If you purchased NVIDIA common stock during the Class Period, you may be a member of the proposed Class. You must move the Court on or before November 10, 2008 if you wish to serve as a lead plaintiff. Lead plaintiffs must meet certain legal requirements. If you have acquired NVIDIA common stock and want to discuss your legal rights, you may contact Bruce D. Bernstein (firstname.lastname@example.org) of Dreier LLP at 800-952-8897. Class members may retain counsel of their choice and move the Court to serve as a lead plaintiff, or may choose to do nothing and remain absent class members.
NVIDIA is engaged in the business of designing and manufacturing media and communications processors ("MCPs"), and is the inventor of the GPU (Graphics Processing Unit), a high-performance processor which generates interactive graphics on workstations, personal computers, game consoles, and mobile devices. The complaint alleges that throughout the Class Period, Defendants concealed the fact that its MCPs and GPUs were experiencing unprecedented failure rates, relating to "heat cycling."
The complaint alleges Defendants knew about these problems throughout the Class Period but concealed them and their ramifications on the Company's financial health and future, through a series of false and misleading statements made to the investing public. According to the complaint, these statements were materially false and misleading because they failed to disclose, among other things, that the Company's graphics cards were defective and the impact the defects would have on NVIDIA's financial condition, results and future business prospects. In addition, these statements failed to adjust the Company's projections and reported financial results for customer warranty, repair, return, replacement and other consequential costs and expenses resulting from the defects. As a result, the complaint alleges that the Company's expenses were understated and its revenue, income and margin were overstated.
On July 2, 2008, the Company shocked investors when it revealed that flawed processes and materials used in manufacturing the graphics cards were causing unprecedented failure rates. On the same day, after the close of trading, NVIDIA unexpectedly slashed its second-quarter revenue and margin forecasts. In substantial part, the Company attributed the drastically revised projections to the fallout from its defective graphics cards. As a direct and proximate result of these revelations, NVIDIA's stock opened at $12.98 on July 3, 2008, down almost $6 per share from its intraday high of $18.78 on July 2, 2008. This 31% decline cut NVIDIA's market capitalization by over $3 billion virtually overnight.
Dreier LLP's Class Action Litigation Group has vast experience representing domestic and foreign institutional and individual investors in securities and other class actions throughout the country. The partners who head Dreier LLP's Class Action Litigation Group have successfully prosecuted securities fraud class actions in a wide variety of industries and have played a significant role in cases that have resulted in some of the largest securities class action settlements. Prior results do not guarantee a similar outcome. As of the date of this Notice, Dreier LLP has not filed a complaint against NVIDIA.
Background on Dreier LLP
Dreier LLP was founded in 1996 by Marc Dreier as a more responsive and innovative alternative to traditional "large-firm" lawyering. Dreier LLP represents a wide range of institutional, entrepreneurial and individual clients in diverse sectors of financial, industrial and service-oriented markets. The firm's principal practices are commercial litigation, class action litigation, real estate, bankruptcy and corporate reorganization, labor and employment law, corporate and securities, entertainment and sports law, intellectual property, matrimonial and tax. Dreier LLP's Los Angeles affiliate, Dreier Stein Kahan Browne Woods George LLP, has its principal practice in entertainment and commercial litigation and corporate transactions. The firm's New York affiliate Schlesinger Gannon & Lazetera LLP has an extensive practice in trusts and estates law. Pitta & Dreier LLP is an affiliate which specializes in labor law, and Pitta, Bishop, Del Giorno & Dreier LLP specializes in government relations. Dreier Sports Opportunities offers athletes and organizations comprehensive business and life management services. Berry Block & Bernstein LLC is an affiliate specializing in building human capital of companies through diversity, corporate social responsibility and leadership training. In the 12 years since its founding, Dreier LLP, with its affiliate members, has grown to more than 225 attorneys, with its principal office at 499 Park Avenue in Manhattan, and additional offices in Los Angeles and Santa Monica, CA; Albany, NY; Stamford, CT; and Pittsburgh, PA.
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