Case 5:22-cv-04273 Document 1 Filed 07/24/22 Page 1 of 87
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`BATHAEE DUNNE LLP
`Yavar Bathaee (CA 282388)
`yavar@bathaeedunne.com
`Andrew C. Wolinsky (p.h.v. forthcoming)
`awolinsky@bathaeedunne.com
`445 Park Avenue, 9th Floor
`New York, NY 10022
`Tel.: (332) 322-8835
`
`Brian J. Dunne (CA 275689)
`bdunne@bathaeedunne.com
`Edward M. Grauman (p.h.v. forthcoming)
`egrauman@bathaeedunne.com
`901 South MoPac Expressway
`Plaza I, Suite 300
`Austin, TX 78746
`Tel.: (213) 462-2772
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`Attorneys for Plaintiffs and the Proposed
`Classes
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
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` Case No. 5:22-cv-4273
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`CLASS ACTION COMPLAINT
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`DEMAND FOR JURY TRIAL
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`TARAN PIETOSI and SUKHDIP RAI,
`individually and on behalf of all others similarly
`situated,
`
`
` Plaintiffs,
`
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`v.
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`HP, INC., a Delaware corporation,
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` Defendant.
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`Case 5:22-cv-04273 Document 1 Filed 07/24/22 Page 2 of 87
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`TABLE OF CONTENTS
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`INTRODUCTION ..................................................................................................................................... 1
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`PARTIES ................................................................................................................................................... 6
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`I.
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`II.
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`PLAINTIFFS ................................................................................................................................. 6
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`DEFENDANT ................................................................................................................................ 8
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`JURISDICTION AND VENUE .............................................................................................................. 10
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`DIVISIONAL ASSIGNMENT ................................................................................................................ 11
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`FACTS ..................................................................................................................................................... 11
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`THE TRUSTED PLATFORM MODULE (TPM) ...................................................................... 11
`A.
`The Advent of TPM ......................................................................................................... 11
`B.
`The TPM as an External System ...................................................................................... 14
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`MICROSOFT FORCES TPM ADOPTION AS PART OF WINDOWS 11 ............................... 17
`The Growing Risk of Firmware Attacks and the Need for Hardware Security Solutions
`A.
`.......................................................................................................................................... 17
`The Onslaught of Firmware Attacks ................................................................................ 18
`Microsoft Requires a TPM to Run Windows 11 ............................................................. 22
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`B.
`C.
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`AMD IMPLEMENTS A DEFEAT DEVICE—A FIRMWARE TPM BUILT ON A
`PLATFORM WITH DIRECT ACCESS TO PRIVILEGED SYSTEM RESOURCES ............. 25
`A.
`The AMD Platform Security Processor ........................................................................... 25
`B.
`AMD Shoehorns a Software-Based TPM into the PSP as Firmware .............................. 28
`
`AMD’S FLAWED DESIGN RESULTS IN PLAYBACK AND GAMING
`STUTTERING ............................................................................................................................. 30
`AMD-Based System Users Flood the Internet with Complaints of Stuttering When
`A.
`Watching Video, Listening to Music, Playing Video Games, and Even
`Videoconferencing ........................................................................................................... 30
`HP’s Forums Receive Repeated Complaints of Stuttering .............................................. 33
`AMD Acknowledges the Stuttering Problem and Recommends Its Users Purchase
`Hardware TPMs as a “Workaround” ............................................................................... 34
`The Stuttering Was Caused by a Serious Design Flaw that Cannot Be Fixed through a
`Firmware Update ............................................................................................................. 35
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`B.
`C.
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`D.
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`III.
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`IV.
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`V.
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`HP JOINTLY MARKETS AMD’S CPUS AND KNEW ABOUT THE FTPM’S
`FLAWED DESIGN ..................................................................................................................... 36
`HP Jointly Markets Its PCs and Laptops with AMD, Touting AMD Processors for
`A.
`Multimedia, Gaming, and Security Applications ............................................................ 36
`HP Knew and Knows About the AMD PSP/fTPM Design Flaw, Including Its Stuttering
`Manifestation ................................................................................................................... 44
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`B.
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`VI.
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`HP OVERCHARGED CONSUMERS FOR PCS WITH AMD CPUS AS A RESULT
`OF ITS FALSE AND MISLEADING STATEMENTS AND OMISSIONS ............................. 46
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`CLASS ACTION ALLEGATIONS ........................................................................................................ 50
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`CLAIMS FOR RELIEF ........................................................................................................................... 56
`A.
