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

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

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

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 

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 SCOTT BOEHMKE IN SUPPORT 

OF DEFENDANTS’ SUR-REPLY 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 

REDACTED VERSION OF DOCUMENT SUBMITTED UNDER SEAL

Case 3:17-cv-00939-WHA Document 306 Filed 04/28/17 Page 1 of 14
SUPPLEMENTAL BOEHMKE DECL. ISO DEFENDANTS’ SUR-REPLY TO WAYMO’S PRELIMINARY INJUNCTION MOTION

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

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

I, Scott Boehmke, declare as follows: 

1. I am an engineering manager within the Advanced Technologies Group at Uber 

Technologies, Inc. (“Uber”), where I am responsible for hardware development and application in 

Uber’s self-driving vehicle project. I understand that Waymo has filed a lawsuit against Uber, 

Ottomotto LLC (“Otto”) and Otto Trucking LLC in the U.S. District Court for the Northern 

District of California. I submit this supplemental declaration in support of Defendants’ Sur-Reply 

to Waymo LLC’s (“Waymo”) Motion for Preliminary Injunction. I have personal knowledge of 

the facts set forth in this declaration and, if called to testify as a witness, could and would do so 

competently. 

Prior Work Reflecting Non-Uniform Beam Spacing 

2. I understand that Waymo’s expert argued in his reply declaration that my work 

relating to beam spacing prior to my first meeting with Otto, which I had included as exhibits to 

my earlier declaration, only shows (1) distinct “zones” in which groups of lasers are equally 

distributed, and (2) distributions of lasers where the differences between zones are “symmetrical.” 

To the contrary, I have been working on developing non-uniform beam spacing for LiDAR 

sensors since 2015, including beam patterns for which the spacing between adjacent laser diodes 

varies continuously and non-symmetrically. Paragraphs 3 to 5 below address the work I 

performed prior to my first meeting with anyone from Otto in late April 2016, which I also 

described in my prior declaration. 

3. Figure 1 is a true and accurate annotated excerpt from my October 2015 “LADAR 

Design Notebook”1 showing schematic and spacing parameters of a variably-spaced diode design 

for Velodyne’s VLP-32, which has 32 diodes. I included an unannotated copy of this excerpt in 

paragraph 8 of my earlier declaration. The blue dots on the right hand side of the excerpt 

represent the vertical positions of each of the 32 diodes, with the diodes at the top and bottom 

. The chart to the right of the schematic 

provides the precise angles of each diode, as well as the change in angular orientation or elevation 

 

1

 A true and correct copy of this document was previously attached as Exhibit B to my earlier 

declaration in support of defendants’ opposition to plaintiff’s motion for preliminary injunction. 

Case 3:17-cv-00939-WHA Document 306 Filed 04/28/17 Page 2 of 14
SUPPLEMENTAL BOEHMKE DECL. ISO DEFENDANTS’ SUR-REPLY TO WAYMO’S PRELIMINARY INJUNCTION MOTION

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

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

(or “deltas”) between the angles. As is evident both visually in the schematic and numerically in 

the corresponding chart, the “angular elevation” of the 32 laser diodes is 

. 

4. As I mentioned in my earlier declaration, was one of the potential 

suppliers I was evaluating in 2015 to provide LiDAR sensors customized to Uber’s beam spacing 

and field of view requirements. From November 2015 through March 2016, I worked on 

developing the custom beam patterns and parameters necessary for Uber’s automotive use, taking 

into account the technical constraints of LiDAR sensors. Figure 2.A is a true and 

accurate annotated excerpt of a request for quotation2

 (RFQ) that Uber provided to on 

December 7, 2015 for a LiDAR sensor capable of providing Uber’s requested parameters and 

 

2

 A true and correct copy of this document was previously attached as Exhibit D to my earlier 

declaration in support of defendants’ opposition to plaintiff’s motion for preliminary injunction. 

