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

01980-00104/9069764.1

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

DECLARATION OF JORDAN R. JAFFE

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 JORDAN R. JAFFE 

REDACTED VERSION OF DOCUMENT 

SOUGHT TO BE SEALED 

Hearing: 

Date: April 27, 2017 

Time: 8:00 a.m. 

Place: 8, 19th Floor 

Judge: The Honorable William H. Alsup

 
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

01980-00104/9069764.1

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

DECLARATION OF JORDAN R. JAFFE

I, Jordan R. Jaffe, hereby declares as follows. 

1. I a member of the bar of the State of California and a partner with Quinn Emanuel 

Urquhart & Sullivan, LLP, counsel for Plaintiff Waymo LLC (“Waymo”). I make this declaration 

of personal, firsthand knowledge, and if called and sworn as a witness, I could and would testify 

competently as follows. 

2. Attached hereto as Exhibit 1 is Plaintiff’s List of Asserted Trade Secrets, submitted 

pursuant to Cal. Civ. Code Proc. Section 2019.210. 

3. Attached hereto as Exhibit 2 is a true and correct copy of a Waymo document titled 

.” 

4. Attached hereto as Exhibit 3 is a true and correct copy of a Waymo document titled 

” 

5. Attached hereto as Exhibit 4 is a true and correct copy of a Waymo spreadsheet 

titled “ ” 

6. Attached hereto as Exhibit 5 is a true and correct copy of a Waymo spreadsheet 

titled “ ” 

7. Attached hereto as Exhibit 6 is a true and correct copy of a Waymo document titled 

“ .” 

8. Attached hereto as Exhibit 7 is a true and correct copy of a Waymo document titled 

” 

9. Attached hereto as Exhibit 8 is a true and correct copy of a Waymo document titled 

” 

10. Attached hereto as Exhibit 9 is a true and correct copy of a Waymo document titled 

” 

11. Attached hereto as Exhibit 10 is a true and correct copy of a Waymo document 

titled ” 

12. Attached hereto as Exhibit 11 is a true and correct copy of a Waymo document 

titled Initial assessment.” 
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

01980-00104/9069764.1

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

DECLARATION OF JORDAN R. JAFFE

13. Attached hereto as Exhibit 12 is a true and correct copy of a Waymo document 

titled “ Assembly Flowchart: Standard Operating Procedure.” 

14. Attached hereto as Exhibit 13 is a true and correct copy of a Waymo document 

titled Testing Station.” 

15. Attached hereto as Exhibit 14 is a true and correct copy of a Waymo document 

titled “Chauffeur Weekly Updates.” 

16. Attached hereto as Exhibit 15 is a true and correct copy of a Waymo document 

titled “ tuning instructions.” 

17. Attached hereto as Exhibit 16 is a true and correct copy of a Waymo document 

titled Intensity Calibration.” 

18. Attached hereto as Exhibit 17 is a true and correct copy of a Waymo document 

titled “ Extrinsic Calibration.” 

19. Attached hereto as Exhibit 18 is a true and correct copy of a Waymo document 

titled “ ” 

20. Attached hereto as Exhibit 19 is a true and correct copy of a Waymo document 

titled “Die Wire Bonding.” 

21. Attached hereto as Exhibit 20 is a true and correct copy of a Waymo document 

titled “External Vendors and Consultants List.” 

22. Attached hereto as Exhibit 21 is a true and correct copy of a Waymo document 

titled “Automation Vendors.” 

23. Attached hereto as Exhibit 22 is a true and correct copy of a blog post titled “What 

we’re driving at,” dated October 9, 2010, and downloaded from 

http://googleblog.blogspot.com/2010/10/what-were-driving-at.html on March 8, 2017. 

