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Case No.3:17-cv-00939 

DECLARATION OF TIM WILLIS

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION

WAYMO LLC,

Plaintiff,

vs.

UBER TECHNOLOGIES, INC.; 

OTTOMOTTO LLC; OTTO TRUCKING 

LLC,

Defendants.

CASE NO. 3:17-cv-00939

DECLARATION OF TIM WILLIS

REDACTED VERSION OF DOCUMENT 

SOUGHT TO BE SEALED

Case 3:17-cv-00939-WHA Document 24-16 Filed 03/10/17 Page 1 of 5
I, Tim Willis, hereby declare as follows. 

1. I have been employed by Waymo LLC ("Waymo") and before that Google Inc. 

("Google") (collectively referred to herein as "Waymo") since August 2015. I currently hold the 

position of Director of Supply Chain Operations at Waymo. I make this declaration in support of 

Waymo's Motion for a Preliminary Injunction and have personal knowledge of the facts stated 

herein. 

2. I received a Bachelor's Degree in Electrical Engineering from Kettering University, 

and a Master's Degree in Engineering / Manufacturing Systems Engineering from Stanford 

University. 

3. In my role as Director of Supply Chain Operations, I am responsible for all aspects 

of Waymo's supply chain for components of self-driving sensors and vehicles, including supplier 

selection, supplier negotiations, supplier readiness, and supplier capacity. My responsibilities 

include oversight of supplier selection, supplier negotiation, supplier readiness, and supplier 

capacity for Waymo's LiDAR sensors. 

Waymo's Reasonable Measures to Protect Confidential and Proprietary Information 

Shared with Suppliers 

4. I am familiar with the security measures taken by Waymo to protect the 

confidentiality of information shared with Waymo's vendors, suppliers, and manufacturers. 

Waymo takes reasonable measures to mark its confidential and proprietary information, such as 

documents and other materials, with visible legends designating them as such. Waymo's policies, 

which are diligently followed, require that all consultants, vendors, suppliers, and manufacturers 

sign confidentiality agreements that require that they undertake reasonable efforts to maintain, and 

not to disclose, any Waymo confidential and proprietary trade secret information they receive. For 

example, Waymo's policies, which are diligently followed, require that each consultant, vendor, 

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DECLARATION OF TIM WILLIS 

Case 3:17-cv-00939-WHA Document 24-16 Filed 03/10/17 Page 2 of 5
supplier, or manufacturer that has received Waymo's LiDAR confidential and proprietary trade 

secret information has executed at least one written non-disclosure agreement. 

5. An example of a Waymo non-disclosure agreement with a third party supplier is 

Waymo's August 10, 2015 "Inbound Services Agreement" with a true and correct 

copy of which is attached hereto as Exhibit A. Section 6 is entitled "Confidentiality; Publicity: 

Privacy and Security": 

Sameer Kshirsagar 

6. Sameer Kshirsagar was one of my direct reports from the time I joined Waymo in 

August 2015 until his resignation in July 2016. His title was Global Supply Manager. In that role, 

his responsibilities included contractual negotiations with suppliers of Waymo's LiDAR hardware 

components. 

7. I understand that in June and July 2016, before his resignation from Waymo, 

Sameer Kshirsagar exported from Google Drive the following files: 

• Laser questions 

• Ramp Checklist

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DECLARATION OF TIM WILLIS 

Case 3:17-cv-00939-WHA Document 24-16 Filed 03/10/17 Page 3 of 5
• and Packaging 

• Lens Placement-01 

• All things Part 3- mode

True and correct copies of these files are attached hereto as Exhibits B-F. 

8. In my role as Director of Supply Chain Operations, I am familiar with these 

documents, which contain proprietary and highly confidential Waymo supply chain information. 

Radu Radutu 

9. Radu Radutu was a manufacturing engineer in Waymo's LiDAR department who 

resigned from Waymo in July 2016. In his capacity as a manufacturing engineer for the LiDAR 

team, Mr. Radutu participated in development meetings with the Global Supply team involving 

Waymo's suppliers of LiDAR components. Mr. Radutu also worked with a specific Waymo 

supplier regarding a

10. I understand that in July 2016, before his resignation from Waymo, Mr. Raduta 

exported from Google Drive the following files: 

• Die-wire bonding houses 

• External Vendors and Consultants List 

• automation vendors

True and correct copies of these files are attached as Exhibits G-I. 

11. In my role as Director of Supply Chain Operations, I am familiar with these 

documents, which contain proprietary and highly confidential Waymo supply chain information. 

I declare under penalty of perjury that the foregoing is true and correct. Executed in 

Mountain View, California, on March 9, 2017. 

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DECLARATION OF TIM WILLIS 

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Case 3:17-cv-00939-WHA Document 24-16 Filed 03/10/17 Page 4 of 5
DATED: March 9, 2017 Ls 

Tim Willis 

-5- Case No.3: I 7-cv-00939 

DECLARATION OF TIM WILLIS 

Case 3:17-cv-00939-WHA Document 24-16 Filed 03/10/17 Page 5 of 5