YANG DECLARATION ISO WAYMO’S ADMINISTRATIVE MOTION TO FILE UNDER SEAL

Case No. 3:17-cv-00939-WHA 

sf-3814471 

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MICHAEL A. JACOBS (CA SBN 111664)

MJacobs@mofo.com 

ARTURO J. GONZÁLEZ (CA SBN 121490) 

AGonzalez@mofo.com 

ERIC A. TATE (CA SBN 178719) 

ETate@mofo.com 

RUDY Y. KIM (CA SBN 199426) 

RKim@mofo.com 

MORRISON & FOERSTER LLP

425 Market Street 

San Francisco, California 94105-2482 

Telephone: 415.268.7000 

Facsimile: 415.268.7522 

KAREN L. DUNN (Pro Hac Vice) 

kdunn@bsfllp.com 

HAMISH P.M. HUME (Pro Hac Vice) 

hhume@bsfllp.com 

BOIES SCHILLER FLEXNER LLP 

1401 New York Avenue, N.W. 

Washington DC 20005 

Telephone: 202.237.2727 

Facsimile: 202.237.6131 

Attorneys for Defendants 

UBER TECHNOLOGIES, INC. 

and OTTOMOTTO LLC 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

WAYMO LLC, 

Plaintiff, 

v. 

UBER TECHNOLOGIES, INC., 

OTTOMOTTO LLC; OTTO TRUCKING LLC, 

Defendants. 

Case No. 3:17-cv-00939-WHA

DECLARATION OF MICHELLE 

YANG IN SUPPORT OF 

PLAINTIFF’S ADMINISTRATIVE 

MOTION TO FILE UNDER SEAL 

ITS OPPOSITION TO UBER’S 

MOTION TO COMPEL 

INTERROGATORIES (DKT. 1143) 

Trial Date: October 10, 2017

Case 3:17-cv-00939-WHA Document 1195 Filed 08/14/17 Page 1 of 3
YANG DECLARATION ISO WAYMO’S ADMINISTRATIVE MOTION TO FILE UNDER SEAL

Case No. 3:17-cv-00939-WHA 1

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I, Michelle Yang, declare as follows: 

1. I am an attorney at the law firm of Morrison & Foerster LLP. I make this

declaration based upon matters within my own personal knowledge and if called as a witness, I 

could and would competently testify to the matters set forth herein. I make this declaration in 

support of Plaintiff’s Administrative Motion to File Under Seal Its Opposition to Uber’s Motion 

to Compel Interrogatories (Dkt. 1143). 

2. I have reviewed the following documents and confirmed that only the portions

identified below merit sealing: 

Document Portions to Be Filed Under Seal 

Exhibit 3 Marked portions (in red boxes) 

3. The marked portions (in red boxes) of Exhibit 3 contain highly confidential

information regarding the details of acquisition and employment agreements for companies and 

individuals with which Defendants have ongoing relationships, including the specific financial 

terms of these agreements. This highly confidential information is not publicly known, and its 

confidentiality is strictly maintained. I understand that disclosure of this information would allow 

competitors to gain insight into how Uber negotiates and structures its business agreements, 

which would allow competitors to tailor their own business strategy. Uber’s competitive standing 

could be harmed. 

4. The marked portions (in red boxes) of Exhibit 3 also contain highly confidential

information regarding Defendants’ employment strategy, including in relation to people currently 

employed by Uber. This highly confidential information is not publicly known, and its 

confidentiality is strictly maintained. I understand that disclosure of this information would allow 

competitors to gain insight into how Uber approaches its employment negotiations and 

employment philosophy, which would allow competitors to tailor their own employment strategy. 

Uber’s competitive standing could be harmed. 

5. Defendants’ request to seal is narrowly tailored to those portions of Plaintiff’s

Opposition and its supporting exhibits that merit sealing. 

Case 3:17-cv-00939-WHA Document 1195 Filed 08/14/17 Page 2 of 3
YANG DECLARATION ISO WAYMO’S ADMINISTRATIVE MOTION TO FILE UNDER SEAL

Case No. 3:17-cv-00939-WHA 2

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I declare under penalty of perjury under the laws of the United States that the foregoing 

is true and correct. Executed this 14th day of August, 2017, at Los Angeles, California. 

/s/ Michelle Yang 

Michelle Yang 

ATTESTATION OF E-FILED SIGNATURE 

I, Arturo J. González, am the ECF User whose ID and password are being used to file this 

Declaration. In compliance with General Order 45, X.B., I hereby attest that Michelle Yang has 

concurred in this filing. 

Dated: August 14, 2017 /s/ Arturo J. González 

Arturo J. González 

Case 3:17-cv-00939-WHA Document 1195 Filed 08/14/17 Page 3 of 3