CHANG DECL. ISO DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

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

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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’ OPPOSITION TO 

PLAINTIFF WAYMO LLC’S 

MOTION FOR PRELIMINARY 

INJUNCTION

Date: May 3, 2017

Time: 7:30 a.m.

Ctrm: 8, 19th Floor

Judge: The Honorable William Alsup

Trial Date: October 2, 2017

Case 3:17-cv-00939-WHA Document 186 Filed 04/07/17 Page 1 of 3
CHANG DECL. ISO DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

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

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I, Esther Kim Chang, declare as follows:

1. I am an attorney with 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 on personal 

knowledge and, if called as a witness, I could and would testify competently to the matters set 

forth herein. I make this declaration in support of Defendant’s Opposition to Plaintiff’s Motion 

for Preliminary Injunction.

2. To comply with this Court’s March 16, 2017, Order, we interviewed 86 Uber 

employees who worked at Google in order to identify any Waymo or Google documents.

3. Attached hereto as Exhibit 1 is a true and correct copy of a Bloomberg Technology 

article entitled “Uber Hires Veteran NASA Engineer to Develop Flying Cars” dated Feb. 6, 2017 

from https://www.bloomberg.com/news/articles/2017-02-06/uber-hires-veteran-nasa-engineer-todevelop-flying-cars.

4. Attached hereto as Exhibit 2 is a true and correct copy of the “Our Story” page 

from https://www.uber.com/our-story.

5. Attached hereto as Exhibit 3 is a true and correct copy of the “Rethinking 

transportation” page from https://newsroom.uber.com/rethinking-transportation.

6. Attached hereto as Exhibit 4 is a true and correct copy of relevant pages from the 

deposition of Tim Willis taken on March 23, 2017.

7. Attached hereto as Exhibit 5 is a true and correct copy of relevant pages from the 

deposition of Gary Brown taken on March 24, 2017.

8. Attached hereto as Exhibit 6 is a true and correct copy of relevant pages from the 

deposition of Michael Janosko taken on March 23, 2017.

9. Attached hereto as Exhibit 7 is a true and correct copy of relevant pages from the 

deposition of Pierre-Yves Droz taken on March 31, 2017.

10. Attached hereto as Exhibit 8 is a true and correct copy of a letter from the Nevada 

Department of Motor Vehicles dated March 15, 2017.

Case 3:17-cv-00939-WHA Document 186 Filed 04/07/17 Page 2 of 3
CHANG DECL. ISO DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

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

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

foregoing is true and correct. Executed this 7th 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 7, 2017 /s/ Arturo J. González

Arturo J. González 

Case 3:17-cv-00939-WHA Document 186 Filed 04/07/17 Page 3 of 3