`Nationwide Claims ........................................................................................................... 56
`B.
`Claims Brought on Behalf of the California Subclass or the California Consumer
`Subclass............................................................................................................................ 67
`Claims Brought on Behalf of the Pennsylvania Subclass ................................................ 79
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`C.
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`REQUEST FOR RELIEF ........................................................................................................................ 83
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`JURY DEMAND ..................................................................................................................................... 84
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`INTRODUCTION
`1.
`Watching videos, listening to music or other audio, videoconferencing, and playing games
`are key—indeed, indispensable—activities on modern personal computers (PCs). Indeed, it is no stretch
`to say that in 2022, a desktop or laptop PC that can’t play video or audio, or run videoconferencing
`software, or render a computer game, without experiencing intrusive stuttering, is unworthy of sale.
`2.
`So, too, is a baseline level of hardware security—one recognized by Microsoft as
`necessary to mitigate the risk and effect of devastating firmware attacks—a central part of the baseline
`bargain expected by modern PC consumers. In a world in which virtually every aspect of an American’s
`life is performed at least in part through their computer, a desktop or laptop that is uniquely vulnerable
`to known, crippling attack vectors is not a computer that consumers seek to buy.
`3.
`Yet Defendant HP Inc. (“HP”) makes, markets, and sells exactly these types of seriously
`flawed desktop and laptop computers. Numerous HP PCs—specifically, HP computers with AMD Ryzen
`or Athlon processors that have so-called “firmware TPM” (“fTPM”) modules embedded within them—
`include a design defect that causes invasive stuttering in audio and video playback, during
`videoconferencing, and while playing games. At the same time, this design defect renders these HP
`computers uniquely vulnerable to catastrophic firmware attacks—despite the fact that a TPM is, by its
`very nature, supposed to defend against such attacks.
`4.
`HP, however, does not acknowledge any of this. Instead, on its website and elsewhere HP
`specifically markets its AMD desktop and laptop computers as especially suited for watching video, for
`videoconferencing, and for gaming. HP also touts these computers’ “enterprise-level” security.
`5.
`The Plaintiffs in this case each purchased HP computers with AMD processors that
`include AMD’s defective fTPM design. They have all experienced severe stuttering in media playback;
`in videoconferencing; and/or in gameplay. Their computers are also uniquely vulnerable to firmware
`attacks that could compromise not just Plaintiffs’ HP computers, but potentially their home or business
`networks. The AMD fTPM design defect and its manifestations has significantly—perhaps totally—
`impaired the value of Plaintiffs’ HP PCs, as they are unfit for their intended use, and their resale value is
`crippled. Despite this—and despite growing complaints about the performance of AMD-based HP
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`computers in HP forums and across the Internet—HP has done nothing to fix or replace its defective
`computers.
`6.
`Plaintiffs and those similarly situated—i.e., other persons who have purchased HP
`computers that include defective AMD processors—bring this lawsuit against HP in order to be made
`whole.
`
`* * *
`7.
`HP designs, manufactures, and sells desktop and laptop personal computers. For almost
`all of the PCs it sells, HP incorporates central processing units (“CPUs”) from one of two manufacturers,
`AMD and Intel. On its website (hp.com) and elsewhere, HP touts its computers, including specifically its
`AMD-based PCs, as providing smooth playback of audio and video, videoconferencing, and gameplay.
`8.
`HP also advertises and markets the security features of its AMD-based PCs, including
`their compliance with the security requirements of the leading PC operating system, Microsoft Windows
`11. HP preinstalls Windows 11 on most of its PCs.
`9.
`HP advertises its AMD-based PCs jointly with AMD itself, including on pages and posts
`within hp.com that proclaim the benefits of AMD-based PCs made by HP.
`10.
`HP is deeply involved with the design of its PCs, including as to the CPUs it incorporates
`into its PCs. HP’s AMD-based PCs, which include AMD Ryzen and Athlon processors, are designed and
`customized to fit the power consumption and use profiles suited for HP’s customers.
`11.
`Put simply, HP and AMD work hand in hand to integrate AMD CPUs into HP PCs sold
`to end-users.
`12.
