[HN Gopher] SEC Charges Nvidia with Inadequate Disclosures about...
       ___________________________________________________________________
        
       SEC Charges Nvidia with Inadequate Disclosures about Impact of
       Cryptomining
        
       Author : jmsflknr
       Score  : 239 points
       Date   : 2022-05-06 13:40 UTC (9 hours ago)
        
 (HTM) web link (www.sec.gov)
 (TXT) w3m dump (www.sec.gov)
        
       | ineedasername wrote:
       | Well, I know who is going to be the target of Matt Levine's next
       | "everything is securities fraud" posting.
        
       | kerng wrote:
       | Interesting that the SEC didn't know while probably everyone in
       | in the world knew at least since 2017 that graphics cards are
       | hard to buy because of the cryptomining demand.
       | 
       | Maybe one these things that are so obvious and hence not
       | explicitly mentioned.
        
         | singlow wrote:
         | Its not about whether the SEC knew. It is about whether nvidia
         | properly incorporated that knowledge into their financial
         | reporting. If nvidia knew how many of its cards were going to
         | crypto then they needed to properly report that as a market
         | segment that has different growth profiles than the standard
         | gaming market. That way analysts could evaluate their
         | projections more effectively.
        
           | [deleted]
        
       | capableweb wrote:
       | Now I'm no lawyer nor taxman, and know not a lot of laws in the
       | US, but judging only by the contents of this press release, it
       | seems they were charged with not disclosing that the sales were
       | for cryptocurrency mining, not for doing the business in the
       | first place.
       | 
       | Which begs the question, does Nvidia have a responsibility to
       | know exactly what their equipment is being used for, no matter if
       | that activity is legal or not? Seems they would have to add a
       | mandatory question asking "What are you gonna use this GPU for?"
       | every time they sell a GPU, which seems weird (to me).
        
         | TrueDuality wrote:
         | I'm reading this the same way as others but I've got a little
         | bit different context. It is the responsibility of publicly
         | traded companies to disclose known risks to their investors.
         | Nvidia effectively got major market growth by knowingly selling
         | and presumably prioritizing sales to an target audience that is
         | known to be _extremely_ volatile.
         | 
         | It looks to me like Nvidia downplayed where their growth was
         | coming from so investors (conjecture based on my own
         | observations) couldn't accurately gauge the risk associated
         | with their growth and that is where the SEC starts paying
         | attention.
        
           | JohnJamesRambo wrote:
           | My goodness though, anyone with a brain knew the cards
           | weren't going to gamers. Was this not known to the average
           | investor?
           | 
           | I guess it doesn't even matter because the $5.5 million fine
           | is so laughably small for the rewards they reaped that I'm
           | sure they are still laughing.
        
             | tyrfing wrote:
             | > My goodness though, anyone with a brain knew the cards
             | weren't going to gamers. Was this not known to the average
             | investor?
             | 
             | If it was so obvious, why did Nvidia never say it? This is
             | a quote from a transcript, and seems representative of how
             | they put it:
             | 
             | > ... I would say the large majority of the cryptocurrency
             | demand [is for those] specialized products. There are still
             | small miners that buy GeForces here and there, and that
             | probably also increased the demand of GeForces.
             | 
             | While it may be true that everyone knew they were lying or
             | being misleading, that isn't a very good defense.
        
             | impulser_ wrote:
             | Doesn't matter.
             | 
             | Nvidia needs to provide accurate information on revenues no
             | matter if it obvious or not.
             | 
             | AMD doesn't even report sales of semiconductors for gaming
             | consoles under gaming because it's misleading.
        
             | Xelbair wrote:
             | >anyone with a brain knew the cards weren't going to
             | gamers.
             | 
             | you answered this yourself.
        
             | kelnos wrote:
             | Maybe, maybe not. But the point isn't who the products were
             | going to, it's just that the explosive growth was driven by
             | an unusual, unpredictable customer base, and Nvidia should
             | have disclosed that future growth would be affected if the
             | cryptocurrency mining landscape (something far more
             | volatile than the "regular" market for GPUs) were to
             | change.
             | 
             | I agree that it seems dumb for the average investor not to
             | know this, but this is just how this sort of thing works.
        
               | lukeschlather wrote:
               | What's confusing to me is I swear I've read press
               | releases from Nvidia that have clearly said "we're not
               | adding new GPU production capacity because cryptocurrency
               | miners are creating a demand bubble that's going to pop."
               | Maybe from 2019 though, so maybe they were just waking up
               | to it in 2018.
        
               | impulser_ wrote:
               | They got themselves in terrible in 2018 because they had
               | a lot of excess inventory from over building when the
               | crypto boom happened. I believe the stock dropped 20+%
               | because of this.
               | 
               | They don't want to make that same mistake.
        
             | jetpks wrote:
             | Most people don't know what a graphics card is.
        
             | falcolas wrote:
             | > anyone with a brain knew the cards weren't going to
             | gamers
             | 
             | Gamers, and industry insiders, knew this. The general
             | public (i.e. most investors) didn't. Most non-desktop
             | gamers couldn't give two figs about the intricacies of the
             | videocard market, they just invest in growing
             | companies/stocks.
             | 
             | Or, to put it another way, NVidia Stocks go brrr, buy.
             | Nvidia stock no longer go brrr, complain.
        
             | weird-eye-issue wrote:
             | Not necessarily. There actually was significant growth in
             | gaming with covid and there were lots of improvements with
             | Nvidia's cards so it would be reasonable to assume most the
             | growth is coming from that.
             | 
             | Public companies need to be ahead of risks for investors.
             | If they weren't mentioning crypto mining in earnings
             | reports then that doesn't look good at all.
        
               | JohnJamesRambo wrote:
               | It was for 2017-2018 though.
        
           | 7speter wrote:
           | A funny thing that nvidia was rumored to have done at the end
           | of last year involved them shutting down production of cards.
           | It being the holiday season, people may have settled and
           | bought a card at a higher price, and them stopping production
           | would make the item scarcer. Thats one way to look at it, but
           | I also wondered if nvidia stopped production because they
           | knew that their sales and revenues and profits would all take
           | a hit in q4 2022 and didn't want the decline to look
           | uncontrollably drastic to investors in the earnings report
           | that would come out in early 2023...
        
             | paulmd wrote:
             | That ended up being completely fake. NVIDIA revenue and
             | volumes have actually been on the incline ever since 2020,
             | there was no reduction in production, and this shows up
             | both in their financials and in actual measurements like
             | the Jon Peddie Research GPU market reports (which are the
             | gold standard for this) and Steam Hardware Survey (more
             | granular but perhaps less accurate numbers). They are
             | actually pumping volume even more this quarter on top of
             | not having reduced them as some previously predicted.
             | 
             | > Q4'21 sees a nominal rise in GPU and PC shipments
             | quarter-to-quarter
             | 
             | https://www.jonpeddie.com/press-releases/q421-sees-a-
             | nominal...
             | 
             | NVIDIA is like Apple, there's a certain clique that really
             | really hates them and is willing to make shit up and see
             | what sticks, and there's a huge number of people willing to
             | automatically believe the worst, because "green man bad".
             | It's utterly irrational and goes far beyond the technical
             | merits, people have a viscerally negative _emotional_
             | reaction to these companies and it 's mostly not fact-
             | based, it's just the result of two decades worth of
             | fanboyism and grudges.
             | 
             | (I expect this reply will be followed by a bunch of people
             | trying to list off everything bad they think NVIDIA has
             | ever done, a lot of which will have been "massaged" by that
             | same clique. Like bumpgate... but AMD had tons of GPU
             | failures due to bad solder bumping in the 2012 timeframe
             | too, that's why "baking your GPU" was a thing for
             | _everyone_. Etc etc. NVIDIA is the hillary clinton of
             | companies... they 're a broadly competent competitor who
             | does a decent job, but a decade worth of propaganda has
             | convinced everyone that gosh, there must be _something_
             | there, because I keep hearing about them!)
        