24. Attached hereto as Exhibit 23 is a true and correct copy of an article titled “Public 

Records Suggest One Company is Dominating the Self-Driving Cars Race,” dated December 13, 

2016, and downloaded from https://www.forbes.com/sites/alanohnsman/2016/12/13/googlesspins-off-self-driving-car-unit-as-waymo/#16059f0433b9 on March 8, 2017. 
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

01980-00104/9069764.1

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

DECLARATION OF JORDAN R. JAFFE

25. Attached hereto as Exhibit 24 is a true and correct copy of an article titled “Google 

Spins Off Self-Driving Car Unit As ‘Waymo,’” dated March 10, 2016, and downloaded from 

http://www.theatlantic.com/technology/archive/2016/03/beep-beep/473142/ on March 8, 2017. 

26. Attached hereto as Exhibit 25 is a true and correct copy of an article titled “Google 

Parent Company Spins Off Self-Driving Car Business,” dated December 13, 2016, and 

downloaded from http://www.nytimes.com/2016/12/13/technology/google-parent-company-spinsoff-waymo-self-driving-car-business.html on March 8, 2017. 

27. Attached hereto as Exhibit 26 is a true and correct copy of a blog post titled “Just 

press go: designing a self-driving vehicle,” dated May 27, 2014, and downloaded from 

http://googleblog.blogspot.com/2014/05/just-press-go-designing-self-driving.html on March 8, 

2017. 

28. Attached hereto as Exhibit 27 is a true and correct copy of an article titled “Google 

made a self-driving car, and it doesn’t have a steering wheel,” dated May 27, 2014, and 

downloaded from http://www.theverge.com/2014/5/27/5756436/this-is-googles-own-self-drivingcar on March 8, 2017. 

29. Attached hereto as Exhibit 28 is a true and correct copy of an article titled 

“Google’s Self-Driving Car Hits Roads Next Month – Without a Wheel or Pedals,” dated 

December 23, 2014, and downloaded from http://www.wired.com/2014/12/google-self-drivingcar-prototype-2/ on March 8, 2017. 

30. Attached hereto as Exhibit 29 is a true and correct copy of an article titled 

“Google’s adorable self-driving cars are now on public roads,” dated June 25, 2015, and 

downloaded from http://www.theverge.com/2015/6/25/8846617/google-self-driving-car-publicroads-mountain-view on March 8, 2017. 

31. Attached hereto as Exhibit 30 is a true and correct copy of an article titled 

“Google’s Self-Driving Car Prototypes Hit Public roads for the First Time,” dated June 25, 2015, 

and downloaded from http://www.nbcnews.com/tech/innovation/googles-self-driving-carprototypes-hit-public-roads-first-time-n381941 on March 8, 2017. 
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

01980-00104/9069764.1

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

DECLARATION OF JORDAN R. JAFFE

32. Attached hereto as Exhibit 31 is a true and correct copy of an article titled “Google 

launches Waymo and moves closer to self-driving cars,” dated December 13, 2016, and 

downloaded from http://money.cnn.com/2016/12/13/technology/google-waymo/ on March 8, 

2017. 

33. Attached hereto as Exhibit 32 is a true and correct copy of an article titled “Google 

Spin-off Waymo Set to Become Full-Fledged Automated Driving Provider,” dated January 8, 

2017, and downloaded from http://www.forbes.com/sites/samabuelsamid/2017/01/08/google-spinoff-waymo-set-to-become-full-fledged-automated-driving-provder/print/ on March 8, 2017. 

34. Attached hereto as Exhibit 33 is a true and correct copy of a blog post titled 

“Reliving the past: how these data centers drive us three million miles each day,” dated December 

13, 2016, and downloaded from https://medium.com/waymo/reliving-the-past-how-these-datacenters-drive-us-three-million-miles-each-day-49a8695e8c75#.h6c9h62qh on March 8, 2017. 

35. Attached hereto as Exhibit 34 is a true and correct copy of an article titled “Waymo 

Reveals the Tech Inside Its Self-Driving Chrysler Minivans,” dated January 8, 2017, and 

downloaded from http://fortune.com/2017/01/08/waymo-detroit-future/ on March 8, 2017. 

