HASLIM DECL. ISO DEFENDANTS’ OPPOSITION TO PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

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

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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 

MORRISON & FOERSTER LLP

425 Market Street 

San Francisco, California 94105-2482 

Telephone: 415.268.7000 

Facsimile: 415.268.7522 

Attorneys for Defendants 

UBER TECHNOLOGIES, INC., 

OTTOMOTTO LLC, and OTTO TRUCKING LLC 

KAREN L. DUNN (Pro Hac Vice app. pending) 

kdunn@bsfllp.com 

HAMISH P.M. HUME (Pro Hac Vice app. pending) 

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 JAMES 

HASLIM IN SUPPORT OF 

DEFENDANTS’ OPPOSITION TO 

PLAINTIFF WAYMO LLC’S 

MOTION FOR PRELIMINARY 

INJUNCTION 

Date: May 3, 2017 

Time: 7:30 a.m. 

Ctrm: 8, 19th Floor 

Judge: The Honorable William Alsup 

Trial Date: October 2, 2017

REDACTED VERSION OF DOCUMENT SUBMITTED UNDER SEAL 

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HASLIM DECL. ISO DEFENDANTS’ OPPOSITION TO PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

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I, James Haslim, declare as follows: 

1. I am a Senior Manager, Engineering for the Advanced Technologies Group at 

Uber Technologies, Inc. (“Uber”) as of January 2017. I understand that Waymo has filed a 

lawsuit against Uber, Ottomotto LLC (“Otto”) and Otto Trucking LLC in the U.S. District Court 

for the Northern District of California. I submit this declaration in support of Defendants’ 

Opposition to Waymo LLC’s (“Waymo”) Motion for Preliminary Injunction. I have personal 

knowledge of the facts set forth in this declaration and, if called to testify as a witness, could and 

would do so competently. 

2. I joined Otto in May 2016 as Senior Mechanical Engineer and LiDAR lead, after 

Otto completed its acquisition of Tyto LIDAR LLC (“Tyto”). I was tasked with leading the team 

at Otto in developing a light detecting and ranging (LiDAR) solution for autonomous trucks. 

Uber acquired Otto in August 2016, and since that time, I have been responsible for the technical 

development of Uber’s LiDAR sensors. 

3. I have never worked for Google or Waymo. I have worked on LiDAR technology 

since May 2008. Prior to joining Otto, I was the Director of Engineering and co-founding 

member at Tyto from September 2012 to May 2016, when Tyto was acquired by Otto. Tyto 

specialized in designing and building LiDAR sensors for 3-D mapping. Prior to Tyto, I worked 

on developing LiDAR sensors at Velodyne Acoustics, Inc. (“Velodyne”) from May 2008 to 

August 2012. Before working at Velodyne, I was a senior staff mechanical engineer at KLATencor Corp., where I worked for over 12 years. I received my Bachelor of Science in 

mechanical engineering from the University of California, Berkeley in 1994. 

4. I have never knowingly used any confidential or trade secret documents or 

information from Google or Waymo for the design or development of Otto’s or Uber’s LiDAR 

technologies. I was never directed by anyone at Uber to use any confidential Google or Waymo 

documents for the design or development of Otto’s or Uber’s LiDAR technologies. I have never 

seen any evidence of any confidential Google or Waymo documents or files being used during 

my employment at Otto and Uber. 

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Fuji Design

5. In late October 2016, my team started developing an in-house LiDAR solution that 

we code-named “Fuji” after Mount Fuji. During that time, I met with Scott Boehmke and Eric 

Meyhofer at Uber’s Advanced Technologies Center in Pittsburgh, Pennsylvania. I understand 

that Scott and Eric had joined Uber in early 2015 along with approximately forty researchers, 

academics, and engineers from Carnegie Mellon University, Carnegie Robotics LLC, and the 

National Robotics Engineering Center (NREC). It is also my understanding that this is when 

Uber first began work on self-driving vehicles. 

6. After in-person discussions, we decided that my team should build an in-house 

LiDAR solution using direct diode projections (i.e., laser diodes) with beam spacing and angles 

provided by Scott Boehmke. I understand that Scott developed the beam spacing and angles 

based on parameters and calculations similar to those he provided to , prior to Uber’s 

acquisition of Otto. I was in charge of overseeing the LiDAR design based on the beam spacing 

and angles that Scott Boehmke, in Uber’s Pittsburgh office, provided. 

7. Figure 1, below, is a true and correct photo of Fuji as of March 2017. Fuji has two 

optical cavities, each with 32 channels oriented at different vertical angles to capture the field of 

view necessary for applications in self-driving vehicles. Each cavity has separate receive and 

transmit lenses. The cavity on the left (which I will refer to as the “medium-range cavity”) is 

tilted downwards in order to see the ground and any obstacles immediately 

in front of a vehicle. The cavity on the right (which I will refer to as the “long-range cavity”) 

, allowing it to see obstacles up to the full detection range. 