               | 7speter wrote:
               | Yep, why I pointed this out to be a rumor. The linux
               | gaming community makes nvidia cards out to being total
               | bricks on linux, and so far I haven't had any issues I
               | could tie to exclusively using an nvidia card (it
               | actually runs some older games better than the AMD I had
               | before it).
        
           | __Joker wrote:
           | Yes. Everything is a securities fraud. Expect sooner or
           | later(mostly after a bad quarter) may be investors would sue.
        
           | roenxi wrote:
           | This risk is the risk of people not wanting the product a
           | company is selling. Philosophically speaking, it is the job
           | of investors to figure that one out, not the company.
           | Capitalists are meant to decide where the capital gets
           | deployed and all that. Customers deciding to do things
           | differently isn't the sort of operational risk that companys
           | are meant to be experts in.
           | 
           | I don't see how Nvidia can reasonably be expected to know who
           | is using their graphics cards for what either. Unless they
           | are actively courting a specific segment, and even then these
           | things are general purpose cards.
        
             | ineedasername wrote:
             | _> Philosophically speaking, it is the job of investors to
             | figure that one out, not the company_
             | 
             | It's less about _who_ should know, and more about the fact
             | that NVidia _does_ know. And, in knowing, it is obligated
             | to provide accurate information.
             | 
             | NVidia _is also_ actively courting a specific segment. They
             | have introduced crypto-specific chips as well as hash rate
             | limiters in GPU gaming chips, so they are clearly aware of
             | how mining may be a factor in gaming GPU sales.
        
           | grog454 wrote:
           | > It is the responsibility of publicly traded companies to
           | disclose known risks to their investors.
           | 
           | Legally maybe(?) but practically this makes no sense. In the
           | real world it is the responsibility of an investor to
           | understand what they are investing in while maintaining
           | skepticism and scrutiny of their investment. If you can't
           | identify the correlation between massive gains in crypto
           | value with massive gains in NVDA, you shouldn't be investing
           | in NVDA.
           | 
           | Disclosure: long NVDA
        
           | lbarrow wrote:
           | This is exactly right. You have to disclose risks to your
           | business and if a really big part of your growth is coming
           | from a new, volatile customer base, that's a big risk and you
           | should disclose it. It has nothing to do with a specific
           | requirement for GPUs or something; publicly traded companies
           | _in general_ have a responsibility to understand where their
           | revenue comes from and disclose that understanding to the
           | public.
           | 
           | This is very run-of-the-mill stuff for the SEC. I think the
           | only reason it's getting play on HN is that, if you aren't
           | familiar with this sort of thing, it looks like the SEC is
           | picking on Nvidia for doing business with crypto miners. But
           | that isn't what the complaint is actually about.
        
             | deevolution wrote:
             | A risk to someone else is an opportunity for others. Risk
             | is very subjective here
        
               | yunohn wrote:
               | What? The premise is very clear - NVIDIA stock has seen a
               | meteoric rise off hugely increased sales, investors are
               | concerned that nvidia is hiding the share of sales
               | attributed specifically to a new volatile demographic
               | (crypto in this case).
               | 
               | It's like if Intel had 50% of their business from Apple
               | and investors wanted to predict the impact of the M1 chip
               | on their sales.
        
             | 1980phipsi wrote:
             | I wouldn't say it's "exactly right" because the investors
             | knew that's where the growth was coming from. Just because
             | it wasn't in the 10-K doesn't mean that investors didn't
             | know it was a risk.
        
             | mpalczewski wrote:
             | What's surprising to me about this, is that if you ever
             | read the risk section of a 10-k it is basically a bunch of
             | non sense, where they imagine every possible risk no matter
             | how small a business might have. It's filled with so many
             | low probability scenarios it's barely worth reading. If
             | they put in a blurb about this in the risks section I'm not
             | sure who would even notice.
             | 
             | At first glance, I suspect that they just copy pasted the
             | risk section from the last 10-k and this was just some
             | mistake rather than an intention to deceive. Anybody who
             | knew anything about the business understood that crypto
             | mining was a sizable part of that demand.
        
               | dlgeek wrote:
               | And enforcement actions like these are why the 10Ks are
               | full of stuff like that.
        
             | paulpan wrote:
             | The implication is how it holds for the most recent
             | cryptomining cycle, since this settlement was for 2018 and
             | we've definitely seen another surge in demand in 2021.
             | Coupled with the chip shortage, this most recent cycle
             | could well be bigger than this 2018 one.
             | 
             | Nvidia arguably hedged their bets better this time by 1)
             | releasing their cryptomining-specific versions of GPUs, and
             | 2) releasing drivers that tried to cripple the mining
             | performance on the GeForce 3000-series lineup. But whether
             | this was done in good faith is debatable and whether they
             | disclosed properlyin the eyes of the SEC will be
             | interesting to see.
        
           | garyfirestorm wrote:
           | Not defending nvidia but most people who own a single gpu
           | also play games and occasionally use it for mining.
        
             | yjftsjthsd-h wrote:
             | > most people who own a single gpu also play games and
             | occasionally use it for mining.
             | 
             |  _Most_ people with 1 GPU use it to mine? I would have
             | guessed that even with things going crazy in the
             | cryptocurrency space pure gamers were a vastly bigger
             | group.
        
             | NikolaNovak wrote:
             | Orthogonal to the issue at hand, but for what little it's
             | worth, literally nobody I know who games is mining. And
             | this includes a lot of tech-savvy IT professionals.
             | 
             | (half a decade ago, one person I knew was getting
             | excited/contemplating it; but he was looking to build a
             | dedicated mining rig, and I don't think he ever followed
             | up)
        
             | jvreeland wrote:
             | I think most is doing a lot of work there. No one I know
             | who games or does CAD is mining crypto because it's in no
             | way worth it and I imagine there's nothing but anecdata for
             | your statment either.
        
           | vmception wrote:
           | > prioritizing sales to an target audience that is known to
           | be _extremely_ volatile.
           | 
           | Every crypto growth cycle is assumed (by enthusiasts) to be
           | more resilient than the prior growth cycle, on the path to
           | steady growth, and this has turned out to be true, with
           | longer and longer steadier growth cycles, with less and less
           | amplitude in the growth and troughs.
           | 
           | in 2018 there was the same optimism, that culminated in a
           | long steep crypto bear market, the longest one so far.
           | Although I think it is obvious that bubbles pop, especially
           | crypto bubbles, I don't think it was obvious or relevant that
           | sales to miners would disrupt so immediately that Nvidia
           | investors needed to know this level of nuance. miners have
           | such high profit margins (if integrated properly) that steep
           | declines in crypto prices shouldn't affect them, but in this
           | case it did.
           | 
           | Especially when looking at the resilience and structure of
           | the mining sector now.
           | 
           | I think this is an odd demand by the SEC, but Nvidia settled
           | it for pennies so moving on.
        
         | lettergram wrote:
         | I don't think this makes sense. The SEC isn't there to protect
         | the share holders, I don't know wtf this is.
         | 
         | The only thing they could be required to disclose was the
         | percent of sales THEY KNEW were being used for crypto. They
         | also wouldn't be required to capture that data really. Plus
         | I've been on their quarterly calls, they've been pretty open
         | about their exposure to crypto so idk.
         | 
         | This seems well beyond the scope of the SEC... imo it's their
         | broader plan to go after crypto, but everyone knows they have
         | no legal basis currently to do so.
        