36. Attached hereto as Exhibit 35 is a true and correct copy an article titled “Travis 

Kalanick on Uber’s bet on self-driving cars, ‘I can’t be wrong,’” dated August 18, 2016, and 

downloaded from http://www.businessinsider.com/travis-kalanick-interview-on-self-driving-carsfuture-driver-jobs-2016-8 on March 8, 2017. 

37. Attached hereto as Exhibit 36 is a true and correct copy of an article titled “Uber 

gutted Carnegie Mellon’s top robotics lab to build self-driving cars,” dated May 19, 2015, and 

downloaded from http://www.theverge.com/transportation/2015/5/19/8622831/uber-self-drivingcars-carnegie-mellon-poached on March 8, 2017. 

38. Attached hereto as Exhibit 37 is a true and correct copy of an article titled “After a 

year, Carnegie Mellon and Uber research initiative is stalled,” dated March 21, 2016, and 

downloaded from http://www.reuters.com/article/us-uber-tech-research-idUSKCN0WN0WR on 

March 8, 2017. 
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

01980-00104/9069764.1

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

DECLARATION OF JORDAN R. JAFFE

39. Attached hereto as Exhibit 38 is a true and correct copy of Velodyne’s product 

information page for the Velodyne HDL-64E, downloaded from http://velodynelidar.com/hdl64e.html on March 8, 2017. 

40. Attached hereto as Exhibit 39 is a true and correct copy of an article titled “Uber set 

to offer driverless rides here” dated August 19, 2016, and downloaded from http://www.postgazette.com/business/tech-news/2016/08/18/Uber-to-use-self-driving-cars-in-Pittsburgh-to-haulpeople-in-next-few-weeks/stories/201608180155 on March 8, 2017. 

41. Attached hereto as Exhibit 40 is a true and correct copy of the “Whois Record” for 

“280Systems.com,” downloaded from http://whois.domaintools.com/280systems.com on March 

10, 2017. 

42. Attached hereto as Exhibit 41 is a true and correct copy of the Delaware “Division 

of Corporations - Filing” record for “OttoMotto LLC” downloaded from 

http://icis.corp.delaware.gov/Ecorp/EntitySearch/NameSearch.aspx on March 10, 2017. 

43. Attached hereto as Exhibit 42 is a true and correct copy of the Delaware “Division 

of Corporations - Filing” record for “Otto Trucking LLC” downloaded from 

http://icis.corp.delaware.gov/Ecorp/EntitySearch/NameSearch.aspx on March 10, 2017. 

44. Attached hereto as Exhibit 43 is a true and correct copy an article titled “Uber’s 

First Self-Driving Fleet Arrives in Pittsburgh This Month,” dated August 18, 2016, and 

downloaded from http://www.bloomberg.com/news/features/2016-08-18/uber-s-first-self-drivingfleet-arrives-in-pittsburgh-this-month-is06r7on on March 8, 2017. 

45. Attached hereto as Exhibit 44 is a true and correct copy an article titled “Uber 

Acquiring Otto Could Be the Lead Domino: Autonomous Vehicles to Spur M&A Activity,” dated 

August 24, 2016, and downloaded from 

http://www.forbes.com/sites/sarwantsingh/2016/08/24/uber-acquiring-otto-could-be-the-leaddomino-autonomous-vehicles-to-spur-ma-activity/print/ on March 8, 2017. 

46. Attached hereto as Exhibit 45 is a true and correct copy of blog post titled 

“Rethinking transportation,” dated August 18, 2016, and downloaded from 

http://newsroom.uber.com/rethinking-transportation/ on March 8, 2017. 
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

01980-00104/9069764.1

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

DECLARATION OF JORDAN R. JAFFE

47. Attached hereto as Exhibit 46 is a true and correct copy an article titled “The Truth 

About Uber’s Otto Deal,” dated December 2, 2016, and downloaded from 

http://www.theinformation.com/the-truth-about-ubers-otto-deal on February 21, 2017. 

