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01980-00104/9529816.1 CASE NO. 3:17-cv-00939-WHA

CORREDOR 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 FELIPE 

CORREDOR IN SUPPORT OF 

DEFENDANTS UBER TECHNOLOGIES, 

INC. AND OTTOMOTTO LLC’S 

ADMINISTRATIVE MOTION TO FILE 

UNDER SEAL PORTIONS OF THEIR 

MOTION FOR SUMMARY JUDGMENT 

AND EXHIBITS THERETO

Case 3:17-cv-00939-WHA Document 1470 Filed 09/05/17 Page 1 of 3
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01980-00104/9529816.1

-2- CASE NO. 3:17-cv-00939-WHA

CORREDOR DECLARATION ISO DEFENDANTS’ ADMINISTRATIVE MOTION TO SEAL

I, Felipe Corredor, 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 Uber Technologies, Inc. and 

Ottomotto, LLC’s Administrative Motion to File Under Seal Portions of Their Motion for Summary 

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

order sealing highlighted portions of Defendants’ Motion for Summary Judgment (“Defendants’ 

Motion”), Exhibits 9-11 and 15 to the Declaration of Michelle Yang (“Yang Exhibits”), the 

Declaration of James Haslim, the Declaration of Brent Schwarz, and Exhibits 1-2 and 4-5 to the 

Declaration of Shane Brun (“Brun Exhibits”), as well as the entirety of Yang Exhibits 2-4, 8, and 17-

18 and Brun Exhibits 3 and 6-7.

3. The portions of Defendants’ Motion marked in red boxes, certain portions of Yang 

Exhibit 3, the green highlighted portions of Yang Exhibits 9-11, and 15 and of Brun Exhibit 2, and the 

entirety of Yang Exhibit 8 and Brun Exhibits 6-7 contain or refer to trade secret information, which 

Waymo seeks to seal. 

4. Defendants’ Motion (portions marked in red boxes in version filed herewith), Yang 

Exhibit 3 (pages 18-20) Yang Exhibit 8 (entire document), Yang Exhibits 9-11 and 15 (green 

highlighted portions), Brun Exhibit 2 (green highlighted portions, except for portion at 5:15), and 

Brun Exhibits 6-7 (entire documents) contain, reference, and/or describe Waymo’s asserted trade 

secrets or information that, from context, tends to disclose Waymo’s asserted secrets, including as 

misappropriated by Defendants. The information Waymo seeks to seal includes the confidential 

design and functionality of Waymo’s proprietary autonomous vehicle system, including its LiDAR 

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

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

31). The public disclosure of this information would give Waymo’s competitors access to 

descriptions of the functionality or features of Waymo’s autonomous vehicle system. If such 

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01980-00104/9529816.1

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

CORREDOR DECLARATION ISO DEFENDANTS’ ADMINISTRATIVE MOTION TO SEAL

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

significantly harmed. 

5. In the event the Court were to deny Velodyne’s request to keep its confidential 

information under seal, Waymo may support sealing additional portions of Defendants’ Motion and 

portions of Yang Exhibit 17.

6. Waymo’s request to seal is narrowly tailored to those portions of Defendants’ Motion, 

Yang Exhibits 3, 8-11, and 15, and Brun Exhibits 2 and 6-7 that merit sealing.

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 September 5, 2017. 

By /s/ Felipe Corredor

 Felipe Corredor

 Attorneys for WAYMO LLC

ATTESTATION

In accordance with Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this 

document has been obtained from Felipe Corredor.

 By: /s/ Charles K. Verhoeven 

Charles K. Verhoeven

Case 3:17-cv-00939-WHA Document 1470 Filed 09/05/17 Page 3 of 3