Finally, most of the documents from the Summary Judgment motions from both Qualcomm and Arm have been uploaded by a kind soul.
I'll highlight what I thought were the juicy
regions. Unfortunately, the actual juicy bits themselves are all redacted.
Arm's Claims in its Motion for Summary Judgment:
Arm's requests for Judgment for itself on 3 claims: Arm terminated the ALA properly; QC & NUVIA breached the termination provisions; Arm did not breach the termination provisions (a claim by Qualcomm).
- NUVIA, namely co-founder & CEO Gerard Williams, "sought multiple concessions from Arm" because NUVIA's core was targeted at the "data centre cloud server market".
- NUVIA & Arm signed an ALA and TLA in Sept 2019.
- Neither NUVIA nor Qualcomm gave Arm advance notice of the NUVIA acquisition before they broke the news (relevant in that Arm claims it needs to give consent first).
- Qualcomm then "repudiated the economic terms of the NUVIA ALA".
- After Arm terminated NUVIA's ALA, Qualcomm admitted "in later correspondence" it was using the code & designs under "a then-terminated ALA" (i.e., NUVIA). Apparently, that admission triggered Arm's lawsuit.
- Arm expands: "But even after termination of the ALA, Defendants continue to use RTL code developed by NUVIA under the ALA."
- Arm concludes: "the ALA prohibits this post-termination use of the code developed under the NUVIA ALA. It unambiguously states..."
- The NUVIA ALA is "governed by California law".
- One sentence ends at "NUVIA's CEO was right." It's all redacted otherwise.
- Defendants should have disputed the ALA termination in 2022, not just after the trial started. Notably, Defendants provided a termination certificate.
- NUVIA requested a few features from Arm, called "CMN". Arm claims it did not use those feature requests in its own internal Arm designs, but "merely ran a 'diff to compare".
- Defendants had claimed that Arm's adoption of features requested by NUVIA was a breach of the termination agreement; Arm says otherwise.
- Arm expands that the TLA with NUVIA "permits" [something redacted] with this CMN feature request. Later documents mention a "CMN - Kampos".
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Arm's expert witnesses:
- On December 20, 2023, Arm served the opening expert reports of its technical experts Dr. Robert Colwell and Dr. Mike Chen, remedies expert Todd Schoettelkotte, licensing expert Guhan Subramanian, and trademark expert Dr. Ravi Dhar.
- Arm seems to be pushing that monetary damages are not adequate (e.g., so Arm wants specific performance).
- Arm claims some QC experts gave their info too late and Arm couldn't respond; if Arm is allowed to respond, it will delay the trial.
- Arm sometimes claims some witnesses should be included b/c they are lawyers; other times, they should be excluded b/c they are not lawyers. ...we need a lawyer here to understand this section LMAO.
- I honestly skimmed this doc, as it got a little too in the weeds re: admissibility of certain expert testimony.
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Arm's Concise Statement
- 19. Portions of the RTL code Nuvia wrote before March 16, 2021, for use in the Phoenix core are used in Qualcomm cores, including [redacted] and the Snapdragon X Elite and Snapdragon X Plus SOCs.
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Exhibits
- Exhibit 3 is an AnandTech article! First-page comments were also included in the screenshot, LOL. See page 26.
- Pg 41: part of Nitin Sharma's deposition. Used to work at NUVIA. Now works at SiFive now. Some discussion on "Orion" vs "Oyron" cores, seemingly.
- Pg 66: part of Murali Annavaram's deposition. QC expert witness. Seems to have a bit of a dispute with the lawyer at one point.
- Pg 76: part of Manu Gulati's deposition. A NUVIA founder. Cores with a "Y" seemingly reference "the series of Qualcomm custom CPU cores". There are some derivative cores of Oryon, seemingly, but they kept the name as Oryon cores. Notably is given a light warming, "Just caution you not to reveal any attorney-client communication" near the end.
- Pg 98: part of Paul Williamson deposition. Arm executive. Claims Arm was not aware of the NUVIA acquisition before it hit the media. He was apparently the main letter writer to Qualcomm re: the dispute before the lawsuit.
- Pg 120: part of Gerard Williams deposition. NUVIA founder. They were still working on the server application after the Qualcomm acquisition.
- Pg 159: part of Ziad Asghar's deposition. Qualcomm executive. QC says the QC ALA "takes precedence" and "was a way to make sure that essentially we can close the acquisition quickly."
- Pg 177: part of Jignesh Trivedi's deposition. Seemingly worked at NUVIA, now at Qualcomm. I think. Virutally all redacted.
- Pg. 188: part of Ramakrishna Chunduru's deposition. Believe he works at Qualcomm, according to random Google hits. All redacted.
- Pg. 197: part of Pradeep Kanapathipillai's deposition. Worked at NUVIA, now Qualcomm. Mentions annual February meetings held by ARM called "ARM TAB" (Technical Advisory Board); these are technical discussions.
- Pg 238: part of expert report by Patrick F. Kennedy, Ph.D. Qualcomm's expert and part of the counter-claim by Qualcomm. Managing director at "Stout Risius Ross LLC". Arm inappropriately received some fees & royalties (re: the CNM QC claims Arm stole).
- Pg 249: part of Simon Segar's deposition. Ex-ARM CEO. Humorously, one email is called "YAASS - Yet another Arm server startup". Rest is redacted.
- Pg. 280: part of Guy Larri's deposition. Arm engineer. Mostly redacted.
- Pg 295: deposition of Vedaraman Geetha. NUVIA "technical staff". Humorously, was deposed once before: when? "I was working at Intel for a number of years, and then I think it was troll something patent case."
There's many more documents, but I need a breather, holy fudge. I'll definitely do Qualcomm, but Arm's documents were submitted first in the docket.
EDIT: swapped a "NUVIA" for a "Qualcomm"