         | 7speter wrote:
         | There's been prevalent rumors in the gaming community that
         | nvidia sold complete graphics cards to mining operations. A lot
         | of times its waived off as the board partners (Asus, MSI,
         | Zotac, etc) and not nvidia but nvidia does sell reference (they
         | call them founders edition) cards. Also there was this big
         | thing in december where there were rumors of a 12gb 2060 design
         | that would alleviate gamer demand but it turned out the
         | whispers that came out of the rumor mill itself a week before
         | the release was that those gpus were made with the top priority
         | of going to miners and not gamers. When examples of those cards
         | came to market they were going for ~750 dollars in january, but
         | now nvidia and board partners seemingly have pie in their face
         | with those cards rotting on shelves at microcenters for $389
         | (the 2060 is a previous generation card and its original msrp
         | was 329 in 2019).
         | 
         | The sec may be starting an investigation from the top down to
         | see if nvidia had any involvement in what they are accusing
         | them of and will see what degree of complicity they and board
         | partners had in all of this.
         | 
         | Anyways I'm jumping the gun a bit there but there are distinct
         | differences between cards for typical consumer uses (gaming,
         | and video and machine learning workflows) and mining, and
         | mining was a big part of the reason why prices were insane (a
         | 3070ti which can now be found on sale for 699 was going for
         | 1900+ dollars on amazon at ethereums peak) since January of
         | last year until the recent gradual descent in prices.
        
         | madeofpalk wrote:
         | The relevant part from the article:
         | 
         | > NVIDIA had information, however, that this increase in gaming
         | sales was driven in significant part by cryptomining. Despite
         | this, NVIDIA did not disclose in its Forms 10-Q, as it was
         | required to do, _these significant earnings and cash flow
         | fluctuations related to a volatile business_ for investors to
         | ascertain the likelihood that past performance was indicative
         | of future performance.
        
         | macspoofing wrote:
         | > does Nvidia have a responsibility to know exactly what their
         | equipment is being used for, no matter if that activity is
         | legal or not?
         | 
         | In aggregate .. yes.
         | 
         | As a company, you should know if the increase in sales for your
         | product was a result of the gaming market growing, or the
         | research market growing, or the crypto market growing.
         | 
         | And as a publicly traded company, you have to communicate this
         | to investors.
         | 
         | >Seems they would have to add a mandatory question asking "What
         | are you gonna use this GPU for?"
         | 
         | They don't need to do that.
        
         | philipwhiuk wrote:
         | No they don't have requirement to know.
         | 
         | But if they do know what their GPUs are used for and then they
         | say something else, that's a problem. And that's what the SEC
         | has a problem with here.
        
           | philipwhiuk wrote:
           | They probably should have said something like:
           | 
           | x units were sold from our gaming line of products, however
           | market research indicates y % of them are likely being used
           | for cryptomining.
        
             | singlow wrote:
             | I don't think it is even that important whether they
             | specifically enumerate the destination of the cards. The
             | important thing is that they should create an honest
             | projection and risk assessment. When they present their
             | earnings statement they need to indicate not only how much
             | they sold but how much they expect to sell in the future.
             | If they knew that a large portion of cards were going to
             | cryptominers then they need ed to indicate the potential
             | difference in growth stability between those sales and the
             | normal consumer sales.
        
         | paulgb wrote:
         | The issue here wasn't whether they should have known, but that
         | they (apparently) did know and didn't disclose it. Whether
         | NVIDIA has a duty to know is not at issue here, since they did:
         | 
         | > NVIDIA had information, however, that this increase in gaming
         | sales was driven in significant part by cryptomining
         | 
         | Color me a little surprised that this is what SEC's Crypto
         | Asset is spending resources on when there is such a dumpster
         | fire of obvious fraud in other areas of crypto (looking at you,
         | public mining companies), but I suppose NVIDIA's upswing did
         | catch a lot of retail investors.
        
           | jonathaneunice wrote:
           | You're absolutely right this is the least of the crypto
           | dumpster fires / fraud situations.
           | 
           | But the official disclosures of public equity firms is one of
           | the lampposts the SEC's clearly mandated to look under. In
           | fact, crypto is essentially immaterial here. If NVIDIA knew
           | that a huge part of their GPUs were being used for the new,
           | highly-volatile fad of Quantum Fubaring instead of the gaming
           | market NVIDIA'd previously disclosed was the market target,
           | the SEC would still have the right and responsibility to ding
           | them for deceptive or insufficient disclosures.
        
         | duxup wrote:
         | I don't think you HAVE to know, but let's say you don't know,
         | now you better not make a statement like you do know in you're
         | earnings report. Or if you do and you make a false statement
         | ...
        
         | gambiting wrote:
         | >>Which begs the question, does Nvidia have a responsibility to
         | know exactly what their equipment is being used for, no matter
         | if that activity is legal or not?
         | 
         | They are being charged not for not knowing, they are being
         | charged for knowing and not disclosing it. The "knowing" part
         | seems to be a forgone conclusion, or at least SEC must have
         | ironclad proof.
         | 
         | >> Seems they would have to add a mandatory question asking
         | "What are you gonna use this GPU for?"
         | 
         | No, but if they are selling thousands of GPUs to cryptominers,
         | they don't need to ask to know. Same how if the US Airforce
         | purchased 100k GPU chips, you can safely assume they won't be
         | using them to play Fortnite, no questionnaire necessary.
        
           | dragonwriter wrote:
           | > The "knowing" part seems to be a forgone conclusion, or at
           | least SEC must have ironclad proof.
           | 
           | The SEC doesn't need ironclad proof for a civil fine. The
           | standard is preponderance of the evidence, not beyond a
           | reasonable doubt.
        
           | cjbgkagh wrote:
           | I wonder if they're using the GPUs in radars.
        
           | erikerikson wrote:
           | The Airforce has flight simulators and other video games for
           | which it must use GPUs. Additionally there are ML models to
           | build and so on. Of the things I would predict, crypto mining
           | would be the least of them.
        
             | gpderetta wrote:
             | I don't think the parent was implying they were.
        
               | erikerikson wrote:
               | > Same how if the US Airforce purchased 100k GPU chips,
               | you can safely assume they won't be using them to play
               | Fortnite, no questionnaire necessary.
               | 
               | My intention was to gently counter this statement. I took
               | Fortnite as a proxy for video games and I meant to add to
               | the conversation that it does use video games. For a
               | while the military was even publishing video games.
        
             | gambiting wrote:
             | Of course, but when you are disclosing your business
             | activities, selling to the military is a pretty major thing
             | to mention, no? You wouldn't just lump it all under
             | "gaming", because your gpus _might_ be used to play video
             | games.
        
               | erikerikson wrote:
               | I accept lower salaries to never have to care about
               | reporting to the SEC. The lost revenues are offset by
               | doing work that matters.
        
         | stjohnswarts wrote:
         | I think it's ridiculous. I think if the government wants you to
         | "declare" something they need to make it explicit and how
         | important that is to "declare". This is probably just someone
         | in that department trying to get their name in trade rags in
         | order to get a promotion.
        
         | vondur wrote:
         | Heck, they modified their driver software to make reduce
         | bitcoin mining efficiency.
        
         | jcranberry wrote:
         | The issue is that they knowingly misinformed their investors.
         | 
         | >In two of its Forms 10-Q for its fiscal year 2018, NVIDIA
         | reported material growth in revenue within its gaming business.
         | NVIDIA had information, however, that this increase in gaming
         | sales was driven in significant part by cryptomining.
        