Case 3:17-cv-00939-WHA Document 306 Filed 04/28/17 Page 3 of 14
SUPPLEMENTAL BOEHMKE DECL. ISO DEFENDANTS’ SUR-REPLY TO WAYMO’S PRELIMINARY INJUNCTION MOTION

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

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

field of view requirements (i.e., a total vertical field of view of 45 degrees, 102 lines or channels, 

“non-uniform spacing,” and 0.16 degrees minimum gap). Figure 2.B is a true and accurate 

annotated excerpt of the preliminary specifications3 for a 64-channel LiDAR sensor customized 

to Uber’s parameters and field of view requirements that Uber provided to on 

December 15, 2015. Similar to the RFQ, the preliminary specifications envisioned a total vertical 

field of view of 45 degrees and , providing precise vertical positions of the 

64 laser channels and the beam separation (i.e., the change in angular orientation) between each 

laser channel. The pattern clearly indicates a distribution of laser channels that was under 

consideration in 2015, where the adjacent pairs of laser diodes had different beam separations. 

For example, the beam separation from 

, where each pair of adjacent laser diodes had different beam separation. Laser 

channels 3-9 are not grouped into “zones” where multiple lasers within each zone are equally 

distributed. Moreover, the differences between the beam separations are not “symmetric.” As 

shown in the chart, the beam separation between laser channels 5 and 6 is , the beam 

separation between laser channels 6 and 7 is , and the beam separation between the 

laser channels 7 and 8 is . Here, the difference between the beam separation in laser 

channels 5 and 6 and laser channels 6 and 7 is different from the 

difference between beam separation in laser channels 6 and 7 and laser channels 7 and 8 

 

 

3

 A true and correct copy of this document was previously attached as Exhibit E to my earlier 

declaration in support of defendants’ opposition to plaintiff’s motion for preliminary injunction. 

Case 3:17-cv-00939-WHA Document 306 Filed 04/28/17 Page 4 of 14
SUPPLEMENTAL BOEHMKE DECL. ISO DEFENDANTS’ SUR-REPLY TO WAYMO’S PRELIMINARY INJUNCTION MOTION

Case No. 3:17-cv-00939-WHA 4

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

5. As I mentioned in my earlier declaration, Uber entered into a contract with 

 in March 2016 under which agreed to develop for Uber 

 based on Uber’s custom 

beam patterns and parameters. Figure 3.A is a true and correct CAD rendering of the 

dual-stack, excerpted from my May 2016 “LIDAR Thoughts.”4 Figure 3.B is a true and correct 

annotated excerpt of the final specifications5 Uber provided to to build a pair of 

 according to Uber’s custom beam pattern and parameters. 

The annotated chart in Figure 3.A clearly shows a distribution of laser channels in the 

dual-stack, from , where each pair of adjacent laser diodes had different 

beam separations. Here, the differences between the beam separations are also not symmetric. 

For example, as annotated below in Figure 3.B, the beam separation between laser channels 18 

and 19 is , the beam separation between laser channels 19 and 20 is , and 

the beam separation between the laser channels 20 and 21 is . Here, the difference 

between the beam separation in laser channels 18 and 19 and laser channels 19 and 20 

 

4

 A true and correct copy of this document was previously attached as Exhibit H to my earlier 

declaration in support of defendants’ opposition to plaintiff’s motion for preliminary injunction. 

5

 A true and correct copy of this document was previously attached as Exhibit F to my earlier 

declaration in support of defendants’ opposition to plaintiff’s motion for preliminary injunction. 

Case 3:17-cv-00939-WHA Document 306 Filed 04/28/17 Page 5 of 14
SUPPLEMENTAL BOEHMKE DECL. ISO DEFENDANTS’ SUR-REPLY TO WAYMO’S PRELIMINARY INJUNCTION MOTION

Case No. 3:17-cv-00939-WHA 5

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

) is different from the difference between beam separation in laser channels 19 and 

20 and laser channels 20 and 21 

Figure 3.A Figure 3.B 

Multiple Laser Diodes on a Single Curved Printed Circuit Board (PCB) 

6. I understand that Waymo’s expert argued in his reply declaration that the first 

document showing placement of multiple laser diodes on a single PCB was in my May 2016 

LiDAR Thoughts document, included as Exhibit H of my earlier declaration. To the contrary, I 

have been considering positioning multiple laser diodes on a curved edge of a printed circuit 

board since December 2015. Paragraphs 7 to 10 address my work in this area. 

