In re NVIDIA Corporation Securities Litigation

I. BACKGROUND

1 Plaintiffs bring this securities action individually and “on behalf of all others who 2 purchased or otherwise acquired common stock of NVIDIA Corporation” between May 10, 2017, 3 and November 14, 2018, inclusive (the “Class Period”). FAC at 1. The following facts are taken 4 from the FAC and judicially noticeable documents. 5 A. Graphic Processing Units 6 NVIDIA “is a multinational technology company” that produces graphic processing units 7 (“GPUs”), types of processors that are used in rendering computer graphics. FAC ¶ 1. NVIDIA’s 8 GPU business is reported by market platforms, two of which are at issue in this case. Id. ¶ 39. 9 The first platform is chips designed for videogames—the Gaming platform—comprised primarily 10 of the “GeForce” GPU product line. Id. ¶¶ 39–40. Original Equipment Manufacturer & IP 11 (“OEM”) is a second platform for chips designed for devices such as tablets and phones. Id. The 12 gaming platform is NVIDIA’s largest market: “[i]n every quarter of the Class Period, [g]aming 13 revenues exceeded those of the four other segments combined.” Id. ¶ 40. Generally, NVIDIA 14 does not sell GPUs directly to the end users, but…