JOINT SUBMISSION OF PROPOSED VOIR DIRE QUESTIONS

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

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[Counsel Signatures Appear at the End]

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

JOINT SUBMISSION OF PROPOSED 

VOIR DIRE QUESTIONS 

Judge: The Honorable William Alsup

Trial Date: October 10, 2017

Case 3:17-cv-00939-WHA Document 1727 Filed 09/21/17 Page 1 of 4
JOINT SUBMISSION OF PROPOSED VOIR DIRE QUESTIONS

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

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JOINT SUBMISSION OF PROPOSED VOIR DIRE QUESTIONS

Pursuant to the Court’s Guidelines for Trial and Final Pretrial Conference in Civil Jury

Cases, the parties submit the following proposed voir dire questions:

Key Questions

1. Do you, or does anyone close to you, have any training, experience or special 

knowledge in any of the following fields? If so, please tell me about it.

Vehicle design and manufacturing

Self-driving vehicles

Optical lasers or LiDAR

Radar

Semiconductor design

Electrical engineering

Product design and development

Finance

Trade secret law

Buying or selling companies

Forensic analysis of data systems

Data security

2. Do you consider yourself computer savvy? Do you regularly read technology or 

computer articles or magazines? If so, how often?

3. Are you familiar with any self-driving vehicle technologies—technologies that 

permit a vehicle to operate with minimal or no human control? Do you have any strong feelings, 

positive or negative, about self-driving vehicle technologies?

4. Have you ever worked for a company that has trade secrets or patents? If so, what 

role did you have with respect to the company’s intellectual property?

5. Have or anyone close to you ever owned a business. If so, what type and was it 

successful?

6. Have you ever served as a juror before? Was it a civil or criminal case? What did 

the case involve? Was it a positive or negative experience for you?

7. Have you ever been involved in litigation over trade secrets or patents? 

8. Have you ever been involved in selling, buying, or licensing trade secrets or 

patents?

Case 3:17-cv-00939-WHA Document 1727 Filed 09/21/17 Page 2 of 4
JOINT SUBMISSION OF PROPOSED VOIR DIRE QUESTIONS

Case No. 3:17-cv-00939-WHA 2

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9. Do you feel that if one company accuses another company of stealing secrets or 

infringing its patents, the accusation is probably true or probably not true?

10. Does anyone here have a close relationship to a lawyer?

11. Is there a reason, because of your background or employment, that you believe you 

cannot judge this case impartially?

12. Do you know of any other matter which you believe should be called to the court’s 

attention as having some bearing upon your qualifications or ability to sit as a juror, or which you 

think may prevent you from rendering a fair and impartial verdict based solely upon the evidence 

and my instructions as to the law?

Dated: September 20, 2017 MORRISON & FOERSTER LLP 

By: /s/ Arturo J. González

ARTURO J. GONZÁLEZ

Attorneys for Defendants

UBER TECHNOLOGIES, INC.

and OTTOMOTTO LLC

Dated: September 20, 2017 GOODWIN PROCTER LLP

By: /s/ Neel Chatterjee

NEEL CHATTERJEE

Attorneys for Defendant

OTTO TRUCKING, LLC

Dated: September 20, 2017 QUINN EMANUEL URQUHART & SULLIVAN, 

LLP

By: /s/ Charles K. Verhoeven

CHARLES K. VERHOEVEN

Attorneys for Plaintiff

WAYMO LLC

Case 3:17-cv-00939-WHA Document 1727 Filed 09/21/17 Page 3 of 4
01980-00104/9567278.1 JOINT SUBMISSION OF PROPOSED VOIR DIRE QUESTIONS

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

sf-3824298

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ATTESTATION OF E-FILED SIGNATURE

I, Charles K. Verhoeven, am the ECF User whose ID and password are being used to file 

this Joint Submission of Proposed Voir Dire Questions. In compliance with General Order 45, 

X.B., I hereby attest that Arturo J. González and Neel Chatterjee have concurred in this filing.

Dated: September 20, 2017 /s/ Charles K. Verhoeven

Charles K. Verhoeven

Case 3:17-cv-00939-WHA Document 1727 Filed 09/21/17 Page 4 of 4