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GOODMAN DECL. ISO PLAINTIFF WAYMO’S ADMINISTRATIVE MOTION TO FILE UNDER SEAL ITS 

RENEWED MOTION IN LIMINE NO. 1 (DKT. 1561) 

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

MICHAEL A. JACOBS (CA SBN 111664)

MJacobs@mofo.com 

ARTURO J. GONZÁLEZ (CA SBN 121490) 

AGonzalez@mofo.com 

MORRISON & FOERSTER LLP

425 Market Street 

San Francisco, California 94105-2482 

Tel: 415.268.7000 / Fax: 415.268.7522 

KAREN L. DUNN (Pro Hac Vice) 

kdunn@bsfllp.com 

HAMISH P. M. HUME 

hhume@bsfllp.com 

BOIES SCHILLER FLEXNER LLP 

1401 New York Avenue, N.W. 

Washington, D.C. 20005 

Tel: 202.237.2727 / Fax: 202.237.6131 

WILLIAM CARMODY (Pro Hac Vice) 

bcarmody@susmangodfrey.com 

SUSMAN GODFREY LLP 

1301 Avenue of the Americas, 32nd Floor 

New York, NY 10019-6023 

Tel.: 212.336.8330 / Fax.: 212.336.8340 

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 MARTHA GOODMAN 

IN SUPPORT OF PLAINTIFF WAYMO’S 

ADMINISTRATIVE MOTION TO FILE 

UNDER SEAL ITS RENEWED MOTION IN 

LIMINE NO. 1 (DKT. 1561) 

Judge: Hon. William H. Alsup 

Trial Date: October 10, 2017 

Case 3:17-cv-00939-WHA Document 1666 Filed 09/18/17 Page 1 of 3
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 1 

GOODMAN DECL. ISO PLAINTIFF WAYMO’S ADMINISTRATIVE MOTION TO FILE UNDER SEAL ITS 

RENEWED MOTION IN LIMINE NO. 1 (DKT. 1561) 

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

I, Martha L. Goodman, declare as follows:

1. I am an associate at the law firm Boies Schiller Flexner LLP representing Defendants 

Uber Technologies Inc. and Ottomotto LLC (collectively, “Uber”) in this matter. I am a member in 

good standing of the Bar of the District of Columbia. I make this declaration in support of Plaintiff’s 

Administrative Motion to File Under Seal Its Motion in Limine No. 17 (Dkt. 1561). I make this 

declaration based on personal knowledge and if called as a witness, I could and would competently 

testify to the matters set forth herein. 

2. I have reviewed the following documents and confirm that only the portions identified 

below merit sealing: 

Document Portions to Be Filed Under Seal

Waymo’s Renewed Motion in Limine No. 1 Red-outline box 

Exhibit A to the Nardinelli Declaration ISO 

Waymo’s Renewed Motion in Limine No. 1 Red-outline box 

Exhibit B to the Nardinelli Declaration ISO 

Waymo’s Renewed Motion in Limine No. 1 Red-outline box 

Exhibit G to the Nardinelli Declaration ISO 

Waymo’s Renewed Motion in Limine No. 1 Red-outline box 

Exhibit 28 to the Goodman Declaration ISO 

Defendants’ Opposition to Waymo’s Renewed 

Motion in Limine No. 1 

Red-outline box 

Exhibit 35 to the Goodman Declaration ISO 

Defendants’ Opposition to Waymo’s Renewed 

Motion in Limine No. 1 

Red-outline box 

Exhibit 36 to the Goodman Declaration ISO 

Defendants’ Opposition to Waymo’s Renewed 

Motion in Limine No. 1 

Red-outline box 

Exhibit 38 to the Goodman Declaration ISO 

Defendants’ Opposition to Waymo’s Renewed 

Motion in Limine No. 1 

Red-outline box 

3. The red-outlined boxed portions of Exhibit B to the Nardinelli declaration contains 

confidential or highly confidential information regarding Uber’s LiDAR development. This information 

is not publicly known, and its confidentiality is strictly maintained. Disclosure of this information could 

allow competitors to obtain a competitive advantage over Uber by giving them details into Uber’s 

internal development of LiDAR and plans for further development, which would allow competitors to 

Case 3:17-cv-00939-WHA Document 1666 Filed 09/18/17 Page 2 of 3
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GOODMAN DECL. ISO PLAINTIFF WAYMO’S ADMINISTRATIVE MOTION TO FILE UNDER SEAL ITS 

RENEWED MOTION IN LIMINE NO. 1 (DKT. 1561) 

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

understand Uber’s LiDAR development, and allow them to tailor their own strategy. If such 

information were made public, Uber’s competitive standing could be significantly harmed. Other redoutlined boxed portions of Exhibit B to the Nardinelli declaration contain Uber employee names, the 

disclosure of which would threaten the privacy of individuals at a company that is currently the subject 

of extensive media coverage 

4. The red-outlined boxed portions of Waymo’s Renewed MIL No. 1, Exhibits A and G to 

the Nardinelli declaration and the red-outlined boxed portions of Exhibits 28, 35, 36, and 38 to the 

Goodman declaration contain Uber employee names and confidential email addresses and contact 

information, the disclosure of which would threaten the privacy of individuals at a company that is 

currently the subject of extensive media coverage. 

5. Defendants’ request to seal is narrowly tailored to those portions of Waymo’s Renewed 

MIL No. 1, and Exhibits A, B, G, 28, 35, 36, and 38 that merit sealing. 

6. Pursuant to Civil Local Rule 79-5(d)(2), Uber will lodge with the Clerk the highlighted 

versions documents at issue, with accompanying chamber copies. 

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

and correct. Executed this 18th day of September, 2017, in Washington, DC. 

ATTESTATION OF E-FILED SIGNATURE 

I, Karen L. Dunn, 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 Martha L. Goodman has 

concurred in this filing. 

/s/ Martha L. Goodman

 Martha L. Goodman 

/s/ Karen L. Dunn 

 Karen L. Dunn 

Case 3:17-cv-00939-WHA Document 1666 Filed 09/18/17 Page 3 of 3