his is a nationwide class action brought on behalf of all consumers who purchased graphics or video card devices incorporating the Nvidia GeForce GTX 970 graphics processing units “GPU” herinafter “GTX 970″ or “GTX 970 devices” which were sold based on the misleading representation that the GTX 970 operates with a full 4GB of VRAM at GDDR5 (not a less performant 3.5GB with a less performant decoupled 0.5GB spillover), 64 ROPs (as opposed to 56 ROPs) and an L2 cache capacity of 2048KB (as opposed to 1792 KB) or omitted material facts to the contrary.