7. Figure 4 is a true and accurate excerpt from my December 2015 LADAR Design 

Notebook6

 showing a LiDAR concept having separate transmit and receive lenses and arranging 

three laser channels (represented in blue, green, and red) along a curved transmit board labeled 

“Lasers” behind a simple transmit (“Tx”) lens. I included this excerpt in my earlier declaration. 

The laser diodes are arranged in a curve because the geometry of a simple lens, such as a single 

 

6

 A true and correct copy of this document was previously attached as Exhibit C to my earlier 

declaration in support of defendants’ opposition to plaintiff’s motion for preliminary injunction. 

Case 3:17-cv-00939-WHA Document 306 Filed 04/28/17 Page 6 of 14
SUPPLEMENTAL BOEHMKE DECL. ISO DEFENDANTS’ SUR-REPLY TO WAYMO’S PRELIMINARY INJUNCTION MOTION

Case No. 3:17-cv-00939-WHA 6

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

transmit lens, would create a curved focal plane instead of a flat focal plane. The geometry of 

this curve is defined by the focal length of the lens. 

Figure 4

8. Figures 5.A and 5.B show true and accurate annotated excerpts of a printed circuit 

board layout with three laser diodes die attached and wire bonded to bond pads that Uber had 

created on March 29, 2016 to illustrate how tightly we could pack the laser diodes and drivers on 

a single printed circuit board (PCB). I understand that the layout in Figure 5.A was previously 

produced to Waymo as UBER00008423, and I informed Waymo’s attorney to the existence of 

this document during my deposition in this case.7

 Figure 5.B is an enlarged and excerpted view 

of the same layout that more clearly illustrates the placement of the laser diodes and the bond 

pads along the edge of the PCB. As this alternative view shows, we were able to reduce the 

spacing between the laser diodes down to 2.3 millimeters. 

 

7 See Boehmke Dep. 63:17-25, April 17, 2017. A true and correct excerpt of this section of my 

deposition is attached as Exhibit E to this declaration. 

Case 3:17-cv-00939-WHA Document 306 Filed 04/28/17 Page 7 of 14
SUPPLEMENTAL BOEHMKE DECL. ISO DEFENDANTS’ SUR-REPLY TO WAYMO’S PRELIMINARY INJUNCTION MOTION

Case No. 3:17-cv-00939-WHA 7

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

Figure 5.A Figure 5.B 

9. Further, as I explained in my earlier declaration, Uber was considering multiple 

options for LiDAR sensors as of May 18, 2016, three of which were laid out in my May 2016 

“LIDAR Thoughts.”8 Plan A was the “dual-stack,” which contrary to Waymo’s 

expert’s assumption, Uber is still pursuing. I understand that there was a PanDAR sensor that 

stacked two commercially available Velodyne HDL-32 sensors to illustrate the concept of 

foveated vision sensing in the LiDAR context.9 The dual-stack that Uber was 

considering was designed for automotive use with a foveated beam pattern different from the 

interleaved design in the PanDAR sensor, and was intended to overcome the technical constraints 

of commercially available LiDAR sensors, such as the Velodyne HDL-32. Plan B was to build 

an in-house diode-based LiDAR sensor that would be simpler to fabricate and would have 

improved specifications over then-existing LiDAR sensors. Figure 6 is a true and 

correct excerpt from my May 2016 “LIDAR Thoughts” listing some potential improvements on 

Velodyne’s designs, such as having and as few boards 

 

8

 A true and correct copy of this document was previously attached as Exhibit H to my earlier 

declaration in support of defendants’ opposition to plaintiff’s motion for preliminary injunction. 

9

 A true and correct copy of this document was previously attached as Exhibit 4 to Dr. Paul 

McManamon’s declaration in support of defendants’ opposition to plaintiff’s motion for 

preliminary injunction. 

Case 3:17-cv-00939-WHA Document 306 Filed 04/28/17 Page 8 of 14
SUPPLEMENTAL BOEHMKE DECL. ISO DEFENDANTS’ SUR-REPLY TO WAYMO’S PRELIMINARY INJUNCTION MOTION

Case No. 3:17-cv-00939-WHA 8

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

as possible to simplify alignment (e.g., 

). This LiDAR concept described in Plan B later became known as “Fuji.” 

