SUPPLEMENTAL LINAVAL DECL. ISO DEFENDANTS’ SUR-REPLY TO WAYMO’S PRELIMINARY INJUNCTION MOTION

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 

RUDY Y. KIM (CA SBN 199426) 

RKim@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

SUPPLEMENTAL DECLARATION OF 

ASHEEM LINAVAL IN SUPPORT OF 

DEFENDANTS’ SURREPLY 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 304 Filed 04/28/17 Page 1 of 4
SUPPLEMENTAL LINAVAL DECL. ISO DEFENDANTS’ SUR-REPLY TO WAYMO’S PRELIMINARY INJUNCTION MOTION

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

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I, Asheem Linaval, declare as follows: 

1. I am a hardware engineer at Uber Technologies, Inc. (“Uber”). My background is 

set forth in my April 6, 2017 declaration in support of Uber’s opposition to plaintiff’s motion for 

preliminary injunction. I make this declaration in support of Uber’s surreply to plaintiff’s motion 

for preliminary injunction. I make this declaration based on personal knowledge and, if called as 

a witness, I would testify to the facts listed below. 

2. I understand that nine unique hash matched files and 3,250 file name matched files 

were located on Uber’s systems since my last declaration. I have reviewed the nine hash matched 

files and the list of 3,250 file name matches. None of these files are from Waymo. Below I 

explain these files and why the hash or file name matches do not establish that these files came 

from Waymo. 

3. Five of the nine hash matched files are ODB++ metadata. I can procure nearly 

identical files from most any ODB++ board package. These files are 11200733.TXT; 

11200747.TXT; 130143.TXT; 130145.TXT and attrlist. I further explained attrlist files in my 

April 6, 2017 declaration. 

4. Three of the hash matched files are structure listings for very simple projects. 

These files reference other design documents and do not contain any substantive information. 

The first file, jdsu_rx.PrjPcbStructure, has a top level generically named “top.SchDoc” and a 

subschematic generically named “pmic.SchDoc.” The second file, 

PCB_Project_0BwLeHzZBkM1wdGF5NFhBSXUwTTQ.PrjPcbStructure, is a single-schematic 

project with the generic schematic name “Sheet1.SchDoc.” The third file, receiver-1-3-

0.PrjPCBStructure, is also a single-schematic project with a generic schematic name 

“receiver.SchDoc.” Because of the simplicity of these projects and the generic nature of the 

schematic names, I am unsurprised by the hash matches. 

5. I am not familiar with the last hash matched file, which is named “tools,” but the 

file path indicates that it came from a user guide for an Atmel microcontroller. 

6. Many of the filenames in the file name match list were explained in my April 6, 

2017 declaration. For example, 304 of the matches are named “netlist,” which is explained in my 

Case 3:17-cv-00939-WHA Document 304 Filed 04/28/17 Page 2 of 4
SUPPLEMENTAL LINAVAL DECL. ISO DEFENDANTS’ SUR-REPLY TO WAYMO’S PRELIMINARY INJUNCTION MOTION

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

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earlier declaration. Over 800 of the matches are .SCHDOC, .PCBDOC, or .PCBLIB files using a 

standard file naming convention with a functional description of the file, which are explained in 

my earlier declaration. I explain some additional file name matches in the list I reviewed below. 

7. Most of the additional file name matches (1279 of them) are files named “Status 

Report.txt.” When PCB outputs are generated using Altium, a Status Report file is usually 

generated. They only indicate that output files were generated, and contain no design 

information. It is unsurprising that there are file name matches. 

8. Another category of matches is SolidWorks files. Ninety-four of the file name 

matches are files named “board.SLDPRT,” “base.SLDPRT,” “rotor.SLDPRT,” and 

“pcb.SLDPRT.” Some of these are sample files that come with the SolidWorks software. Others 

are generically named SolidWorks files for which file name matches are unsurprising; indeed the 

names match those for the sample files.. 

9. Another category of matches is other sample or example files. Thirty-eight of the 

file name matches are .ASC files (e.g., 3683.ASC, 8620.ASC). These files are LTSpice examples 

that come with the software. Thirteen of the file name matches are files named “sort.py.” This 

file ships with Anaconda (a distribution of Python used for data science) and Sublime Text, a 

popular text editor. 

10. Forty-five of the file name matches are files named “Notes.txt” and “PCB.txt.” 

These are generic file names, and it is unsurprising that there are matches. 

11. Sixty-three of the file name matches are files named “PCB1.GBL” or 

“PCB1.GTL.” These are default names for gerber files, and the matches are unsurprising. 

12. Seventy-four of the file name matches are files named “Job1.outjob” or 

“Job2.outjob.” These are generic file names akin to “Document1,” and a file name match is 

unsurprising. These files reference other files and do not contain any substantive data. 

13. Thirteen of the file name matches are files named “Assembly Drawings.PDF.” 

These are generically named files, and a file name match is unsurprising. 

14. Fifteen of the file name matches are files named “J1.SLDASM.” J1 is a common 

designator for a connector, and I am unsurprised that there are file name matches. 

Case 3:17-cv-00939-WHA Document 304 Filed 04/28/17 Page 3 of 4
SUPPLEMENTAL LINAVAL DECL. ISO DEFENDANTS’ SUR-REPLY TO WAYMO’S PRELIMINARY INJUNCTION MOTION

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

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

the foregoing is true and correct. Executed this 27th day of April, 2017, in San Francisco, 

California.

 

Asheem Linaval 

Case 3:17-cv-00939-WHA Document 304 Filed 04/28/17 Page 4 of 4