection with a subpoena Neural Al served on Tesla on June 25, 2026 in the above-captioned action (the “Subpoena’’). %. In the ordinary course of business, Tesla deploys the following NVIDIA GPUs in the United States: A100, H100, H200, GB300, V100, and A16. 4. In the ordinary course of business, Tesla uses the following software and/or libraries identified in the Subpoena (specifically, Request No. 2 for Production of Documents): cuBLAS, cuDNN, cuFFT, cuSOLVER, Isaac Lab, PyTorch, and Triton. I understand that cuBLAS, cuDNN, cuFFT, cuSOLVER, and Isaac Lab are provided by NVIDIA, but PyTorch is managed by the Linux Foundation and Triton is managed by https://triton-lang.org. Case 7:26-mc-00318-LS Document 6-21 Filed 08/18/26 Page3of3 5. In the ordinary course of business, Tesla uses at least cuBLAS, cuDNN, cuFFT, cuSOLVER, and Triton as provided. I understand that Isaac Lab, PyTorch, and Triton are open source software and/or libraries, but cuBLAS, cuDNN, cuFFT, and cuSOLVER are not open source. 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 10, 2026. Alon Daks Alon Daks (Aug 10, 2026 18:35:30 PDT) Alon Daks