Figure 6 

Plan C was to use a fiber laser design based on Uber’s discussions with Otto in late April and 

May 2016, which included discussions about the possibility of using eight fiber lasers that were 

potentially split in four, six, or eight, to allow for 32, 48, and 64 beams respectively. This LiDAR 

concept described in Plan C later became known as Spider, a design that Uber has since 

abandoned. 

10. I was considering placing multiple laser diodes on a curved PCB to reduce the 

number of transmit boards, which would simplify alignment between the laser diodes and the 

detectors. As shown in Figure 6 above, which describes what later became known as Fuji, I was 

considering a design having all laser diodes on one board (e.g., 

). However, we realized that having two cavities and mounting 32 

laser diodes on a single PCB per cavity did not provide enough spacing to accommodate the laser 

diodes’ circuits and associated components. This conclusion was informed in part by my prior 

determination, shown in Figure 5B, that a minimum spacing of at least 2.3mm was required 

between laser diodes. James then suggested in an email to me, dated October 28, 2016, that we 

should for each of the two cavities between the laser diodes’ circuits 

Case 3:17-cv-00939-WHA Document 306 Filed 04/28/17 Page 9 of 14
SUPPLEMENTAL BOEHMKE DECL. ISO DEFENDANTS’ SUR-REPLY TO WAYMO’S PRELIMINARY INJUNCTION MOTION

Case No. 3:17-cv-00939-WHA 9

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

and associated components.10 After further discussions with the LiDAR team, including James 

Haslim, it became evident that within each cavity, the 32 laser diodes would need to be 

distributed across to provide sufficient spacing. Based on these discussions, I 

created beam spacing and angles for what became the Fuji design, which has two cavities and 

 per cavity. Figure 7 is a true and correct excerpt from my November 2016 beam 

spacing and angles summary11 showing the assumptions used in the calculations of beam spacing 

for the Fuji device. This document shows that we independently came up with the design of a 

 (i.e., 2 separate optical 

cavities). 

Figure 7 

Anthony’s Involvement in the Fuji Device 

11. I understand that Waymo cites two email exchanges in June 2016 as evidence that 

Anthony Levandowksi “provided direction” to me, and contends that my development of Fuji’s 

beam spacing was not “independent.” I disagree with Waymo’s contentions. As explained 

 

10 A true and correct copy of this document was previously attached as Exhibit A to James 

Haslim’s April 7, 2017 declaration in support of defendants’ opposition to plaintiff’s motion for 

preliminary injunction. This document was also introduced and designated as Exhibit 56 during 

my deposition. 

11 A true and correct copy of this document was previously attached as Exhibit I to my earlier 

declaration in support of defendants’ opposition to plaintiff’s motion for preliminary injunction. 

Case 3:17-cv-00939-WHA Document 306 Filed 04/28/17 Page 10 of 14
SUPPLEMENTAL BOEHMKE DECL. ISO DEFENDANTS’ SUR-REPLY TO WAYMO’S PRELIMINARY INJUNCTION MOTION

Case No. 3:17-cv-00939-WHA 10

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

previously, including in my deposition in this case, I had independently come up with 

 patterns before these June 2016 emails (the emails related to Plan C and not Fuji.)12 

12. As I explained in my prior declaration, I independently created the beam spacing 

and angles captured in my November 2016 summary,13 which was based on beam spacing work 

that I had started as early as October 2015, and I understand that James and his team used the data 

in this summary to generate the initial optical cavity and transmit PCB designs for Fuji. 

13. At the time that we were considering a pivot from Spider to Fuji in late October 

2016, Anthony Levandowski was not involved in the day-to-day operations of the LiDAR team, 

and to my knowledge did not provide input on the technical details of the Fuji design. As I 

explained in my deposition, Anthony Levandowski did not direct the LiDAR team to pivot from 

Spider to Fuji, but instead deferred to the engineers on the LiDAR team and on their judgment 

that Spider was not a technically viable design and their recommendation to pursue a bistatic, 

diode-based LiDAR design.14 Exhibit A, attached hereto, is an email exchange between Eric 

Meyhofer, James Haslim, Dan Gruver, and me regarding the feasibility of pivoting from V1 (i.e., 

