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

COOPER DECLARATION ISO DEFENDANTS’ ADMINISTRATIVE MOTION TO SEAL

QUINN EMANUEL URQUHART & SULLIVAN, LLP 

 Charles K. Verhoeven (Bar No. 170151) 

 charlesverhoeven@quinnemanuel.com 

 David A. Perlson (Bar No. 209502) 

 davidperlson@quinnemanuel.com 

 Melissa Baily (Bar No. 237649) 

 melissabaily@quinnemanuel.com 

 John Neukom (Bar No. 275887) 

 johnneukom@quinnemanuel.com 

 Jordan Jaffe (Bar No. 254886) 

 jordanjaffe@quinnemanuel.com 

50 California Street, 22nd Floor 

San Francisco, California 94111-4788 

Telephone: (415) 875-6600 

Facsimile: (415) 875-6700 

Attorneys for WAYMO LLC 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION 

WAYMO LLC, 

Plaintiff, 

vs. 

UBER TECHNOLOGIES, INC.; 

OTTOMOTTO LLC; OTTO TRUCKING 

LLC, 

Defendants. 

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

DECLARATION OF LINDSAY COOPER 

IN SUPPORT OF DEFENDANTS’ 

ADMINISTRATIVE MOTION TO FILE 

UNDER SEAL (DKT. 409)

 

Case 3:17-cv-00939-WHA Document 442 Filed 05/15/17 Page 1 of 3
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-2- CASE NO. 3:17-cv-00939-WHA

COOPER DECLARATION ISO DEFENDANTS’ ADMINISTRATIVE MOTION TO SEAL

I, Lindsay Cooper, declare as follows: 

1. I am an attorney licensed to practice in the State of California and am admitted to 

practice before this Court. I am an associate at the law firm Quinn Emanuel Urquhart & Sullivan, 

LLP, counsel for the Plaintiff Waymo LLC (“Waymo”). I have personal knowledge of the matters set 

forth in this Declaration, and if called as a witness I would testify competently to those matters. 

2. I make this declaration in support of Defendants’ Administrative Motion to Seal 

portions of their Response to Waymo’s Supplemental Brief Regarding Haslim Testimony, and 

Supporting Exhibits Thereto (the “Administrative Motion”). The Administrative Motion seeks an 

order sealing certain highlighted portions of Defendants’ Response to Waymo’s Supplemental Brief 

Regarding Haslim Testimony, and Supporting Exhibits Thereto (Dkt. 409) (“Defendants’ Response 

and Supporting Exhibits”). 

3. Portions of Defendants’ Response and Supporting Exhibits (including Yang Exhibit 1-

2 and 4-6 contain or refer to trade secret and confidential business information, which Waymo seeks 

to seal. 

4. Portions of Defendants’ Response (portions highlighted in green), portions of Yang 

Exhibits 1-2 and 4 (portions highlighted in green) and Yang Exhibits 5-6 (entire documents) contain, 

reference, and/or describe Waymo’s asserted trade secrets. The information Waymo seeks to seal 

includes the confidential design and functionality of Waymo’s proprietary autonomous vehicle 

system, which Waymo maintains as secret. I understand that these trade secrets are maintained as 

secret by Waymo (Dkt. 25-47) and are valuable as trade secrets to Waymo’s business (Dkt. 25-31). 

The public disclosure of this information would give Waymo’s competitors access to in-depth 

descriptions—and analysis—of the functionality of Waymo’s autonomous vehicle system. If such 

information were made public, I understand that Waymo’s competitive standing would be 

significantly harmed. 

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

Response that merit sealing, and the scope of information that Waymo is seeking to seal is consistent 

with other administrative motions to seal that have already been granted by the Court in this case. 

(See Dkt. 416, 414, 406, 393, 392.) 

Case 3:17-cv-00939-WHA Document 442 Filed 05/15/17 Page 2 of 3
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-3- CASE NO. 3:17-cv-00939-WHA

COOPER DECLARATION ISO DEFENDANTS’ ADMINISTRATIVE MOTION TO SEAL

I declare under penalty of perjury under the laws of the State of California and the United 

States of America that the foregoing is true and correct, and that this declaration was executed in San 

Francisco, California, on May 15, 2017. 

By /s/ Lindsay Cooper 

 Lindsay Cooper 

 Attorneys for WAYMO LLC 

Case 3:17-cv-00939-WHA Document 442 Filed 05/15/17 Page 3 of 3