`In June 2021, in response to a striking increase in so-called “firmware attacks”—
`devastating cyberattacks that allow an attacker to compromise low-level CPU, memory, and hardware
`resources of computer before an operating system even loads—the leading operating system maker,
`Microsoft, resolved to act. Specifically, Microsoft decided to require, as a precondition for running its
`upcoming operating system Windows 11, a specific piece of hardware designed to separate sensitive
`cryptographic and other security-related resources from the main CPU and system memory—a Trusted
`Platform Module (“TPM”).
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`13.
`Because a TPM was a separate hardware device from the system’s CPU, it could protect
`important computer security resources—such as the system’s random number generator and private keys
`used for encryption—from being compromised. That is, even if the system’s CPU, memory, and
`operating system had been attacked, the secrets stored in the TPM would remain safe. For Microsoft,
`requiring a TPM meant implementing a broad-based minimum level of security that was uniform and
`consistent with a detailed specification, called the TPM 2.0 standard.
`14.
`HP, which pre-installs Windows software on its PCs, accordingly faced a new and
`significant design requirement for its computers. That is, to make sure that its PCs were compatible with
`the newest version of Windows (Windows 11), HP had to ensure that every one of its desktop and laptop
`computers included an onboard TPM.
`15.
`Faced with a potentially burdensome redesign, HP turned to AMD, which had created and
`implemented what was essentially a defeat device for Microsoft’s new TPM requirement: a “firmware
`TPM,” or simply “fTPM.” Not an actual TPM—i.e., a discrete piece of hardware to protect and segregate
`security-sensitive information and operations from the main system processor and memory—in any
`historical or computer security sense, AMD’s fTPM was simply a piece of code that announced itself to
`the system (and critically, to Windows 11) as a “TPM.” AMD implemented this firmware “TPM” as part
`of its Platform Security Processor (PSP)—and ARM-based embedded processor within the overall AMD
`CPU package. The PSP had direct access to sensitive and privileged CPU and memory resources, and as
`such, so did the fTPM module AMD had incorporated within it.
`16.
`Implementing fTPM as part of the AMD PSP subsystem meant that the co-processor that
`ran that subsystem would be further taxed, sharing resources and memory with the fTPM. A micro-
`operating system called a Trusted Execution Environment (“TEE”) sliced the PSP subsystem’s scarce
`resources between the fTPM and numerous other firmware-based systems that ran as part of the PSP,
`including, for example, DRM software that enables the decryption of streaming video and/or audio.
`17.
`Not only did AMD’s fTPM design ironically implement a security module designed to
`prevent firmware attacks in the firmware itself, it did so in a way that exposed sensitive system resources
`to the fTPM. But for HP, fTPM avoided a major hassle: HP would not need to ship new hardware with
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`its AMD-based PCs in order to make them compatible with Windows 11. Instead, HP could simply ensure
`that fTPM—a piece of code that tells the operating system it’s a TPM—was enabled on its AMD-based
`systems, and this would satisfy Windows 11’s security checks.
`18.
`Of course, the fTPM merely checked a box for Windows 11—it was not an actual Trusted
`Platform Module. Indeed, AMD’s fTPM not only failed to accomplish the very reason for being of a
`TPM—hardware segregation of cryptographic keys and other security-sensitive information from system
`resources, the CPU, and system memory, which reduces the risk and effect of firmware attacks—it made
`the problem of firmware attacks worse. Compromising AMD’s PSP subsystem, which hackers had
`repeatedly done since at least the end of 2018, now meant potentially compromising all the security-
`sensitive resources of the entire system—all conveniently grouped in one software-based module for the
`attacker. HP’s design of its new AMD-based PCs left users more vulnerable to firmware attacks, under
`the guise of bolstering system security and ensuring compliance with Windows 11’s system security
`requirements.
`19.
`The flawed CPU design had at least two resultant effects on HP’s AMD-based PCs.
`20.
`First, because the fTPM was implemented as part of the PSP, which could directly access
`system memory and CPU resources, particularly when users’ PCs must decrypt audio and video content
`(e.g., when streaming video from Netflix), interactions with fTPM meant potentially delaying the
`function of other systems implemented in the PSP that were required for smooth playback or time-
`sensitive memory or CPU interactions.
`21.
