CHANG DECL. ISO DEFENDANTS’ ADMINISTRATIVE MOTION TO FILE UNDER SEAL

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

sf-3763320 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

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) 

kdunn@bsfllp.com 

HAMISH P.M. HUME (Pro Hac Vice) 

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 ESTHER KIM 

CHANG IN SUPPORT OF 

DEFENDANTS’ ADMINISTRATIVE 

MOTION TO FILE UNDER SEAL 

Trial Date: October 2, 2017 

Case 3:17-cv-00939-WHA Document 280-1 Filed 04/26/17 Page 1 of 2
CHANG DECL. ISO DEFENDANTS’ ADMINISTRATIVE MOTION TO FILE UNDER SEAL

Case No. 3:17-cv-00939-WHA 1

sf-3763320 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

I, Esther Kim Chang, declare as follows: 

1. I am an attorney at the law firm of Morrison & Foerster LLP. I am a member in 

good standing of the Bar of the State of California. I make this declaration based upon matters 

within my own personal knowledge and if called as a witness, I could and would competently 

testify to the matters set forth herein. I make this declaration in support of Defendants’ 

Administrative Motion to File Under Seal Portions of Defendants’ April 24, 2017 Letter Brief to 

Magistrate Judge Corley (“Defendants’ Letter Brief”) and certain Exhibits thereto. 

2. The redacted portions of Defendants’ Letter Brief, the redacted portions of 

Exhibits A and C to Defendants’ Letter Brief, and the entirety of Exhibit B to Defendants’ Letter 

Brief contain information that Plaintiff Waymo LLC has designated as “Confidential” or “Highly 

Confidential – Attorneys’ Eyes Only” in accordance with the Patent Local Rule 2-2 Interim 

Model Protective Order (“Protective Order”), which the parties have agreed govern this case 

(Transcript of 3/16/2017 Hearing, page 6). 

3. Defendants are required to file this material under seal in accordance with 

Paragraph 14.4 of the Protective Order. 

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

true and correct. Executed this 26th day of April, 2017, in San Francisco, California. 

 /s/ Esther Kim Chang 

Esther Kim Chang 

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 Esther Kim Chang 

has concurred in this filing. 

Dated: April 26, 2017 /s/ Arturo J. González 

Arturo J. González 

Case 3:17-cv-00939-WHA Document 280-1 Filed 04/26/17 Page 2 of 2