EXHIBIT 10

UNREDACTED VERSION 

OF DOCUMENT 

SOUGHT TO BE SEALED

EXHIBIT 10

Case 3:17-cv-00939-WHA Document 1433-15 Filed 08/31/17 Page 1 of 9
From: 

To: 

Sent: 

Subject: 

Sasha Zbrozek 

"Thomas E. Gorman" <TGorman@kvn.com> 

Thu, 6 Oct 2016 16:01:16 -0700 

Re: connecting w/ outside counsel 

It's hosted on , which itself is . 

On Thu, Oct 6, 2016 at 3:23 PM, Thomas E. Gorman <TGorrnan(mkvn.com> wrote: 

We're trying to trace Al's IP add ress on 12/11/2015 to figure out which computer he was using. 

The security ops team wants to know t he "domain/IP address" for your SVN solution . Could you please provide? 

Thanks, 

--Tom 

From: Sasha Zbrozek [mailto:

Sent: Wednesday, October 05, 2016 5:39 PM 

To: Thomas E. Gorman 

Subject: Re: connecting w/ outside counsel 

At least historically, 

Maybe opinions have changed. 

Sensor designs are a combination of electronics, mechanical components, analysis, and manufacturing information. The 

mechanical parts are stored in 

The logs go back to late September or early October 2015. I haven't checked the specific date. 

On Wed, Oct 5, 2016 at 5: 18 PM, Thomas E. Gorman wrote: 

HIGHLY CONFIDENTIAL-ATTORNEYS' EYES ONLY WAYMO-UBER-00084484 

From: Sasha Zbrozek

To: "Thomas E. Gorman" <TGorman@kvn.com>

Sent: Thu, 6 Oct 2016 16:01:16 -0700

Subject: Re: connecting w/ outside counsel

lt‘s hosted on , which itsclfis .

On Thu, Oct 6, 2016 at 3:23 PM, Thomas E. Gorman <TGorman/a>kvn.com> wrote:

We're trying to trace AL’s lP address on 12/11/2015 to figure out which computer he was using.

The security ops team wants to know the "domain/1P address" for your SVN solution. Could you please provide?

Thanks,

--Tom

From: Sasha Zbrozek [mailto:

Sent: Wednesday, October 05, 2016 5:39 PM

To: Thomas E. German

Subject: Re: connecting w/ outside counsel

At least historically,

Maybe opinions have changed.

Sensor designs are a combination of electronics, mechanical components, analysis, and manufacturing information. The

mechanical parts are stored in

The logs go back to late September or early October 2015. l haven't checked the specific date.

On Wed, Oct 5, 2016 at 5:18 PM, Thomas E. German <TGormang¢£'l<vn.com> wrote:

HIGHLY CON FlDENTlAL - ATTORNEYS’ EYES ONLY WAYMO-UBER-00084484

From: Sasha Zbrozek

To: "Thomas E. Gorman" <TGorman@kvn.com>

Sent: Thu, 6 Oct 2016 16:01:16 -0700

Subject: Re: connecting w/ outside counsel

lt‘s hosted on , which itsclfis .

On Thu, Oct 6, 2016 at 3:23 PM, Thomas E. Gorman <TGorman/a>kvn.com> wrote:

We're trying to trace AL’s lP address on 12/11/2015 to figure out which computer he was using.

The security ops team wants to know the "domain/1P address" for your SVN solution. Could you please provide?

Thanks,

--Tom

From: Sasha Zbrozek [mailto:

Sent: Wednesday, October 05, 2016 5:39 PM

To: Thomas E. German

Subject: Re: connecting w/ outside counsel

At least historically,

Maybe opinions have changed.

Sensor designs are a combination of electronics, mechanical components, analysis, and manufacturing information. The

mechanical parts are stored in

The logs go back to late September or early October 2015. l haven't checked the specific date.

