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