         | spamizbad wrote:
         | You have to disclose what you know. It's fine to say "We know
         | people are buying them, but we do not have metrics as toward
         | their use" assuming that's a factually true statement (your
         | business does not collect metrics from sales channels or
         | consumers giving you an indication toward their use). A
         | terrible way to run a business, but legal!
         | 
         | However, if your data indicates that most of your revenue
         | growth is likely due to crypto mining and you turn around and
         | tell investors it's because of gaming, you are lying and
         | misleading your investors.
        
         | tfehring wrote:
         | NVIDIA is required to monitor material risks to its business
         | and disclose them to shareholders. I think in theory the reason
         | for that requirement is so that unsophisticated retail
         | investors don't buy the stock and then lose a bunch of money
         | due to risks they didn't anticipate, though it feels pretty
         | quaint to expect retail investors to read Forms 10-Q.
         | 
         | Importantly, they _did_ (according to the press release) know
         | that a big part of their sales growth was from cryptomining. I
         | have no idea how they measured the magnitude, but miners weren
         | 't exactly quiet about scooping up graphics cards.
        
           | sokoloff wrote:
           | > it feels pretty quaint to expect retail investors to read
           | Forms 10-Q
           | 
           | It's not that there's an expectation that retail (or any
           | given) investor reads the 10-Q; it's sufficient that there is
           | a standardized way to publicize that information and, if you
           | lose money because you _didn 't read_ the readily available
           | information, well, you're an adult who can make investment
           | decisions on whatever criteria you want and that's on you.
        
           | senko wrote:
           | > [any public company] is required to monitor material risks
           | to its business and disclose them to shareholders
           | 
           | This basically means everything is securities fraud: https://
           | www.bloomberg.com/opinion/articles/2019-06-26/everyt...
           | 
           | The parent question still stands: why would NVIDIA need to
           | police how their products get used? They're not manufacturing
           | weapons or drugs.
        
             | gpderetta wrote:
             | They do not need to police it. But how their products are
             | used has an impact on the growth of the company as it can
             | affect future demand; it appears that if the company has
             | this sort of knowledge it is supposed to disclose it to
             | investors.
        
               | singlow wrote:
               | Right. And not just disclose it as a fact, but
               | incorporate it into their projects and risk outlooks.
        
             | Retric wrote:
             | No, the requirement isn't perfection but NVIDA is charged
             | with failing to disclose significant risk that they where
             | aware of.
        
             | JackFr wrote:
             | They don't need to police how their GPU's are being used.
             | 
             | They simply need to release fiancial statements which
             | accurately reflect material information they know.
             | 
             | That securities law can be abused unscrupulous profit
             | seeking lawyers is not news, and isn't really germane to
             | this case. The issue at hand was disclosing information
             | essential to financial results rather than fanciful
             | hypothetical risks.
        
             | VWWHFSfQ wrote:
             | > NVIDIA did not disclose in its Forms 10-Q, as it was
             | required to do, these significant earnings and cash flow
             | fluctuations related to a volatile business for investors
             | to ascertain the likelihood that past performance was
             | indicative of future performance.
             | 
             | Basically they were dishonest about the nature of the
             | business that was driving the short term growth.
        
               | senko wrote:
               | > NVIDIA did not disclose [...] for investors to
               | ascertain the likelihood that past performance was
               | indicative of future performance.
               | 
               | I mean, who am I to argue with SEC, but "past performance
               | is not indicative of future results" should be firmly
               | planted in the minds of everyone remotely capable of
               | understanding the 10-Q.
               | 
               | To me this seems like it was a "hey, you should
               | definitely split out crypto earnings in your gaming
               | division" with a slip on the wrist. Doesn't sound like a
               | big deal.
               | 
               | And going on the tangent, who says earnings due to crypto
               | are more risky than earnings due to gaming? There's been
               | a dearth of new AAA titles and due to the inflation
               | gamers may very well delay their PC upgrade. Sounds as
               | risky as miners to suddenly stop buying equipment, and
               | faster than what the hardware-hungry gaming crowd can get
               | their hands on.
        
             | Robotbeat wrote:
             | Actually... You could potentially consider a GPU an arm
             | subject to EAR/ITAR regulations. EAR/ITAR are overly broad
             | (in a way that could be unconstitutional), so I wouldn't
             | rule it out. https://wccftech.com/us-government-bans-intel-
             | nvidia-amd-chi...
        
         | ineedasername wrote:
         | Public companies have a responsibility to disclose any known
         | risks that are material to their performance.
         | 
         | It could be argued that they don't have a responsibility, or
         | only a limited one. But in this case they really can't that
         | they're actually unaware of it's use for mining. It's not
         | necessary on an individual person-by-person basis, they know
         | that a substantial amount of hardware is used for it.
         | 
         | Perhaps they don't know _exactly_ how many or what %, but a
         | little bit of market research-- over an issue highly material
         | to their bottom line-- would be expected (and was probably
         | done, but maybe they 're bad at their jobs). At a minimum it's
         | trivial to see that sales are correlated to the crypto market.
         | 
         | Also AMD managed to note the risk in its own 10-Q filings.
        
       | cc1616 wrote:
       | Naive question: What does Nvidia have to gain from not accurately
       | disclosing this information?
        
         | y04nn wrote:
         | By not disclosing it they hide the fact that their core
         | business growth may be at risk in case of a cryptocurrency
         | crash. And they may know that if they sell directly to crypto
         | miners.
        
         | philipwhiuk wrote:
         | Maybe more investment. If you're an investor who thinks crypto
         | is a flash in the pan whereas gaming demand is likely more
         | permanent, if you are told the growth is gaming, not crypto,
         | you'll be more likely to invest.
        
         | tejohnso wrote:
         | They could state, or imply, that their sales growth is due to
         | an increased demand in their core business. Which may be
         | considered much better than the increased demand coming from a
         | secondary, highly volatile, and potentially highly regulated
         | business.
        
         | duxup wrote:
         | It could be an actual mistake.
         | 
         | On the other hand I know Nvida and others are sensitive to how
         | they're perceived by non crypto folks and would / could even
         | accidentally try to downplay how much the price / sales are
         | driven by crypto.
         | 
         | But you really shouldn't do that in an earnings report.
        
       | mrtweetyhack wrote:
        
       | jpalomaki wrote:
       | " NVIDIA had information, however, that this increase in gaming
       | sales was driven in significant part by cryptomining. Despite
       | this, NVIDIA did not disclose in its Forms 10-Q, as it was
       | required to do [...]"
       | 
       | That seems to be main issue - they knew, but did not disclose.
        
         | xiphias2 wrote:
         | Additionally Jensen Huang was specifically asked about it in
         | the quaterly call and said that it wasn't significant part of
         | the demand from that quarter. It made a lot of investors angry,
         | as it was a very strange statement that didn't really make
         | sense.
        
         | ticklemyelmo wrote:
         | They didn't disclose that information that everyone even
         | vaguely involved in the tech and gaming industry knew!
        
       | citizenpaul wrote:
       | Its good the SEC is investigating poor disclosures. You know
       | rather than the rampant fraudulent activity happening all across
       | their supposed purview.
        
       | zzleeper wrote:
       | I just bought an RX 6600, for about $320. It's definitely not the
       | latest GPU, not even close, but it made me realize something:
       | 
       | Because of the GPU shortage, game makers couldn't rely on enough
       | users having the best/latest card, so now there is not much point
       | in having, say, a RTX 3090, where a 3080 performs as well for
       | most non-mining purposes.
       | 
       | Now, what if crypto enters a crisis (or ETH switches to PoS,
       | which is less likely), and then the next generation of GPUs has
       | almost no demand at the inflated triple-digit prices. That's
       | going to be a huge hit to its market cap
        
         | vmception wrote:
         | > and then the next generation of GPUs has almost no demand at
         | the inflated triple-digit prices. That's going to be a huge hit
         | to its market cap
         | 
         | NVIDIA ('s distributors) still sale at the lower MSRP (right?)
         | so the risk for them is people not buying them at all, which
         | seems more farfetched
         | 
         | maybe I'm wrong, but I thought the true price was shown by what
         | scalpers could fetch, which means the places the scalpers buy
         | from had the wrong lower price
        
         | Havoc wrote:
         | >game makers couldn't rely on enough users having the
         | best/latest card
         | 
         | Yup. Built a rig (2070S/3700X) just before covid/shortage
         | kicked off and it has been holding up suspiciously well two
         | years later - likely due to that effect.
         | 
         | 3 year old card and no immediate need for an upgrade in sight.
        
