CORRECTED CHANG DECL. ISO DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

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 

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

CORRECTED DECLARATION OF 

ESTHER KIM CHANG IN SUPPORT 

OF DEFENDANTS’ OPPOSITION 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 215 Filed 04/11/17 Page 1 of 4
CORRECTED CHANG DECL. ISO DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

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I, Esther Kim Chang, declare as follows: 

1. I am an attorney with the law firm of Morrison & Foerster LLP. I am a member in 

good standing of the Bar of the State of California. I make this declaration based on personal 

knowledge and, if called as a witness, I could and would testify competently to the matters set 

forth herein. I make this declaration in support of Defendant’s Opposition to Plaintiff’s Motion 

for Preliminary Injunction. 

2. To comply with this Court’s March 16, 2017 Order, we interviewed 86 Uber 

employees who had previously worked at Waymo,1 in order to identify any Waymo documents. 

3. Attached hereto as Exhibit 1 is a true and correct copy of a Bloomberg Technology 

article entitled “Uber Hires Veteran NASA Engineer to Develop Flying Cars,” dated 

February 6, 2017, from https://www.bloomberg.com/news/articles/2017-02-06/uber-hiresveteran-nasa-engineer-to-develop-flying-cars. 

4. Attached hereto as Exhibit 2 is a true and correct copy of the “Our Story” page 

from https://www.uber.com/our-story. 

5. Attached hereto as Exhibit 3 is a true and correct copy of the “Rethinking 

transportation” page from https://newsroom.uber.com/rethinking-transportation. 

6. Attached hereto as Exhibit 4 is a true and correct copy of relevant pages from the 

deposition of Tim Willis, taken on March 23, 2017. 

7. Attached hereto as Exhibit 5 is a true and correct copy of relevant pages from the 

deposition of Gary Brown, taken on March 24, 2017. 

8. Attached hereto as Exhibit 6 is a true and correct copy of relevant pages from the 

deposition of Michael Janosko, taken on March 23, 2017. 

9. Attached hereto as Exhibit 7 is a true and correct copy of relevant pages from the 

deposition of Pierre-Yves Droz, taken on March 31, 2017. 

10. Attached hereto as Exhibit 8 is a true and correct copy of a letter to the Nevada 

Department of Motor Vehicles, dated March 15, 2017. 

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 “Waymo” refers to Waymo LLC, Google Inc., and Alphabet Inc. 

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

foregoing is true and correct. Executed this 11th day of April, 2017, in San Francisco, California. 

 /s/ Esther Kim Chang 

 ESTHER KIM CHANG 

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CORRECTED CHANG DECL. ISO DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

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ATTESTATION OF E-FILED SIGNATURE 

I, Arturo J. González, am the ECF User whose ID and password are being used to file this 

Declaration. In compliance with General Order 45, X.B., I hereby attest that Esther Kim Chang 

has concurred in this filing. 

Dated: April 11, 2017 /s/ Arturo J. González 

Arturo J. González 

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