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8. We decided to use two cavities in the Fuji design primarily because I wanted to 

use simple collimation lenses (i.e., the transmit lenses) for the optical transmit paths. A simple 

transmit lens design does not perform well when light passes through the lens at a steep angle 

relative to the axis through the center of the lens. To minimize interference within a cavity, the 

laser diodes are configured to fire one at a time. By using two cavities with 32 channels each, 

Fuji can fire two laser diodes simultaneously, with the diodes well separated vertically to 

minimize interference between the laser diodes. 

9. Figures 2A and 2B, below, are true and correct annotated CAD drawings of a 

cross-sectional top view of a single optical cavity within Fuji. The “medium-range cavity” and 

“long-range cavity” use the same mechanical components and lenses. Figure 2A, below, shows a 

line drawing of one of the optical cavities, and Figure 2B, below, shows a colored version of one 

of the optical cavities, including the light paths (i.e., the red and blue regions). As evident from 

the CAD drawings, each cavity comprises two separate compartments—a narrower compartment 

for the transmit path and a wider compartment for the receive path. Annotated below is a metal 

separation that optically separates the transmit path and the receive path, so that within each 

cavity the transmit path and the receive path do not overlap. This metal separation prevents 

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interference between the emitted light and the target-reflected light within the receive 

compartment. Care is taken to ensure that the light emitted from the transmit path does not enter 

the receive path until after it exits the transmit lens and is reflected from a target. Moreover, the 

transmit path has a separate lens from the receive path. The narrower lens is for the transmit path, 

and the wider lens is for the receive path. In designing the lens for the transmit path, there is no 

benefit to making the transmit lens significantly larger than the footprint of the light projected by 

the laser diodes. For the receive lens, a larger receive lens is desirable to capture more of the 

target-reflected light, thus improving the sensor’s ability to detect and range darker objects at 

farther distances. 

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10. Each cavity in Fuji has 32 channels, and each channel represents light from a 

single laser diode. Fuji uses laser diodes, which emit light with a 

wavelength of approximately 905 nm. A laser diode such as the has a 

large divergence angle in one direction (i.e., in the fast axis, as shown in Figure 3 below1). As a 

result, depending on its distance from the main collimation lens (e.g., a transmit lens), the light 

emitted by the diode may spread too much before it reaches the main collimation lens. Thus, as 

well known in the art, the laser diode cannot be efficiently used unless it is pre-collimated with a 

fast axis collimating (“FAC”) lens that focuses and redirects the light towards the transmit lens.2 

Figure 3 

11. The 32 laser diodes in each cavity are distributed across 

. I came up with the idea of distributing the 32 laser diodes across 

 through an iterative approach. 

. Exhibit A attached hereto is a true and accurate copy of an email 

exchange I had with Scott Boehmke on October 28, 2016 (discussing potentially 

 and separate lenses for transmit and receive). We ultimately decided to use 

 because distributing 32 laser diodes on allowed for a 

minimum of spacing between adjacent laser diodes, which we determined provided 

 

1

 See Hamamatsu, FAC Lens (Fast-Axis Collimating Lens) J10919 Series, available at 

https://www.hamamatsu.com/resources/pdf/etd/J10919_TOTH1005E.pdf. 2 See id.

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sufficient space for the firing circuit and the FAC lens. We further decided to put 

. 

12. The transmit PCBs within the transmit compartment are arranged with their edges 

facing the transmit lens because diodes are edge-emitting laser diodes, i.e., 

light is emitted from an edge, such as seen above in Figure 3. The within a 

transmit block are mounted onto the transmit block using 

. The spacing between the is constrained by the 

spacing between the columns of detectors on the receive board, because the spacing on the 

detectors is more restrictive due to the need to fit 32 detectors and circuity on a single receive 

board. 

13. Figure 4, below, is a true and correct annotated CAD drawing of a cross-sectional 

top view of the Fuji design. In the “long-range cavity” (which is the cavity on the left), the 32 

diodes are distributed as follows: 

. In the “medium range cavity” (which is the cavity on the right), the 32 laser diodes are 

distributed as follows: . 

