10. Defendants began monitoring crypto-related sales well before the Class Period began. Indeed, prior to the Class Period, Huang explained: “We monitor the inventory in the channel continuously, not only from the guys that buy from us, but where the parts go after that—who they sell to, and who they sell to,” confirming “we monitor sellout in the channel literally every day.” By late 2016, NVIDIA’s sales force in China—the Company’s largest market by far, accounting for more revenues than the rest of the world combined—had started to track crypto-related GeForce sales based on transaction data provided by NVIDIA’s manufacturing partners.
NVIDIA paid its partners to collect this data. The data expressly quantified GeForce sales to crypto-miners, who began to make bulk purchases of tens of thousands of GPUs at a time from these partners. This data, which, as recounted by a former Senior Account Manager, “obsessed” NVIDIA’s U.S. executive team, was sent in weekly reports to top executives and consolidated in NVIDIA’s centralized sales database. Huang personally reviewed the sales data in this centralized sales database, a fact documented by a Company-produced video shown at an internal meeting attended by top executives. The sales data demonstrated that, throughout 2017, 60% to 70% of NVIDIA’s GeForce revenue in China came from sales to crypto-miners, not gamers. Given the importance of both the GeForce product line and the China market to NVIDIA’s overall business, this staggering percentage revealed that a substantial portion of the Company’s total Gaming-segment revenues actually came from crypto-related sales in that one region alone.