On Wed, Oct 5, 2016 at 5:18 PM, Thomas E. German <TGormang¢£'l<vn.com> wrote:

HIGHLY CON FlDENTlAL - ATTORNEYS’ EYES ONLY WAYMO-UBER-00084484

Case 3:17-cv-00939-WHA Document 1433-15 Filed 08/31/17 Page 2 of 9
How far back do these logs go? I'm trying to figure out whether this is truly out of character based on Al's work pattern, or whethe r we 

only have a short window of logs (and therefore no idea what his normal work pattern was). 

--Tom 

From: Sasha Zbrozek [mailto: ] 

Sent: Wednesday, October 05, 2016 3:42 PM 

To: Thomas E. Gorman 

Subject: Re: connecting w/ outside counsel 

It's all electronics designs - schematics and PCB layouts, and the component library for their creation. 

He was a high-level manager, 

On Wed, Oct 5, 2016 at 2:54 PM, Thomas E. Gorman <TGorman@kvn.com> wrote: 

He only accessed SVN the one time, on 12/11/2015? That's a little strange, isn't it? 

I'm still trying to parse his machine/host history, but I believe he had a windows laptop for only 3 weeks in December 2015. 

What, exactly, is in this SVN system? PCB designs? Something else? Any other hardware designs? 

--Tom 

HIGHLY CONFIDENTIAL-ATTORNEYS' EYES ONLY WAYMO-UBER-00084485 

How far back do these logs go? l’m trying to figure out whether this is truly out of character based on AL’s work pattern, or whether we

only have a short window of logs (and therefore no idea what his normal work pattern was).

-~Tom

From: Sasha Zbrozek [mailto: ]

Sent: Wednesday, October 05, 2016 3:42 PM

To: Thomas E. German

Subject: Re: connecting w/ outside counsel

It's all electronics designs - schematics and PCB layouts, and the component library for their creation.

He was a high-level manager,

On Wed, Oct 5, 2016 at 2:54 PM, Thomas E. German <TGoi"i1iaiigcDkvn.coin> wrote:

He only accessed S\/N the one time, on 12/11/2015? That's a little strange, isn’t it?

l’m still trying to parse his machine/host history, but l believe he had a windows laptop for only 3 weeks in December 2015.

What, exactly, is in this SVN system? PCB designs? Something else? Any other hardware designs?

»»Tom

HIGHLY CON FlDENTlAL - ATTORNEYS’ EYES ONLY WAYMO-UBER-00084485

How far back do these logs go? l’m trying to figure out whether this is truly out of character based on AL’s work pattern, or whether we

only have a short window of logs (and therefore no idea what his normal work pattern was).

-~Tom

From: Sasha Zbrozek [mailto: ]

Sent: Wednesday, October 05, 2016 3:42 PM

To: Thomas E. German

Subject: Re: connecting w/ outside counsel

It's all electronics designs - schematics and PCB layouts, and the component library for their creation.

He was a high-level manager,

On Wed, Oct 5, 2016 at 2:54 PM, Thomas E. German <TGoi"i1iaiigcDkvn.coin> wrote:

He only accessed S\/N the one time, on 12/11/2015? That's a little strange, isn’t it?

l’m still trying to parse his machine/host history, but l believe he had a windows laptop for only 3 weeks in December 2015.

What, exactly, is in this SVN system? PCB designs? Something else? Any other hardware designs?

»»Tom

HIGHLY CON FlDENTlAL - ATTORNEYS’ EYES ONLY WAYMO-UBER-00084485

Case 3:17-cv-00939-WHA Document 1433-15 Filed 08/31/17 Page 3 of 9
From: Sasha Zbrozek ] 

Sent: Wednesday, October 05, 2016 2:44 PM 

To: Thomas E. Gorman 

Subject: Re: connecting w/ outside counsel 

The hostname isn't logged because it isn't part of the protocol. It was a Windows machine, but that's no surprise. Only one 

IP was ever used, which is registered to Google. 

On Wed, Oct 5, 2016 at 2:32 PM, Thomas E. Gorman 

Was Anthony's account sync'd to his Windows laptop? anthonylO-w? 

