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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 

DISCOVERY LETTER BRIEF 

REGARDING MOTION TO COMPEL 

ADDITIONAL DEPOSITION OF 

PIERRE-YVES DROZ AND EXHIBITS 

THERETO

Case 3:17-cv-00939-WHA Document 1180 Filed 08/14/17 Page 1 of 3
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-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 Discovery Letter Brief 

Regarding Motion to Compel Additional Deposition of Pierre-Yves Droz and Exhibits Thereto (the 

“Administrative Motion”). The Administrative Motion seeks an order sealing highlighted portions of 

Uber’s Discovery Letter Brief Regarding Motion to Compel Additional Deposition of Pierre-Yves 

Droz (“Uber’s Motion”) and of Exhibit 4 thereto, as well as the entirety of Exhibits 1, 3, and 6 thereto. 

3. The portions of Uber’s Motion marked in red boxes and the green highlighted portions 

of Exhibits 1, 3, and 6 contain or refer to trade secret and confidential business information, which 

Waymo seeks to seal. 

4. Uber’s Motion (portions marked in red boxes in version filed herewith) and Exhibits 1 

and 6 (green highlighted portions in versions filed herewith) contain, reference, and/or describe 

Waymo’s asserted trade secrets. 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 

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

significantly harmed. 

5. Exhibit 3 (green highlighted portions in version filed herewith) further contains, 

references, and/or describes Waymo’s highly confidential and sensitive business information. Such 

information includes details regarding Waymo’s security measures and protocols and detailed 

computer forensics regarding access to Waymo’s trade secrets. I understand that Waymo maintains 

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

CORREDOR DECLARATION ISO DEFENDANTS’ ADMINISTRATIVE MOTION TO SEAL

that this information as confidential. The public disclosure of this information would cause significant 

competitive harm to Waymo, as its security measures and computer forensics methods would become 

known to competitors who could use such information to Waymo’s disadvantage. 

6. Waymo’s request to seal is narrowly tailored to those portions of Uber’s Motion and 

Exhibits 1, 3, and 6 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 August 14, 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 1180 Filed 08/14/17 Page 3 of 3