`The result was the catastrophic stuttering of playback on HP PCs with AMD Ryzen and
`Athlon processors. Reports flooded online forums and YouTube channels describing HP and other AMD-
`based PCs stuttering when playing back video, when playing audio, or both. The stuttering also affected
`video conferencing—a staple in the post-pandemic work-from-home environment. And, with respect to
`gamers, whom HP directly targets for PC sales, the defective HP PCs would stutter when playing video
`games. In YouTube video after YouTube video, users showed the stuttering effect in various popular
`computer games being run (or attempting to run) on HP and other AMD-based computers. Despite HP’s
`promises that its AMD-based PCs were suitable for ordinary uses, such as watching video, listening to
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`music, video conferencing, and playing games, its AMD PCs stuttered during each of these baseline
`applications.
`22.
`Second, the flawed fTPM design left HP’s AMD-based PCs vulnerable to cyberattacks
`that exploit a PC’s firmware. This sort of attack was (and is) especially pernicious, as it allows a hacker
`to access a computer system’s most sensitive resources (e.g., its Basic Input Output System (“BIOS”))
`before the operating system even comes online. Even though HP purported to make systems, particularly
`those running Windows 11, more secure from such attacks, the design of its AMD-based PCs did the
`opposite.
`23.
`Despite the swelling of complaints over several years by HP’s customers that its AMD-
`based PCs had significant stuttering problems, HP did nothing. It never ordered a recall of its PCs to
`replace the faulty CPUs (e.g., with Intel CPUs that did not have the design defect) or to provide purchasers
`with comparable PCs that did not have the design defect. HP never as much as acknowledged the problem.
`It kept selling its AMD-based PCs, and indeed kept making false and misleading statements and
`omissions about the PCs’ functionality and security.
`24.
`On March 8, 2022, the dam broke. AMD finally recognized that there was a problem.
`AMD explained that systems running Windows 10 and 11 that enabled its fTPM subsystem would
`experience “intermittent system sutter[ing].” The release by AMD tersely blamed the stuttering on its
`CPUs “intermittently perform[ing] extended fTPM-related memory transactions in SPI flash memory
`(‘SPIROM’) located on the motherboard,” which AMD explained led to “temporary pauses in system
`interactivity or responsiveness until the transaction is concluded.”
`25.
`The problem arose, however, from the flaw in the fTPM’s design: it shared resources with
`the PSP subsystem, including flash memory (such as SPIROM), which in turn had access to the PC’s
`CPU and memory resources. When the fTPM consumed too much of the PSP’s scarce processing power
`and its TEE micro-operating system failed to prioritize time-sensitive needs of the overall PC, this caused
`the entire system to stutter. This happened in predictable—but critical—circumstances, such as media
`playback, videoconferencing, or gameplay.
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`26.
`The stuttering had revealed a deep flaw in the AMD-based CPUs that HP incorporated
`into its PCs, including desktop and laptop computers that HP designs, markets, and sells as specially
`adapted for media playback, videoconferencing, and gameplay.
`27.
`AMD provided no meaningful fix for the problem, recommending that owners of AMD-
`based systems buy external hardware TPMs, potentially at significant additional cost. Although AMD
`signaled that firmware updates may be available through individual PC and hardware manufacturers
`(such as HP), there was no true fix possible. The flawed fTPM design, which implemented what should
`have been—by definition—a segregated hardware module in the CPU’s firmware, remained fatally
`defective. No fix could cure the security problem that resulted, nor could there be a fix for the fundamental
`problem that had caused the stuttering—the fTPM is part of a PSP subsystem that can and frequently
`does access the PC’s sensitive CPU and memory resources, including for DRM tasks.
`28.
`The design flaw in AMD’s CPUs—and in the HP computers incorporating them—leads
`to two substantial Effects: (1) intrusive stuttering during media playback, videoconferencing, and
`gameplay; and (2) elevated vulnerability to firmware attacks. Each of these Effects had a direct and
`quantifiable demand and price effect on defective AMD-based PCs sold by HP. Based on a pre-complaint
`statistical conjoint study (described in Section VI of this Complaint), (i) the defective HP PCs were worth
`less at purchase than the price Plaintiffs and Class Members paid for them, resulting in an out-of-pocket
`loss at purchase; (ii) each Effect caused a diminution in value of HP’s AMD-based PCs owned by
`Plaintiffs and Class Members; and (iii) these PCs will remain defective until HP recalls and replaces the
`faulty AMD CPUs in Plaintiffs’ and Class Members’ PCs.
`29.
`This lawsuit seeks to recover this out-of-pocket loss and diminution in value to Plaintiffs’
`and Class Members’ HP PCs, and seeks an injunction requiring HP to replace the PCs that include the
`defective AMD CPUs.