From: Sasha Zbrozek [mailto: ] 

Sent: Wednesday, October 05, 2016 1:41 PM 

To: Thomas E. Gorman 

Subject: Re: connecting w/ outside counsel 

Here you go. 

wrote: 

On Wed, Oct 5, 2016 at I :24 PM, Thomas E. Gorman <TGorman@iJkvn.com> wrote: 

Apologies for not getting back to you sooner. 

Don't wipe anything just yet, and in fact, please send me the logs for anthonyl REDACTED - PRIVILEGE 

Thanks, 

--Tom 

HIGHLY CONFIDENTIAL-ATTORNEYS' EYES ONLY WAYMO-UBER-00084486 

From: Sasha Zbrozek ]

Sent: Wednesday, October 05, 2016 2:44 PM

To: Thomas E. Gorman

Subject: Re: connecting w/ outside counsel

The hostname isn't logged because it isn't part of the protocol. It was a Windows machine, but that's no surprise. Only one

lP was ever used, which is registered to Google.

On Wed, Oct 5, 2016 at 2:32 PM, Thomas E. Gorman <TGoi"1iizingéL“l<vn.com> wrote:

Was Anthony's account sync’d to his Windows laptop? anthOnylO-W?

From: Sasha Zbrozek [mailto: ]

Sent: Wednesday, October 05, 2016 1:41 PM

To: Thomas E. Gorman

Subject: Re: connecting w/ outside counsel

Here you go.

On Wed, Oct 5, 2016 at 1:24 PM, Thomas E. Gorman <TGoi"man§éUl<vn.coin> wrote:

Apologies for not getting back to you sooner.

Don't\1vipe anything just yet, and in fact, please send me the logs for anthonyl REDACTED - PR/\//LEGE

Thanks,

“»Tom

HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY WAYMO-UBER—00084486

From: Sasha Zbrozek ]

Sent: Wednesday, October 05, 2016 2:44 PM

To: Thomas E. Gorman

Subject: Re: connecting w/ outside counsel

The hostname isn't logged because it isn't part of the protocol. It was a Windows machine, but that's no surprise. Only one

lP was ever used, which is registered to Google.

On Wed, Oct 5, 2016 at 2:32 PM, Thomas E. Gorman <TGoi"1iizingéL“l<vn.com> wrote:

Was Anthony's account sync’d to his Windows laptop? anthOnylO-W?

From: Sasha Zbrozek [mailto: ]

Sent: Wednesday, October 05, 2016 1:41 PM

To: Thomas E. Gorman

Subject: Re: connecting w/ outside counsel

Here you go.

On Wed, Oct 5, 2016 at 1:24 PM, Thomas E. Gorman <TGoi"man§éUl<vn.coin> wrote:

Apologies for not getting back to you sooner.

Don't\1vipe anything just yet, and in fact, please send me the logs for anthonyl REDACTED - PR/\//LEGE

Thanks,

“»Tom

HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY WAYMO-UBER—00084486

Case 3:17-cv-00939-WHA Document 1433-15 Filed 08/31/17 Page 4 of 9
From: Sasha Zbrozek [mailto: ] 

Sent: Wednesday, October 05, 2016 1:22 PM 

To: Thomas E. Gorman 

Cc: Tom Lue; Tamara Jih Murray; OTTO-KVN; Charley Saint 

Subject: Re: connecting w/ outside counsel 

-nick, as he has moved on . 

Was there any other information you were looking for? If not, I'm going to wipe my copies of the logs and the analysis 

scripts. 

On Wed, Sep 21, 2016 at 11 :21 AM, Sasha Zbrozek wrote: 

Summary: 

anthonyl - last access 2015-12-11 

rradu - no access ever 

skshirsagar - no access ever 

If you think there's need, I can send you those users' log entries, but they don't look very interesting. 

HIGHLY CONFIDENTIAL-ATTORNEYS' EYES ONLY WAYMO-UBER-00084487 

From: Sasha Zbrozek [mailto: ]

Sent: Wednesday, October 05, 2016 1:22 PM

To: Thomas E. Gorman

Cc: Tom Lue; Tamara Jih Murray; OTTO-KVN; Charley Saint

Subject: Re: connecting w/ outside counsel

-nick, as he has moved on .