In other words, the order of the boards from left to right, across the two cavities, is as follows: 

: 

 

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14. There are two fiducials on each transmit PCB. Fiducials are small reference marks 

that are printed on a PCB for automated alignment. Uber uses the fiducials to position the 

individual laser diodes on a PCB, where the bottom fiducial represents the origin of an x-y 

coordinate system, and the upper fiducial is used to indicate the orientation of the x-y coordinate 

system. This is a common and well-known technique in the fabrication of a PCB for precise 

positioning of components.3

 There are also 

 

3 See, e.g., Optimum Design Associates, Are Local Fiducials Necessary?, 

http://blog.optimumdesign.com/are-local-fiducials-necessary; Worthington Assembly, Working 

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. This is a common technique for aligning 

mechanical components based on my experience as a mechanical engineer.4 Figures 5A and 5B, 

below, illustrate a transmit PCB A. Figure 5A is a true and correct CAD drawing of a transmit 

PCB A. Figure 5B is a true and correct photo of a transmit PCB A. In Figure 5B, I have circled 

in green the fiducials on the PCB. 

15. Figures 6A-F, below, show true and correct CAD drawings of transmit PCBs A-C 

in the “medium-range cavity” and transmit PCBs D-F in the “long-range cavity.” Exhibit B 

attached hereto is a true and correct copy of the specific position and orientation of each diode on 

transmit PCBs A-F. Transmit PCBs A-C in the “medium-range cavity” have a field of view 

(FOV) from , for a total FOV of . Transmit PCBs DF in the “long-range cavity” have a FOV from , for a total field of 

 

with a Manufacturer – What are Fiducials and why are they Useful? (Apr. 17, 2015), 

https://www.worthingtonassembly.com/blog/2014/12/29/what-are-fiducials-and-why-are-theyuseful. 

4 See, e.g., MiSUMi USA, Principles of Positioning, https://us.misumiec.com/maker/misumi/mech/tech/locating_pins_tutorial/. 

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view of . Because the “long-range cavity” and is intended to see 

obstacles up to the full detection range, the laser diodes are tightly positioned on transmit PCBs 

D-F such that there is uniform angular spacing between laser diodes of approximately 0.39 

degrees. 

16. The firing of a light pulse from each laser diode in Fuji is controlled using a laser 

diode firing circuit. Exhibits C and D attached hereto illustrate ten laser firing circuit designs 

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considered for Fuji. None of the circuit designs includes the use of an inductor, which 

complicates the circuitry and takes up more space on the PCB. 

17. Each cavity also includes a filter and in the receive 

compartment. The filter blocks out light in the receive path that is not near 905 nm (i.e., the 

wavelength of the emitted light), effectively preventing noise, such as sunlight, from reaching the 

detectors. a flat receive PCB. 

Figure 8 is a true and correct annotated CAD drawing of a cross-sectional top view of a single 

optical cavity within Fuji, showing the filter and 

 the flat receive PCB. 

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18. The position and orientation of the laser diodes in Fuji is based on the beam 

patterns and parameters provided by Scott Boehmke and his team in Pittsburgh, Pennsylvania. 

Exhibit E attached hereto is a true and correct copy of the custom beam spacing and angle 

summary Scott provided on November 4, 2016, which includes the required beam angles for a 64 

channel LiDAR with two cavities, on a vehicle traveling at 30 mph, 35 mph, 40 mph, and 45 

mph. The current Fuji design is based on the beam angles for a vehicle traveling up to 

approximately 35mph. My team imported the data in this summary into Zemax (ray tracing 

simulation) software to determine the resultant emitting points of the laser diodes. This data was 

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then exported into SolidWorks CAD software as the basis for the initial optical cavity designs and 

transmit PCB designs. 

19. Anthony Levandowski has never had, nor currently has, any design input in the 

number of boards, number of cavities, number of channels, beam parameters, or location and 

orientation of the laser diodes on the transmit PCBs. Nor have I ever seen any of the 14,000 

documents allegedly downloaded by Anthony, or used any such documents in designing the Fuji 

LiDAR. 

Fuji Development Timeline and Efforts

20. There are approximately employees currently working on the Fuji project. 

Since November 1, 2016, the first full month of Uber’s work on Fuji, until March 31, 2016, Uber 

has spent many thousands of hours on developing Fuji. 

21. To date, no Fuji sensor has ever been mounted on any vehicle for testing or any 

other purpose. All Uber cars currently on the road, for commercial use, testing, or any other 

purpose, use third-party sensors. 

22. Uber will not be ready to deploy any public vehicles with Fuji sensors for selfdriving purposes prior to . In other words, Uber will not 

be ready to “commercialize” or “launch” any vehicles using the Fuji sensor for self-driving 

purposes prior to that time. 

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

true and correct. Executed this on 7th day of April, 2017, in San Francisco, California. 

 /s/ James Haslim 

James Haslim 

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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 James Haslim has 

concurred in this filing. 

Dated: April 7, 2017 /s/ Arturo J. González 

Arturo J. González 

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