`
`PARTIES
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`I.
`
`PLAINTIFFS
`30.
`Taran Pietosi is a domiciled resident of Pennsylvania, residing in West Mifflin. In 2020,
`Ms. Pietosi purchased a new HP All-in-One 22-df0xxx laptop with an AMD Ryzen 3 processor from
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`Walmart. Ms. Pietosi reviewed and relied upon marketing materials and advertisements concerning the
`HP laptop prior to purchasing it. Ms. Pietosi purchased her laptop for the specific purpose of working
`from home, including voice and video calls, web chat, and the ability to run multiple programs at once.
`She planned to play games on her computer as well, but has been mostly unable to do that upon realizing
`that her processor was unable to run tasks like gaming smoothly. Since purchasing her laptop, Ms. Pietosi
`has experienced stuttering during media playback, video calls, voice calls, and gameplay. Ms. Pietosi
`experiences stuttering on her laptop almost every time she uses any type of audio. None of the
`representations received and reviewed by Ms. Pietosi contained any disclosure relating to the defectively
`designed AMD fTPM in her computer. None of the representations received and reviewed by Ms. Pietosi
`disclosed that her computer would be uniquely vulnerable to firmware attacks, nor that it would
`experience stuttering, because of a defectively designed AMD processor. Ms. Pietosi would not have
`purchased her laptop at the price she paid had she known about the AMD fTPM defect described in this
`Complaint. HP has not fixed the problems with Ms. Pietosi’s laptop attributable to the AMD fTPM defect,
`including its stuttering during audiovisual playback and/or gaming and its unique vulnerability to
`firmware attacks. Ms. Pietosi would like these problems fixed.
`31.
`Sukhdip Rai is a domiciled resident of California, residing in Livingston. In 2019, Mr. Rai
`purchased a new HP Pavilion Gaming Desktop 690-00xx with an AMD Ryzen 7 processor from
`Amazon.com. Mr. Rai reviewed and relied upon marketing materials and advertisements concerning the
`HP laptop prior to purchasing it, including visiting hp.com prior to the purchase. The hp.com website
`boasted fast game play and clock speeds, particularly for gaming. Mr. Rai purchased his desktop
`specifically to play games, watch and edit video, and listen to audio. Since purchasing his desktop, Mr.
`Rai has experienced stuttering at least once or twice per month during video calls, gameplay, and video
`playback. Mr. Rai tried to troubleshoot the issue including performing virus and spyware checks, hard
`drive cleanups, and even factory-resetting his computer. None of these actions fixed the issue and the
`stuttering he experienced has not been fixed. None of the representations received and reviewed by Mr.
`Rai contained any disclosure relating to the defectively designed AMD fTPM in his computer. None of
`the representations received and reviewed by Mr. Rai disclosed that his computer would be uniquely
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`vulnerable to firmware attacks, nor that it would experience stuttering, because of a defectively designed
`AMD processor. Mr. Rai would not have purchased his laptop at the price he paid had he known about
`the AMD fTPM defect described in this Complaint. HP has not fixed the problems with Mr. Rai’s laptop
`attributable to the AMD fTPM defect, including its stuttering during audiovisual playback and/or gaming
`and its unique vulnerability to firmware attacks. Mr. Rai would like these problems fixed.
`
`II.
`
`DEFENDANT
`32.
`Defendant HP, Inc. is a Palo Alto, California-based corporation incorporated under the
`laws of Delaware. HP’s headquarters are located at 1501 Page Mill Road, Palo Alto, California, 94304.
`33.
`According to HP’s annual report filed with the SEC, it is a “global provider of personal
`computing and other access devices, imaging and printing products, and related technologies, solutions,
`and services.” HP sells to individual consumers, to small- and medium-sized businesses, and to large
`enterprises, including to customers in the government, health and education sectors.
`34.
`HP has three business segments: Personal Systems, Printing, and Corporate Investments.
`HP’s Personal Systems segment is responsible for the design, manufacture, and sale of commercial and
`consumer desktop and notebook personal computers (“PCs”), as well as workstations and thin clients.
`35.
`As HP explained in its 2021 Annual Report, HP develops these products using both Intel
`and AMD-based processors and targets the Windows and Google Chrome operating systems:
`
`Both commercial and consumer PCs maintain multi-operating system,
`multi-architecture strategies using Microsoft Windows and Google
`Chrome operating systems, and predominantly use processors from Intel
`Corporation (“Intel”) and Advanced Micro Devices, Inc. (“AMD”).