         | mtoner23 wrote:
         | Eth is switching to PoS https://ethereum.org/en/upgrades/merge/
        
           | dehugger wrote:
           | When? The time frame on that page is "eventually" which more
           | or less equates to "perhaps, someday". Until a date is
           | committed to and the merge actually occurs Ethereum proof of
           | stake will never be taken seriously.
        
             | okwubodu wrote:
             | There's more than 25 billion on the line with the merge so
             | it's not like they're stalling for fun.
        
           | tromp wrote:
           | Probably sometime in the next 5 years...
        
       | onphonenow wrote:
       | Umm, wasn't this super well known? Every enthusiasts website had
       | tons of tracking of card prices which were high because of...
       | cryptomining.
       | 
       | I mean, really entry level folks knew this.
       | 
       | When crypto prices would go down a bunch of articles would pop up
       | saying, hey, maybe supply for gaming will go up.
       | 
       | I read these risk sections and 80% of the stuff is so overblown,
       | boilerplate, repetitive, well known etc that it loses its
       | usefulness.
        
         | xxpor wrote:
         | This was from 2018, before card prices really exploded.
        
           | onphonenow wrote:
           | That is a key point then ok.
        
       | boredumb wrote:
       | Just wait till the feds find out that my "gaming" card has been
       | used extensively to train pytorch models. Book um danno!
        
         | reaperducer wrote:
         | _Just wait till the feds find out that my "gaming" card has
         | been used extensively to train pytorch models. Book um danno!_
         | 
         | Are you telling your investors that you're using your gaming
         | card for games, and then using it for pytorch models?
         | 
         | Remembering that this is the SEC, not the FBI, gives you a lot
         | of context.
        
           | selimthegrim wrote:
           | But Agent, I started my rig up at 8:00 am that morning, not
           | 8:01 am like the power company records say...
        
           | boredumb wrote:
           | For starters it was a joke, but the SEC is still a federal
           | agency, for joke context.
        
       | FollowingTheDao wrote:
       | Gaming, yeah, that's the problem, not the environmental damage...
        
       | stjohnswarts wrote:
       | Nvidia is now Big GPU? lol
        
       | jenny91 wrote:
       | NVIDIA knew a lot of their GPUs were bought for crypto mining,
       | but attributed those sales instead to growth in gaming,
       | potentially misleading some investors (maybe they wanted to
       | invest in gaming, not the very volatile crypto industry).
       | 
       | This is the SEC doing their job, giving a public company a
       | reminder to be honest about their disclosures. The fine is
       | insignificant and nobody is in trouble.
       | 
       | It has nothing to do with whether people could've read between
       | the lines, whether NVIDIA has a duty to know what their products
       | are used for, or anything like that. Just that they knew what was
       | going on and told a small lie to bolster their finances. You
       | should be able to read company financial disclosures and trust
       | them.
        
         | paulmd wrote:
         | AMD and NVIDIA's numbers for crypto sales have always been
         | dodgy. Like in 2017-2018 I think they said that crypto sales
         | (including gaming cards used for crypto) made up like 5% or 10%
         | of their revenue, which is total bullshit. I assume they had a
         | range of potential numbers internally (there is always a range)
         | and they picked the lowest possible number to avoid spooking
         | investors.
         | 
         | There is very very little gaming demand for these cards at 2-3x
         | MSRP. Yeah, there's a few, but not many. As mining demand has
         | tapered off this quarter, you've seen prices absolutely
         | plummet, and if there was truly organic gaming demand for cards
         | at those prices, that wouldn't have happened.
         | 
         | When prices get super elevated (that 2-3x MSRP range), IMO the
         | realistic number is at least 30% if not more like 50% of total
         | sales are crypto-related.
         | 
         | Some caveats:
         | 
         | bear in mind that OEM sales are a huge thing. Something like
         | half the cards on the market will never even hit a distribution
         | channel. So even if nearly-100% of _aftermarket_ sales go to
         | miners, there 's a significant number being moved in prebuilts.
         | That said, at the height of crypto mania, miners will buy
         | prebuilts and strip them of their GPUs and resell them on
         | ebay/craigslist/facebook, so OEM sales are not 100% crypto-
         | unrelated either.
         | 
         | I am taking that into account when I am guessing 30-50% - I
         | think the number for _retail_ sales are  >75% if not >90% miner
         | sales when that happens, and it's really only the OEM sales
         | that hold things down to 30-50%. There are _very few_ actual
         | _consumers_ willing to pay the $2400 that 3080s were going for
         | at their peak, that 's _triple MSRP_ , and prices immediately
         | plummeted when the LHR was created, because prices are driven
         | by hash rate and expected crypto profit, not gaming sales.
         | 
         | AMD more or less didn't participate in crypto this time around
         | though, because they simply didn't make any GPUs. 6800 and
         | 6700XT are reasonably competent miners - about 3060 Ti/3070
         | performance, which is undesirable in a _relative_ sense
         | compared to Ampere and RDNA1 but that 's still twice the
         | hashrate of a RX 480, miners still use those cards very
         | happily, and RDNA2 is more efficient because it's 7nm. But it
         | took over a year after launch for the first RDNA2 card to show
         | up on the Steam Hardware Survey - at 0.15% marketshare.
         | Meanwhile Ampere was around 10% marketshare at that time. You
         | can go back and look at the historical Steam results using the
         | Wayback machine, or here's a contemporary article (you don't
         | have to like Tom's, the numbers are from Steam):
         | 
         | https://www.tomshardware.com/news/rtx-3090-outsells-all-rx-6...
         | 
         | (If anything this probably understates it since miners did go
         | after NVIDIA cards preferentially. It's likely more like a
         | factor of 20x in total shipments, vs the Steam numbers. I guess
         | that's where you go to the JPR numbers tho.)
         | 
         | Basically, AMD did not make hardly any GPUs because console
         | sales were unexpectedly high and those contracts got first
         | priority, at one point there were reports that console sales
         | were eating 80% (!) of AMD's wafer supply. The remaining wafers
         | went to CPUs since even a consumer CPU is ~10x more profit per
         | wafer than a GPU - it makes complete sense to maximize their
         | revenue on the remaining wafers after consoles got the lion's
         | share.
         | 
         | https://www.hardwaretimes.com/in-q4-amd-supplied-a-total-of-...
         | 
         | RDNA2 was the paperiest of paper launches. They delayed it as
         | long as they could, and did a token paper launch to satisfy
         | investors. I think the term "paper launch" is overused - it
         | doesn't mean "I can't buy one on launch day" or even "I can't
         | get one the first month" - Pascal took 6 months for inventory
         | to normalize, 1080 was unobtanium until about November 2016 and
         | even the 1070 was hard to get for a few months. Someone I know
         | used the term "holodomor launch" at the time (cringe). But
         | RDNA2 was a true paper launch, in the sense of only existing to
         | satisfy commitments made to investors. AMD had no intention of
         | producing serious quantities of it when they could be making
         | 10-50x the money per wafer selling CPUs (and wafers are their
         | bottleneck scaling profit). 6700XT and 6600XT/6600 were the
         | only cards that shipped in any volume and those lower-end cards
         | didn't launch until almost a year after the initial RNDA2
         | cards.
         | 
         | Not saying that wasn't the right decision in a financial sense,
         | of course. Investors want them to make money, and AMD was very
         | very wafer-bottlenecked. But the GPUs were launched just to say
         | they launched.
         | 
         | But in a backhanded way, that was a good strategy this time
         | around. No GPUs manufactured means very little crypto exposure.
         | That's one solution to crypto boom-and-bust I guess - find a
         | new market and don't sell GPUs anymore. NVIDIA is very, very
         | subject to the boom/bust cycle of crypto and unlike AMD or
         | Intel they don't have diversity of other products to smooth
         | things out (not just other segments like enterprise/automotive,
         | but other _products_ like CPUs and mobile SOCs, etc).
         | 
         | AMD did participate last time though, and they had a huge
         | inventory overhang that took almost a year to clear just like
         | NVIDIA did. Not sure where people got the idea they didn't, but
         | they discussed it openly in their late-2018 and early/mid-2019
         | financials calls... Here's a random one from that period I
         | pulled up, ctrl-f "inventory" and look for yourself.
         | 
         | https://www.fool.com/earnings/call-transcripts/2019/01/30/ad...
         | 
         | Also, the bit about "NVIDIA selling cards directly to miners!"
         | ended up being fake and based on tech media wildly
         | misinterpreting a paywalled RBS article (that none of them
         | wanted to pay for lol) that used an estimate of crypto network
         | hash growth to estimate crypto gpu sales... after some
         | massaging the line "miners bought $175m of NVIDIA GPUs based on
         | hashrate estimates" became "NVIDIA sold $175M of their GPUs
         | directly to miners outside retail channels" which simply isn't
         | true.
         | 
         | Fake spin: https://www.kitguru.net/tech-news/featured-
         | announcement/leo-...
         | 
         | Actual article:
         | https://twitter.com/dylan522p/status/1332502890104188929
         | 
         | This is a great example of what I reference elsewhere in the
         | thread, about how there's a clique that likes to manufacture
         | fake or marginal rumors about NVIDIA, because a lot of people
         | have viscerally negative emotional reactions to NVIDIA and it
         | gets a lot of attention and clicks.
         | 
         | Mining card sales (not _gaming cards used for mining_ , but
         | actual dedicated mining cards) were a thing, but a very small
         | thing overall (I'd guess less than 5% revenue as a segment,
         | with gaming running around 50%). And many mining cards are
         | still sold through partners or OEMs like HP... I used to see
         | the EVGA cards coming through b-stock back in 2019.
         | 
         | Now in contrast _partners_ were absolutely selling gaming cards
         | in bulk direct to miners. Miners pay a premium for access to
         | the cards, and partners require them to give up their
         | warranties, so it 's an advantageous deal for them, but as far
         | as I know NVIDIA does not sell direct.
         | 
         | Just some baseline stuff that I often see come up in the
         | nvidia/crypto discussions that is wrong, tried to source as
         | much as I can.
        