48. Attached hereto as Exhibit 47 is a true and correct copy an article titled “The man 

who invented the first self-driving motorcycle is leading Uber into the future,” dated December 

13, 2016, and downloaded from http://www.businessinsider.com/anthony-levandowski-uberinterview-2016-12 on March 8, 2017. 

49. Exhibit 48 has been intentionally left blank. 

50. Exhibit 49 has been intentionally left blank. 

51. Exhibit 50 has been intentionally left blank. 

52. Attached hereto as Exhibit 51 is a true and correct copy of letter from Margaret A. 

McLetchie to the Nevada Governor’s Office of Economic Development and the Department of 

Motor Vehicles, subject “PUBLIC RECORDS REQUEST – IMMEDIATE ACTION 

REQUIRED,” dated February 3, 2017. 

53. Attached hereto as Exhibit 52 is a true and correct copy of a document entitled 

“Autonomous Technology Certification Facility License,” dated September 15, 2016. 

54. Attached hereto as Exhibit 53 is a true and correct copy an article titled “Meet the 

Former Google Engineer Who Allegedly Stole Trade Secrets For Uber,” dated February 23, 2017, 

and downloaded from https://www.forbes.com/sites/briansolomon/2017/02/23/meet-the-formergoogle-engineer-who-allegedly-stole-secrets-for-uber-anthony-levandowski/#352876d5c5ea on 

March 10, 2017. 

55. Attached hereto as Exhibit 54 is a true and correct copy an article titled “Tesla’s 

Getting More Competition in Self-Driving Cars,” dated February 23, 2017, and downloaded from 

http://www.barrons.com/articles/teslas-getting-more-competition-in-self-driving-cars-1487022122 

on March 10, 2017. 

56. Attached hereto as Exhibit 55 is a true and correct copy an article titled “Apple 

confirms it is working on self-driving cars,” dated December 4, 2016, and downloaded from 
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

01980-00104/9069764.1

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

DECLARATION OF JORDAN R. JAFFE

https://www.theguardian.com/technology/2016/dec/04/apple-confirms-it-is-working-on-selfdriving-cars on March 10, 2017. 

57. Attached hereto as Exhibit 56 is a true and correct copy an article titled “Taking a 

ride in Nvidia’s self-driving car,” dated January 7, 2017, and downloaded from 

https://arstechnica.com/cars/2017/01/nvidia-audi-bb8-self-driving-car/ on March 10, 2017. 

58. Attached hereto as Exhibit 57 is a true and correct copy of a February 23, 2017, 

Bloomberg Technology article titled “Alphabet’s Waymo Alleges Uber Stole Self-Driving 

Secrets” by Mark Bergen and Kartikay Mehrotra, available at 

https://www.bloomberg.com/news/articles/2017-02-23/alphabet-s-waymo-sues-uber-for-stealingself-driving-patents. 

59. Attached hereto as Exhibit 58 is a true and correct copy of a February 24, 2017, 

Business Insider article titled “Uber denies Google’s claims of stolen self-driving tech” by Steve 

Kovach, available at http://www.businessinsider.com/uber-shoots-down-googles-claims-of-stolenself-driving-tech-2017-2. 

60. Attached hereto as Exhibit 59 is a true and correct copy of an April 8, 2013, order 

in GSI Tech., Inc. v. United Memories, Inc., Case No. 5:13-cv-01081-PSG (N.D. Cal. filed March

8, 2013). 

61. Attached hereto as Exhibit 60 is a true and correct copy of Plaintiff’ NobelBiz, 

Inc.’s First Set of Requests for Production of Documents and Other Tangible Things to Defendant 

Jeff L. Wesson, filed as Exhibit A to the Declaration of Mark A. Konkel. These expedited 

discovery requests were at issue in NobelBiz Inc. v. Wesson, No. 14cv0832 W(JLB), 2014 WL 

1588715 (S.D. Cal. Apr. 18, 2014). 

I declare under penalty of perjury under the laws of the State of California that the 

foregoing is true and correct. 

DATED: March 10, 2017 /s Jordan R. Jaffe

Jordan R. Jaffe