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ACTIVE/91712536.1

HYDE DECLARATION ISO WAYMO'S ADMINISTRATIVE MOTION TO FILE UNDER 

SEAL CASE NO. 3:17-CV-00939 

Neel Chatterjee (SBN 173985)

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 (SBN 189247) 

bschuman@goodwinlaw.com 

Shane Brun (SBN 179079) 

sbrun@goodwinlaw.com 

Rachel M. Walsh (SBN 250568) 

rwalsh@goodwinlaw.com 

Hayes P. Hyde (SBN 308031) 

hhyde@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.; Ottomotto LLC; Otto 

Trucking LLC, 

Defendants. 

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

DECLARATION OF HAYES HYDE IN 

SUPPORT OF PLAINTIFF'S 

ADMINISTRATIVE MOTION TO FILE 

UNDER SEAL PORTIONS OF ITS 

DISCOVERY LETTER BRIEF IN 

SUPPORT OF WAYMO’S MOTION TO 

COMPEL 

Case 3:17-cv-00939-WHA Document 740 Filed 06/26/17 Page 1 of 4
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ACTIVE/91712536.1 1

HYDE DECLARATION ISO WAYMO'S ADMINISTRATIVE MOTION TO FILE UNDER 

SEAL CASE NO. 3:17-CV-00939 

I, Hayes Hyde, declare as follows: 

1. I am an attorney at the law firm of Goodwin Procter, LLP. I make this declaration 

based upon matters within my own personal knowledge and if called as a witness, I could and 

would competently testify to the matters set forth herein. I make this declaration in support of 

Plaintiff’s Administrative Motion to File Under Seal Portions of Its Discovery Letter Brief in 

Support of Waymo’s Motion to Compel (Dkt. 681). 

2. I have reviewed the following documents and confirmed that only the portions 

identified below merit sealing: 

Document Portions to Be Filed Under Seal 

Portions of Waymo’s Letter Brief Highlighted Portions 

Exhibit 1 to the Letter Brief Entire Documents 

Exhibit 7 to the Letter Brief Entire Documents 

3. The highlighted portions of the Letter Brief include highly confidential, sensitive 

business information relating to the terms of Otto Trucking’s agreements and corporate structure, 

that is not publicly known, and this information’s confidentiality is strictly maintained. I 

understand that this information could be used by competitors to Otto Trucking’s detriment, 

including in the context of negotiating business deals. If such information were made public, I 

understand Otto Trucking’s competitive standing could be significantly harmed. 

4. The entirety of Exhibit 1 contains highly confidential sensitive business 

information of Otto Trucking relating to terms of Otto Trucking’s agreements. This information is 

not publicly known, and its confidentiality is strictly maintained. I understand that this information 

could be used by competitors to Otto Trucking’s detriment, including in the context of negotiating 

business deals. If such information were made public, I understand Otto Trucking’s competitive 

standing could be significantly harmed. 

5. The entirety of Exhibit 7 contains personally identifiable information of a third 

party, and must therefore not be made public. 

6. I have reviewed the following document, served upon plaintiff Waymo as Exhibit 

A to this declaration, and state that further redaction is required. The portions highlighted in 

Case 3:17-cv-00939-WHA Document 740 Filed 06/26/17 Page 2 of 4
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ACTIVE/91712536.1 2

HYDE DECLARATION ISO WAYMO'S ADMINISTRATIVE MOTION TO FILE UNDER 

SEAL CASE NO. 3:17-CV-00939 

yellow were originally omitted in error. 

Document Portions to Be Filed Under Seal 

Exhibit 2 to the Letter Brief Portions highlighted in blue and yellow 

7. The highlighted portions of Exhibit 2 contain highly confidential sensitive business 

information of Otto Trucking relating to terms of Otto Trucking’s agreements. This information is 

not publicly known, and its confidentiality is strictly maintained. I understand that this information 

could be used by competitors to Otto Trucking’s detriment, including in the context of negotiating 

business deals. If such information were made public, I understand Otto Trucking’s competitive 

standing could be significantly harmed. 

8. Defendants’ request to seal is narrowly tailored to those portions of the Plaintiff’s 

Letter Brief and its supporting papers that merit sealing. 

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

true and correct. Executed this 26th day of June, 2017 in San Francisco, California. 

 /s/ Hayes P. Hyde 

 Hayes P. Hyde 

 

Case 3:17-cv-00939-WHA Document 740 Filed 06/26/17 Page 3 of 4
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ACTIVE/91712536.1 3

HYDE DECLARATION ISO WAYMO'S ADMINISTRATIVE MOTION TO FILE UNDER 

SEAL CASE NO. 3:17-CV-00939 

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 June 26, 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 this 26th 

day of June 2017. 

/s/ Hayes P. Hyde 

 Hayes P. Hyde 

Case 3:17-cv-00939-WHA Document 740 Filed 06/26/17 Page 4 of 4