EXHIBIT A

   

Case 3:17-cv-00939-WHA Document 280-5 Filed 04/26/17 Page 1 of 8
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1 UNITED STATES DISTRICT COURT

2 NORTHERN DISTRICT OF CALIFORNIA

3 SAN FRANCISCO DIVISION

4

 ______________________________

5 WAYMO LLC, )

6 Plaintiff, )

7 vs. ) Case No.

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

9 OTTOMOTTO LLC; OTTO )

10 TRUCKING LLC, )

11 Defendants. )

 ______________________________)

12

13 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY

14

15 VIDEOTAPED DEPOSITION OF DANIEL CHU

16 San Francisco, California

17 Monday, April 3, 2017

18 Volume I

19

20

21 Reported by:

22 SUZANNE F. GUDELJ, CSR No. 5111

23 Job No. 2583707

24

25 PAGES 1 - 53

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1 THE WITNESS: So it's -- it's probably a --

2 a growing -- growing list of folks, but the folks

3 that we'd probably look at most are -- are Uber in

4 terms of their self-driving efforts. We also look

5 at, for instance, Tesla in terms of some of their -- 10:06:20

6 their efforts there.

7 BY MR. GONZALEZ:

8 Q Would you agree that your number one

9 competitor in the market is Uber?

10 MS. BAILY: Object to form. 10:06:28

11 THE WITNESS: I think it depends what

12 you -- 

13

14

15 . 10:06:39

16 BY MR. GONZALEZ:

17 Q All right. Let me focus on -- on your

18 words. I'll use your words.

19 

20 10:06:48

21

22 A Sorry, say again?

23 Q 

24

25 10:06:59

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1 A 

2

3 Q 

4

5 MS. BAILY: Object to form. 10:07:09

6 THE WITNESS: 

7 .

8 BY MR. GONZALEZ:

9 Q Would you agree that it's your number one

10 competitor in that space? 10:07:18

11 MS. BAILY: Object to form.

12 BY MR. GONZALEZ:

13 Q I'm not trying to trap you.

14 A Yeah.

15 Q If somebody else is number one, I want to 10:07:20

16 know, that's all.

17 A Yeah.

18 Q So let me go back.

19 

20 10:07:26

21 MS. BAILY: Same objection.

22 THE WITNESS: 

23

24 BY MR. GONZALEZ:

25 Q And who would you consider to be number 10:07:33

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1 basically my user research team does the surveys.

2 BY MR. GONZALEZ:

3 Q And your research team is to have -- does

4 it have a name?

5 A They -- they basically just called it the 10:08:38

6 user research group, yeah.

7 Q User research group?

8 A Yeah.

9 Q Not Daniel's brigade or anything like that?

10 A No. 10:08:49

11 Q All right. 

12

13

14 A I don't remember the exact date.

15 Q Approximately. 10:08:58

16 A But approximately, we've done probably in

17 the last -- I'm trying to remember -- I mean, last

18 few months, but it's been more focused on the

19 markets that we're interested in, yeah.

20 Q And what markets are those that you were 10:09:13

21 more focused on?

22 

23

24 

25 10:09:24

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1

2 

3

4 

5 10:09:36

6

7

8 

9

10 10:09:53

11 MS. BAILY: Object to form.

12 THE WITNESS: It's -- well, are you talking

13 about litigation in general or like this -- this

14 litigation in specific?

15 BY MR. GONZALEZ: 10:10:08

16 Q Litigation in general.

17 

18

19

20 Q All right. Fair enough. Let's talk about 10:10:20

21 this litigation.

22 A Yeah.

23 

24

25 10:10:27

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1

2 MS. BAILY: Object to form.

3 THE WITNESS: 

4

5 10:10:40

6

7

8 BY MR. GONZALEZ:

9 Q Do you ever have communications with public

10 agencies about your vehicles? 10:10:51

11 A Do --

12 MS. BAILY: Object to form.

13 THE WITNESS: Do I personally or --

14 BY MR. GONZALEZ:

15 Q Yes, you. 10:10:57

16 A Most of my efforts are more internal

17 focused.

18 Q Who at Waymo is the person who communicates

19 with public agencies to try to get approval for you

20 to be able to drive your autonomous vehicles there? 10:11:08

21 A It's probably going to be more of our

22 public policy team and our partnership teams.

23 Q And who are the people who are in charge of

24 those groups?

25 A So -- I'm trying to think. So Kevin Vosen, 10:11:20

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