           | caymanjim wrote:
           | That's a lot of words and a lot of numbers that you appear to
           | have pulled out of thin air.
        
           | anonymous0099 wrote:
           | Some gamers with high-end cards are likely doing a bit of
           | mining. If the parents or dorms are picking up the
           | electricity bill, that makes sense. And then there are some
           | cards that are used for gaming and to study deep learning, I
           | guess. It is likely a bit more of a mixed use of compute than
           | just pure mining.
           | 
           | To give an example, I'm not a student, but I do have a box
           | with 2 x RTX 2080 sitting in my garage, which I use for
           | hobbyist deep learning research. Sometimes, I also need
           | heating in my garage, it gets cold during the winter. It was
           | pretty easy to flash a NiceHash usb stick. So I boot it from
           | it and it becomes a 1.5kW heater which pays for itself. Not
           | particularly efficient or climate friendly, but oh well.
        
             | paulmd wrote:
             | > Some gamers with high-end cards are likely doing a bit of
             | mining. If the parents or dorms are picking up the
             | electricity bill, that makes sense.
             | 
             | Yeah, I think a good number of gamers who bought cards are
             | mining on them in their spare time as well. I'm counting
             | that as a gaming sale since it's primarily for gaming
             | rather than someone who set out to buy 10 cards and build a
             | mining rig, but I do think a lot of people did the "well,
             | I'll mine on it when I'm not using it and it'll soften the
             | blow a bit..." approach.
             | 
             | And you don't even need free electricity, the cards were
             | and are still profitable, just not profitable enough
             | (anymore) to gamble $10-20k setting up an industrial-style
             | mining rig with a full loadout of cards. If you have the
             | card anyway (because you game/train AI/etc) then it's still
             | worth mining.
             | 
             | I question how many people cashed out regularly though,
             | there may be a lot of people sitting with a bunch of paper
             | profits from their gaming card...
             | 
             | > And then there are some cards that are used for gaming
             | and to study deep learning, I guess. It is likely a bit
             | more of a mixed use of compute than just pure mining.
             | 
             | I think that's a small market in general, there's not
             | millions and millions of those people and they're not
             | setting up hundreds of rigs with thousands of cards, but
             | yeah definitely, that exists. I know people who bought a
             | quad-1080 ti or quad-3090 rig and used it for
             | gaming/DL/homelab and mined on it when they weren't using
             | it.
             | 
             | It was perhaps a little less appealing this gen since there
             | was never a proper Titan - the 3090 is still locked down in
             | certain types of operations, not just FP64 but also some
             | data types/operations that iirc might be relevant to DL
             | users. bfloat16, and some types of FMA operations, or
             | something like that? But lots of people can work around it
             | or it isn't relevant to the thing they wanted to do, there
             | are still a decent number of DL/homelab people who will buy
             | it. It's again, not a gigantic market, but it's there.
             | 
             | imo with the way prices stacked up - it was $2400 for a
             | 3080 or $3000 for a 3090 on ebay, and it was actually
             | possible sometimes to get 3090s at decent prices ($2000)
             | from partners (Zotac, EVGA, etc), where it wasn't really
             | possible to ever score a 3080 from partners due to extreme
             | levels of demand. So you could score a retail 3090 for
             | cheaper than an ebay 3080, and actually even at ebay
             | pricing, if you're going to spend $2.4k on a GPU
             | _anyway_... just spend the last $600 and get the extra
             | VRAM. 10GB is going to noticeably shorten the viable
             | lifespan of the card anyway.
             | 
             | Given the pricing, it made a lot of sense imo to aim for
             | the 3090 over the 3080, both for homelab/DL type stuff, and
             | honestly also because the 3080 had a very stingy amount of
             | VRAM out of the box even for gaming. I know the technical
             | reasons (yield, memory bus width, etc) that make this
             | complicated, but I'd really liked to have seen 12GB on the
             | original 3080, if not 16GB. I think GDDR6X was a mis-step
             | in a lot of ways and they would have been better off with a
             | conventional 512b bus with GDDR6 instead of a super-fast
             | 384b bus with GDDR6X... but that also complicates routing
             | and board design.
        
             | lostmsu wrote:
             | Case in point: I do all of the above. These RTX cards are
             | marvelous.
        
           | johnwalkr wrote:
           | > There is very very little gaming demand for these cards at
           | 2-3x MSRP
           | 
           | Anecdotally, I know 10 or so people that paid 2x+ for RTX3000
           | series cards and zero that are mining. A lot of people my age
           | (about 40) got back into PC games for something to do during
           | the pandemic.
        