`36.
`HP provides PCs for both commercial and consumer users, with varying product lines
`targeted to each group. HP describes its commercial PC products as follows:
`
`Commercial PCs are optimized for use by enterprise, public sector which
`includes education, and SMB customers, with a focus on robust design,
`security, serviceability, connectivity, reliability and manageability in the
`customer’s environment and working remotely. Commercial PC include
`the HP ProBook and HP EliteBook lines of notebooks, convertibles and
`detachables, the HP Pro and HP Elite lines of business desktops and all-in-
`ones, retail POS systems, HP Thin Clients, HP Pro Tablet PCs and the HP
`notebook, desktop and Chromebook systems. Commercial PCs also
`
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`37.
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`include workstations that are designed and optimized for high-performance
`and demanding application environments
`including Z desktop
`workstations, Z all-in-ones and Z mobile workstations. Additionally, we
`offer a range of services and solutions to enterprise, public sector which
`includes education and SMB customers to help them manage the lifecycle
`of their PC and mobility installed base.
`As to its consumer products, HP states:
`
`Consumer PCs are optimized for consumer usage, focusing on gaming,
`learning and working remotely, consuming multi-media for entertainment,
`managing personal life activities, staying connected, sharing information,
`getting things done for work including creating content, and staying
`informed and secure. These systems include HP Spectre, HP Envy, HP
`Pavilion, HP Chromebook, HP Stream, Omen by HP Lines of notebooks,
`desktops and hybrids, HP Envy, HP Pavilion desktops and all-in-one lines.
`
`Personal Systems groups its global business capabilities into the following
`business units when reporting business performance:
`
`• Notebooks consists of consumer notebooks, commercial notebooks,
`mobile workstations, peripherals, and commercial mobility
`devices;
`
`• Desktops includes consumer desktops, commercial desktops, thin
`clients, displays, peripherals, and retail POS systems;
`
`• Workstations consists of desktop workstations, displays and
`peripherals; and
`
`• Other consists of consumer and commercial services as well as
`other Personal Systems capabilities.
`38.
`HP’s PC business is highly dependent on central processing units created by AMD and
`Intel. As HP explained in its 2021 Annual Report:
`
`We are dependent upon Intel and AMD as suppliers of x86 processors and
`Microsoft and Google for various software products. We believe that
`disruptions with these suppliers would have industry-wide ramifications,
`and therefore would not disproportionately disadvantage us relative to our
`competitors.
`39.
`HP discloses AMD and Intel as its single-source CPU suppliers, meaning that its PCs are
`dependent on processors from these two companies:
`
`Single-source suppliers. We obtain a significant number of components
`from a single source due to technology, availability, price, quality or other
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`considerations. . . . We also rely on both Intel and AMD to provide us with
`a sufficient supply of processors for the majority of our PCs and
`workstations. Some of those processors may be customized for our
`products.
`40.
`Because HP relies on processors from Intel and AMD, it must maintain a strong
`relationship with these two companies to avoid adverse affects to its business:
`
`In certain circumstances, we purchase components from single-source
`suppliers under short-term agreements that contain favorable pricing and
`other terms, but that may be unilaterally modified or terminated by the
`supplier with limited notice and with little or no penalty. The performance
`of single-source suppliers under those agreements (and the renewal or
`extension of those agreements upon similar terms) may affect the quality,
`quantity and price of our components. The loss of, deterioration of our
`relationship with, or limits in allocation by, a single-source supplier, or any
`unilateral modification to the contractual terms under which we are
`supplied components by a single-source supplier could adversely affect our
`business and financial performance.
`41.
`HP’s Personal Systems division made approximately $43.3 billion in 2021, with notebook
`PCs constituting the bulk of the revenue—$30.5 billion. Desktops were responsible for approximately
`$9.3 billion, and workstations approximately $1.7 billion, of reported 2021 revenue.
`42.
`HP has over 50,000 employees worldwide, including at its offices in Palo Alto, California.
`
`JURISDICTION AND VENUE
`43.
`This Court has personal and subject matter jurisdiction over all causes of action asserted
`in this Complaint.
`44.
`This Court has subject matter jurisdiction over this action pursuant to the Class Action
`Fairness Act of 2005 (“CAFA”), 28 U.S.C. § 1332(d), because at least one member of the proposed
`Classes is of diverse citizenship from D