Was there any other information you were looking for? lf not, I'm going to wipe my copies of the logs and the analysis

scripts.

On Wed, Sep 21, 2016 at l l:2l AM, Sasha Zbrozek wrote:

Summary:

anthonyl - last access 2015-12-l l

rradu - no access ever

skshirsagar - no access ever

If you think there's need, I can send you those users‘ log entries, but they don't look very interesting.

HIGHLY CONFlDENTlAL — ATTORNEYS’ EYES ONLY WAYMO-UBER-00084487

From: Sasha Zbrozek [mailto: ]

Sent: Wednesday, October 05, 2016 1:22 PM

To: Thomas E. Gorman

Cc: Tom Lue; Tamara Jih Murray; OTTO-KVN; Charley Saint

Subject: Re: connecting w/ outside counsel

-nick, as he has moved on .

Was there any other information you were looking for? lf not, I'm going to wipe my copies of the logs and the analysis

scripts.

On Wed, Sep 21, 2016 at l l:2l AM, Sasha Zbrozek wrote:

Summary:

anthonyl - last access 2015-12-l l

rradu - no access ever

skshirsagar - no access ever

If you think there's need, I can send you those users‘ log entries, but they don't look very interesting.

HIGHLY CONFlDENTlAL — ATTORNEYS’ EYES ONLY WAYMO-UBER-00084487

Case 3:17-cv-00939-WHA Document 1433-15 Filed 08/31/17 Page 5 of 9
On Tue, Sep 20, 2016 at 8:39 PM, Thomas E. Gorman <TGon11an(fvkvn.com> wrote: 

@Charley, the request is a little further down in this threat, in my 9/19 email @ 8:15 PM. Please let me know if you have any questions. 

Thanks, 

--Tom 

From: Tom Lue 

Date: Tuesday, September 20, 2016 at 11:21 AM 

To: Nick Vines 

Cc: Thomas Gorman <TGorman@kvn.com>, Sasha Zbrozek , Tammy Murray 

OTTO-KVN <OTTO-KVN@kvn.com>, Charley Saint 

Subject: Re: connecting w/ outside counsel 

+Charley, who I just chatted with briefly. 

Charley -- Tom Gorman is from Keker & Van Nest, our outside counsel on this matter, and Tammy is from the Google 

litigation team. @Tom G. -- Can you let Charley know what you need on your end? 

Thanks all, 

Tom 

HIGHLY CONFIDENTIAL-ATTORNEYS' EYES ONLY WAYMO-UBER-00084488 

~:-§§l:tt*$l1££.

On Tue, Sep 20, 2016 at 8:39 PM, Thomas E. Gorman <TGon1iaii§ti)~kvn.coni> wrote:

@Charley, the request is a little further down in this threat, in my 9/19 email @ 8:15 PM. Please let me know if you have any questions.

Thanks,

--Torn

From: Tom Lue

Date: Tuesday, September 20,2016 at 11:21 AM

To: Nick Vines >

Cc: Thomas Gorman <TGorrnan@kvn.com>, Sasha Zbrozek , Tammy Murray

, OTTO-KVN <OTTO-KVN@kvn.com>, Charley Saint

Subject: Re: connecting w/ outside counsel

+ Charley, who Ijust chatted with briefly.

Charley -- Tom Gorman is from Keker & Van Nest, our outside counsel on this matter, and Tammy is from the Google

litigation team. @Tom G. -- Can you let Charley know what you need on your end?

Thanks all,

Tom

HIGHLY CON FlDENTlAL - ATTORNEYS’ EYES ONLY WAYMO-UBER-00084488

~:-§§l:tt*$l1££.

On Tue, Sep 20, 2016 at 8:39 PM, Thomas E. Gorman <TGon1iaii§ti)~kvn.coni> wrote:

@Charley, the request is a little further down in this threat, in my 9/19 email @ 8:15 PM. Please let me know if you have any questions.