             | dubcanada wrote:
             | Are you big in the crypto world? Cause one miner buying 250
             | cards matters a lot more then 10 gamers buying 1 each.
             | 
             | Also miners are typically buying the best card per a price
             | point, which tends to be higher end or datacenter cards.
             | Your average gamer is usually buying a medium tier.
             | 
             | The price point is also completely indifferent.
        
             | paulmd wrote:
             | Anecdotally I know a lot of people who are too ashamed to
             | admit they're mining on it in their spare time but know
             | that leaving a money printer that makes $5 a day sitting
             | idle is stupid. ;)
             | 
             | (even today, a 3090 is still profitable even with absurd
             | $0.30/kWh electricity or whatever - if you are around the
             | national average of 10c they're still doing like $3 a day.
             | Not "buy 10 of them and build a rig" profitable anymore,
             | but at the peak they could do ~$11 a day after electricity
             | and for a long time they were $5 a day after electricity.
             | Pre-LHR 3080s were a beast too, almost the same hashrate as
             | a 3090.)
             | 
             | Anyway the backlash against mining and miners in the 2021
             | timeframe was real and intense. I'm not saying there aren't
             | legitimate reasons - it's a waste of electricity, it's
             | screwing up the market for everyone else, etc - but I think
             | a huge number of gamers who bought cards in the 2020-2021
             | timeframe mined on them when they weren't using them and
             | just don't want to admit it.
             | 
             | Unfortunately, crypto is a memeplex, it's like a
             | corporation, it's a self-reinforcing _living entity_ that
             | supports itself (maintains homeostasis) through a series of
             | rules and incentives, and now that it 's been created it
             | can't be easily killed. Every individual is financially
             | incentivized to keep playing their part, so everyone would
             | have to collectively agree to not make money by taking
             | part, and as people fall out the incentives become steeper
             | and steeper to participate. Would you mine on your card for
             | $100 a day? $1000 a day?
             | 
             | Even if you pulled the plug on the exchanges, crypto is far
             | enough along that it would be self-sustaining simply based
             | on the black market. And the existence of PoS paradoxically
             | makes it impossible to ever kill the PoW coins, because
             | they can be traded on decentralized exchanges even if the
             | real money exchanges ban them.
             | 
             | We will just have to live with destroying our planet,
             | because now that it's been created it's virtually
             | impossible to kill. That was the whole point. With
             | apologies to _Alien_ : it's biologically engineered to be a
             | survivor... the perfect predator (of certain other
             | memeplexes).
        
             | im3w1l wrote:
             | There are few miners so it's unlikely you would know one.
             | But every miner buys a ton of cards, so even though there
             | are few of them it matters a lot.
        
         | thereddaikon wrote:
         | My only problem here is once again the fine is meaningless.
         | $5.5 million is couch change for Nvidia. The fines are supposed
         | to deter these actions. This has no effect whatsoever.
        
           | nickff wrote:
           | Fines against public companies are among the least effective
           | deterrents I can possibly imagine. The officers make the
           | mistake/misrepresentations, and the shareholders take the
           | hit. If the government really wanted to deter these actions,
           | they'd fine the officers making the 'wrong' statements.
        
             | omegalulw wrote:
             | This is a terrible idea. Mistakes of this magnitude are
             | often the result of multiple people making mistakes - so
             | blaming a specific person is wrong.
             | 
             | Not to mention that this would force a culture of
             | attributing blame to individuals which is toxic, encourages
             | people to hide mistakes and when mistakes happen the first
             | thing everyone would scramble to is to find a scapegoat.
             | This is objectively worse for both the company and the
             | shareholders.
             | 
             | The right approach for the government is to appropriately
             | penalize the companies. The right approach for companies is
             | to put in processes that make sure no single person is even
             | in a position to make mistakes like this.
        
               | nickff wrote:
               | > _" The right approach for the government is to
               | appropriately penalize the companies."_
               | 
               | The government isn't penalizing the companies, it's
               | penalizing the shareholders, who are the ones that
               | suffered the inadequate disclosures!
               | 
               | > _" Mistakes of this magnitude are often the result of
               | multiple people making mistakes - so blaming a specific
               | person is wrong."_
               | 
               | Then either split the fine amongst the responsible
               | parties, or just issue some sort of order that requires
               | changes (such as some sort of audit) without a fine. If
               | you can't find any specific person who did something
               | clearly wrong, it's probably best to avoid blaming 'the
               | company' (which is just a collection of individuals).
        
               | yywwbbn wrote:
               | What makes you think the SEC can find the 'guilty'
               | parties and that the company (i.e. possibly the very same
               | people) would willingly cooperate with them and not just
               | find a scapegoat to push under the bus? And just repeat
               | this process every time something bad happens.
               | 
               | The point of the fine is to disincentive the company (and
               | also other companies) from doing the same thing again,
               | unless criminal behavior (i.e. fraud) was involved that's
               | purely an internal matter for the company (they may fire
               | the people who supposedly did this or do whatever they
               | think is necessary).
        
               | nickff wrote:
               | If the SEC or DoJ can't figure out who's done something
               | wrong, they should probably refrain from any prosecution.
               | I am not sure what the 'point of the fine' is, but it
               | seems like most companies just treat it as a cost of
               | doing business, that they pay before moving on with
               | whatever they were doing.
               | 
               | If you think it's difficult to figure out who did what
               | wrong, and that the companies are just scapegoating
               | people, then the SEC implementing fines that cause the
               | company to fire people is likely causing unjust firings.
        
           | credit_guy wrote:
           | That's not entirely true. A fine from a regulator, no matter
           | how small, contains the threat that a much bigger punishment
           | will come if you are a repeat offender. That includes trading
           | suspensions:
           | 
           | https://www.sec.gov/files/tradingsuspensions.pdf
           | 
           | https://www.sec.gov/litigation/suspensions.htm
        
           | dsr_ wrote:
           | The fine should be proportionate to the severity of the
           | offense and the magnitude of the misbegotten gains.
           | 
           | In this case, the severity was fairly low: they didn't lie
           | about what they were selling or how much they were selling,
           | but they did purposefully omit some material information
           | about their customers. If you were convinced that
           | cryptocurrency is the future, then NVidia not mentioning
           | cryptominers should have reduced your forecast of their
           | earnings. If you were convinced that cryptocurrency will die
           | any day now, then NVidia's omission should have increased
           | your forecast for them.
           | 
           | But how much money did people lose? It's hard to say. This
           | should be enough money that NVidia's investor relations
           | people make sure not to do it again, but not so much money
           | that NVidia can't recover.
           | 
           | In a hypothetical where NVidia told lies in order to
           | manipulate its stock price, a much much larger fine should be
           | levied.
        
         | mgh2 wrote:
         | What about AMD?
        
           | ineedasername wrote:
           | AMD properly noted potential volatility due to cryptocurrency
           | mining their SEC filings. [1]
           | 
           |  _> The demand for our products depends in part on the market
           | conditions in the industries into which they are sold.... for
           | example, our GPU revenue has been affected in part by the
           | volatility of the cryptocurrency mining market...If we are
           | unable to manage the risks related to the volatility of the
           | cryptocurrency mining market, our GPU business could be
           | materially adversely affected._
           | 
           | That's from their most recent one, but similar statements are
           | in prior ones as well.
           | 
           | [1] https://ir.amd.com/sec-filings/filter/quarterly-
           | filings/cont...
        
             | paulmd wrote:
             | NVIDIA noted it too. This is about their earnings calls
             | where they gave estimates of the _magnitude_ of the crypto
             | sales, and did what I consider (and really, most people who
             | looked at it seriously) to be a massive massive undercount,
             | by a factor of like 3-10x.
             | 
             | AMD was underselling it too though (in 2017-2018 it was a
             | huge factor, not so much this time) and they had a huge
             | inventory overhang lasting years as well... ctrl-f
             | "inventory" in their late-2018/early-2019 earnings call
             | transcripts.
             | 
             | https://www.fool.com/earnings/call-
             | transcripts/2019/01/30/ad...
        
