Exhibit 1 

Case 3:17-cv-00939-WHA Document 980-2 Filed 07/21/17 Page 1 of 8
HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

WAYMO LLC, ) 

Plaintiff, ) 

vs. ) Case No. 

UBER TECHNOLOGIES, INC., ) 3:17-cv-00939-WHA 

OTTOMOTTO LLC; OTTO ) 

TRUCKING LLC, ) 

Defendants. ) 

) 

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY 

CONTINUED VIDEOTAPED DEPOSITION OF GAETAN PENNECOT 

San Francisco, California 

Wednesday, June 14, 2017 

Volume II 

Reported by: 

SUZANNE F. GUDELJ, CSR No. 5111 

Job No. 2638084 

PAGES 96 - 274 

Page 96 

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Case 3:17-cv-00939-WHA Document 980-2 Filed 07/21/17 Page 2 of 8
HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

WAYMO LLC, ) 

Plaintiff, ) 

vs. ) Case No. 

UBER TECHNOLOGIES, INC., ) 3:17-cv-00939-WHA 

OTTOMOTTO LLC; OTTO ) 

TRUCKING LLC, ) 

Defendants. ) 

) 

Continued Videotaped Deposition of GAETAN PENNECOT, 

Volume II, taken on behalf of Plaintiff Waymo 

LLC, at the Law Offices of Quinn Emanuel 

Urquhart & Sullivan LLP, 50 California Street, 

22nd Floor, San Francisco, California, 

beginning at 9:13 a.m., and ending at 4:38 p.m. 

a.m., on Wednesday, June 14, 2017, before 

SUZANNE F. GUDELJ, Certified Shorthand Reporter 

No. 5111. 

Page 97 

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Case 3:17-cv-00939-WHA Document 980-2 Filed 07/21/17 Page 3 of 8
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A This is correct. 

Q They're the manufacturer of the FAC lens 

for the Fuji LiDAR, right? 

A This is correct. 

Q At your last deposition we talked about in 02:37:56 

GBR3 how the diodes 

; do you recall that? 

A Yes. 

Q And we -- we talked about how in Fuji the 

diodes ; is that right? 02:38:12 

A This is correct. 

Q Who came up with 

on the Fuji PCBs? 

A I did. 

Q What did you look at to come up with that? 02:38:24 

A It's from a previous experience. 

Q When you say "previous experience," what 

are you referring to? 

A It's my experience in the past at Google. 

Q Talking about your -- the beam angles that 02:38:42 

you got from Mr. Boehmke -- switching topics a 

little bit. 

A Yeah. 

02:38:58 

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Case 3:17-cv-00939-WHA Document 980-2 Filed 07/21/17 Page 4 of 8
HIGHLY CONFIDENTIAL - ATTORNEYS EYES ONLY 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

WAYMO LLC, 

Plaintiff, 

Case 

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

UBER TECHNOLOGIES, INC.; 

OTTOMOTTO LLC; OTTO TRUCKING LLC, 

Defendants. 

/ 

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VIDEOTAPED DEPOSITION OF GAETAN PENNECOT 

VOLUME III (PAGES 275 to 478) 

FRIDAY, JUNE 16, 2017 

Reported by: 

Anrae Wimberley 

CSR No. 7778 

Job No. 2641228 

Page 275 

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Case 3:17-cv-00939-WHA Document 980-2 Filed 07/21/17 Page 5 of 8
HIGHLY CONFIDENTIAL - ATTORNEYS EYES ONLY 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

WAYMO LLC, 

Plaintiff, 

Case 

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

UBER TECHNOLOGIES, INC.; 

OTTOMOTTO LLC; OTTO TRUCKING LLC, 

Defendants. 

/ 

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY 

Transcript of video-recorded deposition 

of GAETAN PENNECOT, taken at Quinn Emanuel 

Urquhart & Sullivan LLP, 50 California Street, 

22nd Floor, San Francisco, California 94111, 

beginning at 10:15 a.m. and ending at 5:25 p.m. on 

Friday, June 16, 2017, before Anrae Wimberley, 

Certified Shorthand Reporter No. 7778. 

Page 276 

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Case 3:17-cv-00939-WHA Document 980-2 Filed 07/21/17 Page 6 of 8
Q. Was a supplier of FAC lenses? 15:53:08 

Q. And so what information did have about 15:53:16 

suggested 

Did you use in connection with your 15:54:20 

Q. And what are 15:54:26 

A. are very common in mechanical 15:54:29 

engineering. 

15:54:39 

Q. What did you use the for in connection 15:54:42 

A. I used the 

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A. "You should do it yourself." 15:53:03 

A. No. 15:53:08 

FAC lenses that they provided to you? 15:53:19 

A. They had like an optical engineer that could 15:53:25 

optimize FAC lens pretty easy. I remember they 15:53:36 

Q. I want to switch to a different topic. 15:54:16 

work on transmit boards for Fuji? 15:54:23 

A. Yes. 15:54:23 

with the Fuji transmit boards? 15:54:45 

Q. Can you explain a little more how you did 15:54:59 

that. 15:55:00 

Page 423 

Case 3:17-cv-00939-WHA Document 980-2 Filed 07/21/17 Page 7 of 8
A. So 15:55:03 

15:55:29 

15:56:05 

15:56:09 

15:56:12 

in connection with transmit boards? 15:56:17 

Q. And how did you use in connection with 15:56:21 

know about how to use in engineering? 15:56:31 

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15:55:08 

Q. While you were at Google, did you also use 15:56:14 

A. Yes. 15:56:17 

transmit boards at Google? 15:56:23 

A. The same way. 15:56:24 

Q. Now, prior to your work at Google, did you 15:56:27 

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15:55:34 

15:55:37 

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15:55:48 

15:55:51 

15:55:56 

15:56:00 

Case 3:17-cv-00939-WHA Document 980-2 Filed 07/21/17 Page 8 of 8