The complaint alleges that Nvidia Corp. chip sets used by Hewlett Packard in its notebooks fail at an unusually high rate. Nvidia has stated that its graphic processing units and media and communication processors contain a weak die/packaging material. As the GPUs and MCPs fail the HP notebooks display black screens, duplicate images, wireless networking complications, and the random appearance of lines, characters and other on screen interference, and total failure.
The complaint further alleges that HP knew of the problems with Nvidia GPU’s and MCP’s and remained silent while consumers purchased HP notebooks and while HP notebooks where serviced for warranty and out of warranty claims.
The Plaintiff claims that HP’s acts and omissions constitute: (1) statutory fraud; (2) breach of implied warranty; (3) unjust enrichment; and (4) declaratory judgment.