Spider) to V2 (i.e., a new diode-based design, which became Fuji).15 In this email, Eric Meyhofer 

stated that he had spoken with Anthony and had promised Anthony that 

Exhibit B, attached hereto, is a true and 

correct copy of the email from James Haslim inviting Eric Meyhofer, Daniel Gruver, and me to 

edit a spreadsheet comparing design considerations in Spider (i.e., “1550”) and a new diodebased design that later became Fuji (i.e., “905”).16 Notably, Anthony Levandowski was not 

 

12 See Boehmke Dep. 38:12-14. A true and correct excerpt of this section of my deposition is 

attached as Exhibit E to this declaration. 

13 A true and correct copy of this document was previously attached as Exhibit I to my earlier 

declaration in support of defendants’ opposition to plaintiff’s motion for preliminary injunction. 

14 See Boehmke Dep. 42:4-19, 48:7-48:9. A true and correct excerpt of this section of my 

deposition is attached as Exhibit E to this declaration. 

15 A true and correct copy of this document was provided to Waymo as UBER00008592 and was 

introduced and designated by Waymo as Exhibit 55 in my deposition. 

16 A true and correct copy of this document was provided to Waymo as UBER00008589. 

Case 3:17-cv-00939-WHA Document 306 Filed 04/28/17 Page 11 of 14
SUPPLEMENTAL BOEHMKE DECL. ISO DEFENDANTS’ SUR-REPLY TO WAYMO’S PRELIMINARY INJUNCTION MOTION

Case No. 3:17-cv-00939-WHA 11

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

included in this invitation. Exhibit C, attached hereto, is a true and correct copy of the 

spreadsheet referred to in Exhibit B.17

Comparison between Dual-Stack and Fuji 

14. I understand that Waymo’s expert argued in his reply declaration that my work 

relating to beam spacing prior to my first meeting with Otto was very different from my work on 

Fuji. To the contrary, I applied similar approaches to determine the desired beam angles for both 

the dual-stack that Uber was considering as early as November 2015, and the Fuji 

design. In calculating the distribution and quantity of light beams in both the dualstack and Fuji, I took into account various parameters, including vehicle speed, permissible 

deceleration rate, reaction time, mounting geometry of the sensor, anticipated road geometry, 

minimum detectable obstacle, and manufacturing tolerances. 

15. When I documented my thoughts for the dual-stack (“Plan A”) and the 

Fuji device (“Plan B”) in the May 2016 “LIDAR Thoughts,” I used the same base assumptions. 

Figure 7 is a true and correct excerpt from my May 2016 “LIDAR Thoughts” that explains the 

same base assumptions are used in the subsequent slides discussing Plan A and Plan B. 

 

17 I understand that a true and correct copy of this document was provided to Waymo as 

UBER00008487. 

Case 3:17-cv-00939-WHA Document 306 Filed 04/28/17 Page 12 of 14
SUPPLEMENTAL BOEHMKE DECL. ISO DEFENDANTS’ SUR-REPLY TO WAYMO’S PRELIMINARY INJUNCTION MOTION

Case No. 3:17-cv-00939-WHA 12

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

Figure 8 

16. When I finalized the beam spacing for the dual-stack in March 2016, I 

designed it to have no larger than a 

When I designed the beam spacing for the Fuji device in 

November 2016, I designed it to have no larger than a 

because I was no longer constrained by the limitations and poor manufacturing tolerances of 

. I was able to design Fuji to have tighter beam spacing, allowing Uber’s vehicle to see 

smaller targets at the same distances than the dual-stack. Further, when I designed the 

 dual-stack, I had envisioned applying a less aggressive deceleration and 

constant speed regardless of road slope, whereas for Fuji, I allowed for more aggressive 

deceleration and to reduce the vehicle speed when crossing steep slopes. 

17. Exhibit D is a true and correct copy of my calculations underlying the final 

specifications for the dual-stack.18 Figure 9.A is a true and correct excerpt of the 

assumptions for the beam spacing calculations for the dual-stack in Exhibit D, and 

 

18 The final specifications for the dual-stack were provided as Exhibit F to my earlier 

declaration. 

Case 3:17-cv-00939-WHA Document 306 Filed 04/28/17 Page 13 of 14