Thanks,

--Torn

From: Tom Lue

Date: Tuesday, September 20,2016 at 11:21 AM

To: Nick Vines >

Cc: Thomas Gorman <TGorrnan@kvn.com>, Sasha Zbrozek , Tammy Murray

, OTTO-KVN <OTTO-KVN@kvn.com>, Charley Saint

Subject: Re: connecting w/ outside counsel

+ Charley, who Ijust chatted with briefly.

Charley -- Tom Gorman is from Keker & Van Nest, our outside counsel on this matter, and Tammy is from the Google

litigation team. @Tom G. -- Can you let Charley know what you need on your end?

Thanks all,

Tom

HIGHLY CON FlDENTlAL - ATTORNEYS’ EYES ONLY WAYMO-UBER-00084488

Case 3:17-cv-00939-WHA Document 1433-15 Filed 08/31/17 Page 6 of 9
On Tue, Sep 20, 2016 at 10: 11 AM, Tom Lue wrote: 

OK thanks, Nick. @Tammy -- I'll reach out to and connect him with you/KVN. 

Best, 

Tom 

On Tue, Sep 20, 2016 at I 0:08 AM, Nick Vines wrote: 

Hi Torn, 

I haven't been able to find a way to get access logs. 

is a better contact to see if there is a log or report that 

might show sync operations around a specific date. 

Nick 

On Mon, Sep 19, 2016 at 8: 15 PM Thomas E. Gorman <TGorrnan(ciJ kvn.corn> wrote: 

ATTORNEY-CLIENT PRIVILEGED & CONFIDENTIAL 

Nick I SashaThanks in advance for your help! We're looking to check two systems for the account activity associated with a few Xooglers. 

HIGHLY CONFIDENTIAL-ATTORNEYS' EYES ONLY WAYMO-UBER-00084489 

On Tue, Sep 20, 2016 at 10:1 I AM, Tom Lue wrote:

OK thanks, Nick. @Tammy -- I'll reach out to and connect him with you/KVN.

Best,

Tom

On Tue, Sep 20, 2016 at 10:08 AM, Nick Vines wrote:

Hi Tom,

I haven't been able to find a way to get access logs.

is a better contact to see ifthere is a log or report that

might show sync operations around a specific date.

Nick

On Mon, Sep I9, 2016 at 8: I5 PM Thomas E. Gorman <TGorman§é1Jkvn.com> wrote:

ATTORNEY-CLIENT PRIVILEGED & CONFIDENTIAL

Nick / SashaThanks in advance for your help! We're looking to check two systems for the account activity associated with a few Xooglers.

HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY WAYMO-UBER-00084489

On Tue, Sep 20, 2016 at 10:1 I AM, Tom Lue wrote:

OK thanks, Nick. @Tammy -- I'll reach out to and connect him with you/KVN.

Best,

Tom

On Tue, Sep 20, 2016 at 10:08 AM, Nick Vines wrote:

Hi Tom,

I haven't been able to find a way to get access logs.

is a better contact to see ifthere is a log or report that

might show sync operations around a specific date.

Nick

On Mon, Sep I9, 2016 at 8: I5 PM Thomas E. Gorman <TGorman§é1Jkvn.com> wrote:

ATTORNEY-CLIENT PRIVILEGED & CONFIDENTIAL

Nick / SashaThanks in advance for your help! We're looking to check two systems for the account activity associated with a few Xooglers.

HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY WAYMO-UBER-00084489

Case 3:17-cv-00939-WHA Document 1433-15 Filed 08/31/17 Page 7 of 9
The systems are: 

1. Solidworks/PLM 

2. SVN/Altium 

The individuals/ time periods that we are focused on are: 

anthonyl - Aug. 2015 through Jan. 2016 

skshirsagar - June to July 2016 

rradu - June to July 2016. 

The second tranche includes hardware engineers and a supply-chain manager, so those logs could be more burdensome to collect. 

We might need to chat about ways to limit the burden by focusing the search (limit the time period? limit to certain types of access?). 