               | ineedasername wrote:
               | It is not about the earnings call. The SEC notice
               | specifically cites 10-Q filings in 2018 as the reason for
               | their action. Earning calls may have been deficient as
               | well, but it's their filings that got them in trouble.
               | 
               | Earnings calls are not intended to be anywhere near as
               | comprehensive as a Q-10 filing. They will typically last
               | a shorter time that it would take to merely read the Q-10
               | itself. Further, earnings calls are not a legally
               | mandated requirement, some companies may not have them at
               | all. This makes them less susceptible to SEC scrutiny.
               | 
               | As for AMD, they were making similar comments to what I
               | quoted above in their 2018 filings, NVidia was not. AMD
               | downplayed it a bit in an informal non-regulated setting
               | but gave better information in the 10-Q does. For
               | NVidia's 10-Q, it was barely a mention that some earnings
               | were impacted crypto, and they did not (per the SEC & a
               | quick read through of their 2018 10-Q's) sufficiently
               | note that it's gaming _growth_ was still driven to a
               | material extent by crypto, thereby exposing them to even
               | more downside risk than what had already occured.
        
           | TedDoesntTalk wrote:
           | AMD may have disclosed it in their financial statements.
        
           | KennyBlanken wrote:
           | Did AMD attribute sales to growth in gaming, not crypto?
        
       | pigtailgirl wrote:
       | Section 17(a)(2) and (3) of the Securities Act
       | 
       | "(2)to obtain money or property by means of any untrue statement
       | of a material fact or any omission to state a material fact
       | necessary in order to make the statements made, in light of the
       | circumstances under which they were made, not misleading; or
       | 
       | (3)to engage in any transaction, practice, or course of business
       | which operates or would operate as a fraud or deceit upon the
       | purchaser."
        
       | someguydave wrote:
       | Sounds like a pretext to begin regulating tech like finance.
        
         | duxup wrote:
         | No this is just a run of the mill dorked up quarterly earnings
         | disclosure.
        
         | JackFr wrote:
         | a $5 million fine with no admission of wrongdoing on a company
         | with quarterly revenue > $7 billion? This is barely a wrist
         | slap.
        
           | someguydave wrote:
           | I agree, it seems like a waste of everyone's time, unless the
           | government was executing some nefarious agenda.
        
             | frenchy wrote:
             | > some nefarious agenda
             | 
             | Like requiring that publicly own companies disclose known
             | sources of income?
        
       | KasianFranks wrote:
       | [deleted]
        
         | birracerveza wrote:
         | I'm the first one to complain about "crypto bad" articles, but
         | this is simply related to crypto mining, nothing else. It's
         | sure to attract the crypto detractors crowd to complain about
         | how crypto is destroying the environment, though.
        
           | microtherion wrote:
           | Even an investor who has full faith in the crypto industry
           | might not want to invest in a company deriving significant
           | revenue from selling GPU mining hardware, because if the
           | long-announced switch of Ethereum from proof of work to proof
           | of stake ever happens, that revenue might drop massively, as
           | other chains seem much smaller and/or less lucrative:
           | https://whattomine.com
        
       | tejohnso wrote:
       | > NVIDIA agreed to a cease-and-desist order and to pay a $5.5
       | million penalty.
       | 
       | So roughly 0.02% of last year's revenue. Basically a warning, I
       | guess.
        
         | ergocoder wrote:
         | If anything, Nvidia shouldn't have paid anything.
         | 
         | The wrongdoing here is just so strange and on the fence.
        
         | throwme_123 wrote:
         | Not a major crime though... if any at all.
         | 
         | They sell gaming cards, does not matter what game you play
         | (even the mining coin game).
        
       | jokoon wrote:
       | I wonder if there is a conspiracy of big GPU trying to promote
       | crypto currencies.
       | 
       | Although I wonder if you can absorb the cost of an expensive
       | GPU+power bill by reselling bitcoins, because I'm not sure it's
       | profitable.
        
       | omginternets wrote:
       | I'm intrigued by the fact that the press release focuses on
       | cryptomining, specifically, but also suggests that the issue has
       | to do with fiduciary duty. Would Nvidia have been charged if they
       | had failed to disclose a similar volume of sales to, say,
       | scientific research labs?
       | 
       | In other words, is this about the US's policy towards (foreign?)
       | crypto operations, or is it "just" about nvidia's investors?
        
         | duxup wrote:
         | Legally, yes it would be the same situation. If they were
         | tracking research labs buying product and then got something
         | wrong about it on their disclosure they'd be in the same
         | situation.
         | 
         | Legally it is all about the disclosure.
         | 
         | Conspiracy minded crypto super fans might find it hard to
         | believe but ultimately this is a small slap for a dorked up
         | disclosure that can be easily avoided by Nvidia. The amount of
         | crypto related purchases could be 100% and as long as Nvidia
         | doesn't dork up disclosing that (or even saying what they know
         | accurately) nothing happens here.
        
           | omginternets wrote:
           | Yeah, that was my lay impression as well. The fact that it's
           | crypto seems largely immaterial, except maybe insofar as it's
           | a risky market.
        
       | Barrera wrote:
       | This seems to be the crux of the case, which the document
       | clarifies has been settled:
       | 
       | > In two of its Forms 10-Q for its fiscal year 2018, NVIDIA
       | reported material growth in revenue within its gaming business.
       | NVIDIA had information, however, that this increase in gaming
       | sales was driven in significant part by cryptomining. Despite
       | this, NVIDIA did not disclose in its Forms 10-Q, as it was
       | required to do, these significant earnings and cash flow
       | fluctuations related to a volatile business for investors to
       | ascertain the likelihood that past performance was indicative of
       | future performance. The SEC's order also finds that NVIDIA's
       | omissions of material information about the growth of its gaming
       | business were misleading given that NVIDIA did make statements
       | about how other parts of the company's business were driven by
       | demand for crypto, creating the impression that the company's
       | gaming business was not significantly affected by cryptomining.
       | 
       | Some commenters are asking where the line gets drawn for the
       | responsibility of disclosure. From this document, the SEC is
       | saying that if material risks are known and not disclosed, that's
       | a red line they will take action on.
        
       | bodhiandphysics wrote:
       | Note that this is the announcement of a settlement. Nvidia agrees
       | to pay 5.5 million, agrees to state the risk, and doesn't admit
       | to fault. No one is in serious trouble... nvidia should have
       | indicated the risk, and didn't... (probably because someone in
       | legal fucked up). It's not like investors didn't know this was a
       | risk!
        
         | danuker wrote:
         | > probably because someone in legal fucked up
         | 
         | Isn't there a list containing every risk in the world, that one
         | can paste into the form? Would that suffice?
        
         | drc500free wrote:
         | Exactly. This is a light slap on the wrist for not including a
         | two sentence blurb in the "risk factors" section that no
         | sophisticated investor relies upon. But as a public company,
         | they are supposed to make things clear for unsophisticated
         | investors.
        
           | KennyBlanken wrote:
           | No, it's for attributing the sales to gaming industry growth,
           | not more volatile crypto.
        
           | albertshin wrote:
           | In reality though I wonder how many of the "unsophisticated"
           | investors have even opened a 10-K before investing... Let
           | alone know what it is...
        
       | whywhywhywhy wrote:
       | If running a GPU 100% to mine crypto is a problem, why wouldn't
       | running the same GPU at 100% to simulate a virtual cowboy world
       | not be a problem?
        
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