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CASE NO. 3:17-cv-00939-WHA

JUDAH DECLARATION ISO UBER’S ADMINISTRATIVE MOTION TO SEAL

QUINN EMANUEL URQUHART & SULLIVAN, LLP

 Charles K. Verhoeven (Bar No. 170151)

 charlesverhoeven@quinnemanuel.com

 David A. Perlson (Bar No. 209502)

 davidperlson@quinnemanuel.com

 Melissa Baily (Bar No. 237649)

 melissabaily@quinnemanuel.com

 John Neukom (Bar No. 275887)

 johnneukom@quinnemanuel.com

 Jordan Jaffe (Bar No. 254886)

 jordanjaffe@quinnemanuel.com

50 California Street, 22nd Floor

San Francisco, California 94111-4788

Telephone: (415) 875-6600

Facsimile: (415) 875-6700

Attorneys for WAYMO LLC

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-WHA

DECLARATION OF JAMES JUDAH IN 

SUPPORT OF DEFENDANTS’ 

ADMINISTRATIVE MOTION TO FILE 

UNDER SEAL (DKT. 280)

Case 3:17-cv-00939-WHA Document 316 Filed 04/28/17 Page 1 of 3
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-2- CASE NO. 3:17-cv-00939-WHA

JUDAH DECLARATION ISO UBER’S ADMINISTRATIVE MOTION TO SEAL

I, James Judah, declare as follows: 

1. I am an attorney licensed to practice in the State of California and am admitted to 

practice before this Court. I am an associate at the law firm Quinn Emanuel Urquhart & Sullivan, 

LLP, counsel for the Plaintiff Waymo LLC (“Waymo”). I have personal knowledge of the matters set 

forth in this Declaration, and if called as a witness I would testify competently to those matters. 

2. I submit this declaration in support of Defendants’ Administrative Motion to File 

Under Seal (Dkt. 280) related to its discovery letter brief (the “Administrative Motion”) pursuant to 

Civil Local Rules 79-5(d)(1)(A) and 79-5(e). 

3. I have reviewed the following documents and confirmed that the portions identified 

merits sealing: 

Document Portions to Be Filed Under Seal

Defendants’ April 24, 2017 Letter Brief to 

Magistrate Judge Corley (“Defendants’ Letter 

Brief”)

Redacted Portions

Exhibits A and C to Defendants’ Letter Brief Redacted Portions

Exhibit B to Defendants’ Letter Brief Entire Document

4. The above documents – at the identified portions – contain trade secret and confidential 

business information, which Waymo seeks to seal. 

5. Defendants’ Discovery Letter Brief (redacted portions), Exhibits A and C (redacted 

portions), and Exhibit B contain, reference, or describe Waymo’s highly confidential and sensitive 

business information. Such information includes information on Waymo’s confidential business 

strategy, as well as its competitive and market analysis. I understand that Waymo maintains this 

information as confidential. The public disclosure of this information would cause significant 

competitive harm to Waymo, as its confidential business information and strategy would become 

known to competitors who could use such information to Waymo’s disadvantage. 

6. Waymo’s request to seal is narrowly tailored to those portions of the above-referenced 

documents that merit sealing. 

Case 3:17-cv-00939-WHA Document 316 Filed 04/28/17 Page 2 of 3
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-3- CASE NO. 3:17-cv-00939-WHA

JUDAH DECLARATION ISO UBER’S ADMINISTRATIVE MOTION TO SEAL

I declare under penalty of perjury under the laws of the State of California that the foregoing is 

true and correct, and that this declaration was executed in San Francisco, California, on April 28, 

2017. 

By /s/ James Judah

 James Judah

 Attorneys for WAYMO LLC

Case 3:17-cv-00939-WHA Document 316 Filed 04/28/17 Page 3 of 3