DEFENDANT OTTO TRUCKING LLC’S NOTICE TO JOIN SUR-REPLY TO MOTION TO COMPEL FILED BY UBER TECHNOLOGIES,

INC. AND OTTOMOTTO LLC (CASE NO. 3:17-CV-00939-WHA) 

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Neel Chatterjee (SBN 173985) 

nchatterjee@goodwinlaw.com 

GOODWIN PROCTER LLP

135 Commonwealth Drive 

Menlo Park, California 94025-1105 

Tel.: +1 650 752 3100 

Fax.: +1 650 853 1038 

Brett Schuman (SBN 189247) 

bschuman@goodwinlaw.com

Rachel M. Walsh (SBN 250568) 

rwalsh@goodwinlaw.com

GOODWIN PROCTER LLP

Three Embarcadero Center 

San Francisco, California 94111 

Tel.: +1 415 733 6000 

Fax.: +1 415 677 9041 

Attorneys for Defendant 

OTTO TRUCKING LLC 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

WAYMO LLC, 

Plaintiff, 

v. 

UBER TECHNOLOGIES, INC., et al., 

Defendants. 

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

OTTO TRUCKING LLC’S NOTICE TO 

JOIN AND ADOPT DEFENDANTS UBER 

TECHNOLOGIES, INC’S AND 

OTTOMOTTO LLC’S SUR-REPLY BRIEF 

IN OPPOSITION TO PLAINTIFF 

WAYMO LLC’S MOTION TO COMPEL 

PRODUCTION OF DUE DILIGENCE 

REPORT 

Date: May 25, 2017 

Time: 10:00 a.m. 

Ctrm: F, 15th Floor 

Judge: The Honorable Jacqueline Scott Corley 

Trial Date: October 2, 2017 

Case 3:17-cv-00939-WHA Document 478 Filed 05/19/17 Page 1 of 4
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DEFENDANT OTTO TRUCKING LLC’S NOTICE TO JOIN SUR-REPLY TO MOTION TO COMPEL FILED BY UBER TECHNOLOGIES,

INC. AND OTTOMOTTO LLC (CASE NO. 3:17-CV-00939-WHA) 

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TO THE COURT, ALL PARTIES AND THEIR COUNSEL OF RECORD: 

PLEASE TAKE NOTICE THAT Defendant Otto Trucking LLC (“Otto Trucking”) hereby 

joins and adopts Defendants Uber Technologies, Inc.’s (“Uber”) and Ottomotto LLC’s (“Ottomotto”) 

Sur-Reply in Opposition to Plaintiff Waymo LLC’s (“Waymo”) Motion to Compel Production of 

Due Diligence Report. The hearing on the Motion is set for May 25, 2017 at 10:00 a.m. before the 

Honorable Jacqueline Scott Corley. In support, Otto Trucking states as follows: 

1. Waymo filed a Complaint on February 23, 2017 (Dkt. No. 1) and an Amended Complaint 

on March 10, 2017 (Dkt. No. 23) asserting seven causes of action equally against all 

Defendants, alleging trade secret misappropriation, patent infringement, and unfair 

competition. 

2. On May 1, 2017, Waymo filed a Motion to Compel the Production of Withheld 

Documents (Dkt No. 321) seeking the production of documents and information 

pertaining to all of Defendants Uber, Ottomotto, and Otto Trucking. 

3. On May 8, 2017, Co-Defendants Uber and Ottomotto filed a Brief in Opposition to 

Waymo’s Motion to Compel. Defendant Otto Trucking joined and adopted this brief. 

4. On May 17, 2017, Magistrate Judge Corley issued an order permitting Defendants Uber 

and Ottomotto to file a four-page sur-reply in support of their opposition to Waymo’s 

motion to compel. Co-Defendants Uber and Ottomotto filed their sur-reply on May 19, 

2017. 

5. Otto Trucking joins and adopts, as if set out verbatim herein, the arguments, authorities, 

contentions, exhibits, attachments, and prayers of Co-Defendants Uber and Ottomotto set 

forth in Co-Defendants’ Sur-Reply in Opposition to Waymo’s Motion to Compel 

Production of Due Diligence Report, filed with this Court on May 19, 2017, for the reason 

that said motion is equally applicable to this Defendant in the above captioned matter. 

6. Otto Trucking joins and adopts Co-Defendants’ Sur-Reply Brief in order to best serve 

justice and avoid unnecessary or duplicative effort, time, or expense to the parties 

involved. 

Case 3:17-cv-00939-WHA Document 478 Filed 05/19/17 Page 2 of 4
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DEFENDANT OTTO TRUCKING LLC’S NOTICE TO JOIN SUR-REPLY TO MOTION TO COMPEL FILED BY UBER TECHNOLOGIES,

INC. AND OTTOMOTTO LLC (CASE NO. 3:17-CV-00939-WHA) 

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WHEREFORE, Defendant Otto Trucking LLC hereby joins and adopts Co-Defendants’ SurReply in Opposition to Plaintiff’s Motion to Compel Production of Due Diligence Report. 

Dated: May 19, 2017 Respectfully submitted, 

By: /s/ Neel Chatterjee 

Neel Chatterjee 

nchatterjee@goodwinlaw.com

GOODWIN PROCTER LLP

135 Commonwealth Drive 

Menlo Park, California 94025 

Tel.: +1 650 752 3100 

Fax.: +1 650 853 1038 

Brett Schuman 

bschuman@goodwinlaw.com

Rachel M. Walsh 

rwalsh@goodwinlaw.com

GOODWIN PROCTER LLP

Three Embarcadero Center 

San Francisco, California 94111 

Tel.: +1 415 733 6000 

Fax.: +1 415 677 9041 

Attorneys for Defendant 

OTTO TRUCKING LLC 

Case 3:17-cv-00939-WHA Document 478 Filed 05/19/17 Page 3 of 4
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DEFENDANT OTTO TRUCKING LLC’S NOTICE TO JOIN SUR-REPLY TO MOTION TO COMPEL FILED BY UBER TECHNOLOGIES,

INC. AND OTTOMOTTO LLC (CASE NO. 3:17-CV-00939-WHA) 

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CERTIFICATE OF SERVICE 

I hereby certify that I electronically filed the foregoing with the Clerk of the Court for the 

United States District Court for the Northern District of California by using the CM/ECF system on 

May 19, 2017. I further certify that all participants in the case are registered CM/ECF users and that 

service will be accomplished by the CM/ECF system.

I certify under penalty of perjury that the foregoing is true and correct. 

Executed May 19, 2017. 

/s/ Neel Chatterjee 

Neel Chatterjee 

Case 3:17-cv-00939-WHA Document 478 Filed 05/19/17 Page 4 of 4