Please let me know if you have any questions. Thanks again, 

--Tom 

From: Tom Lue 

Date: Monday, September 19, 2016 at 1:41 PM 

To: Nick Vines Sasha Zbrozek 

Cc: Thomas Gorman <TGorman@kvn.com>, Tammy Murray 

Subject: connecting w/ outside counsel 

Hi Nick and Sasha, 

Per my chat with you both individually, I'm connecting you with Tom Gorman from Keker & Van Nest (outside counsel), 

as well as Tammy who is lead POC from the Google litigation team. 

HIGHLY CONFIDENTIAL-ATTORNEYS' EYES ONLY WAYMO-UBER-00084490 

The systems are:

1. Solidworks/PLM

2. SVN/Altium

The individuals /time periods that we are focused on are:

anthonyl — Aug. 2015 through Jan. 2016

skshirsagar — June to July 2016

rradu —lune to July 2016.

The second tranche includes hardware engineers and a supply~chain manager, so those logs could be more burdensome to collect.

We might need to chat about ways to limit the burden by focusing the search (limit the time period? limit to certain types of access?).

Please let me know if you have any questions. Thanks again,

--Tom

From: Tom Lue

Date: Monday, September 19, 2016 at 1:41 PM

To: Nick Vines , Sasha Zbrozek

Cc: Thomas Gorman <TGorrnan@kvn.com>, Tammy Murray

Subject: connecting w/ outside counsel

Hi Nick and Sasha,

Per my chat with you both individually, I'm connecting you with Tom Gorman from Keker & Van Nest (outside counsel),

as well as Tammy who is lead POC from the Google litigation team.

HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY WAYMO-UBER-00084490

The systems are:

1. Solidworks/PLM

2. SVN/Altium

The individuals /time periods that we are focused on are:

anthonyl — Aug. 2015 through Jan. 2016

skshirsagar — June to July 2016

rradu —lune to July 2016.

The second tranche includes hardware engineers and a supply~chain manager, so those logs could be more burdensome to collect.

We might need to chat about ways to limit the burden by focusing the search (limit the time period? limit to certain types of access?).

Please let me know if you have any questions. Thanks again,

--Tom

From: Tom Lue

Date: Monday, September 19, 2016 at 1:41 PM

To: Nick Vines , Sasha Zbrozek

Cc: Thomas Gorman <TGorrnan@kvn.com>, Tammy Murray

Subject: connecting w/ outside counsel

Hi Nick and Sasha,

Per my chat with you both individually, I'm connecting you with Tom Gorman from Keker & Van Nest (outside counsel),

as well as Tammy who is lead POC from the Google litigation team.

HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY WAYMO-UBER-00084490

Case 3:17-cv-00939-WHA Document 1433-15 Filed 08/31/17 Page 8 of 9
@Tom -- please advise Nick and Sasha on what you need from your end. 

Thanks all, 

Tom 

If you received this communication by mistake, don't forward it to anyone else (it may contain confidential or privileged 

information), please erase all of it, including all attachments, and please let the sender know it went to the wrong person. Thanks. 

HIGHLY CONFIDENTIAL-ATTORNEYS' EYES ONLY WAYMO-UBER-00084491 

@Tom -- please advise Nick and Sasha on what you need from your end.

Thanks all,

Tom

If you received this communication by mistake, please don‘t forward it to anyone else (it may contain confidential or privileged

information), please erase all copies of it, including all attachments, and please let the sender know it went to the wrong person. Thanks.

Nick Vines I Self-Driving-Car Project I

HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY WAYMO-UBER-00084491

@Tom -- please advise Nick and Sasha on what you need from your end.

Thanks all,

Tom

If you received this communication by mistake, please don‘t forward it to anyone else (it may contain confidential or privileged

information), please erase all copies of it, including all attachments, and please let the sender know it went to the wrong person. Thanks.

Nick Vines I Self-Driving-Car Project I

HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY WAYMO-UBER-00084491

Case 3:17-cv-00939-WHA Document 1433-15 Filed 08/31/17 Page 9 of 9