UBER’S ADMINISTRATIVE MOTION TO SHORTEN TIME FOR HEARING ON MOTION TO COMPEL

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

sf-3752161 

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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 

KAREN L. DUNN (Pro Hac Vice app. pending) 

kdunn@bsfllp.com

HAMISH P.M. HUME (Pro Hac Vice app. pending) 

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., 

OTTOMOTTO LLC, and OTTO TRUCKING 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

UBER TECHNOLOGIES, INC., 

OTTOMOTTO LLC, AND OTTO 

TRUCKING LLC’S 

ADMINISTRATIVE MOTION TO 

SHORTEN TIME FOR HEARING ON 

DEFENDANTS’ MOTION TO 

COMPEL ARBITRATION 

Complaint Filed: February 23, 2017 

First Am. Compl. Filed: March 10, 2017 

Trial Date: October 2, 2017
UBER’S ADMINISTRATIVE MOTION TO SHORTEN TIME FOR HEARING ON MOTION TO COMPEL

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

sf-3752161 

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As the Court knows, a preliminary injunction hearing in this matter is scheduled for 

May 4, 2017. At the case management conference, on March 16, 2017, counsel for Uber advised 

the Court that it would be filing a petition to compel arbitration on the basis that Google’s 

employment agreements contain very broad arbitration provisions. This Court then stated: “I 

don’t want to go through the pain and suffering of a preliminary injunction hearing if it has to be 

arbitrated, is the point. Think that through.” (González Decl. Ex. A at 15:12-14.) 

Today, Uber is filing a Motion to Compel Arbitration of, and to Stay, Trade Secrets and 

UCL Claims (“Motion”), and will set it for hearing on May 4, the same date as the preliminary 

injunction. By this motion, Defendants ask that the Court set the following schedule for the 

Motion to Compel Arbitration: 

 Waymo’s Opposition to the Motion: April 3, 2017: 

 Defendants’ Reply In Support of Their Motion: April 6, 2017

 Hearing on the Motion: April 13, 2017 

This proposed schedule would have the Court consider this Motion three weeks before the 

hearing on preliminary injunction. Plaintiff has advised us that it opposes this request on the 

basis that even if this motion is granted, there will still be a hearing on its motion for preliminary 

injunction pertaining to the four patent claims at issue. (González Decl. ¶ 3, Ex. B.) That may 

be true, but that would be a very different hearing. 

Dated: March 27, 2017 MORRISON & FOERSTER LLP

By: /s/ Arturo J. González 

ARTURO J. GONZÁLEZ 

Attorneys for Defendants 

UBER TECHNOLOGIES, INC., 

OTTOMOTTO LLC, and OTTO TRUCKING LLC