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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 

RUDY Y. KIM (CA SBN 199426) 

RKim@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

SUPPLEMENTAL DECLARATION OF 

JAMES HASLIM IN SUPPORT OF 

DEFENDANTS’ SUR-REPLY 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

REDACTED VERSION OF DOCUMENT SUBMITTED UNDER SEAL 

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I, James Haslim, declare as follows: 

1. I am a Senior Manager, Engineering for the Advanced Technologies Group at 

Uber Technologies, Inc. (“Uber”) as of January 2017. I understand that Waymo has filed a 

lawsuit against Uber, Ottomotto LLC (“Otto”) and Otto Trucking LLC in the U.S. District Court 

for the Northern District of California. I submit this supplemental declaration in support of 

Defendants’ Sur-Reply to Waymo LLC’s (“Waymo”) Motion for Preliminary Injunction. I have 

personal knowledge of the facts set forth in this declaration and, if called to testify as a witness, 

could and would do so competently. 

The Spider Project 

2. As stated in my original declaration, I joined Otto in May 2016 as Senior 

Mechanical Engineer and LiDAR lead, after Otto completed its acquisition of Tyto LIDAR LLC 

(“Tyto”). I was tasked with leading the team at Otto in developing a light detecting and ranging 

(LiDAR) solution for autonomous trucks. Shortly after I joined Otto, my team began working on 

a fiber-based LiDAR project intended for autonomous trucks. This project was known as the 

“Spider” project. The Spider project sought to leverage a pre-existing LiDAR sensor (known as 

“Owl”) that had been developed at Tyto beginning in 2012. Tyto’s Owl device was a mapping 

LiDAR sensor that used a single fiber laser. The Spider project was never completed and my 

team abandoned the Spider project to work on a very different LiDAR design (called “Fuji”) in 

late October 2016. Prior to abandoning the Spider project, we built a few components for testing 

purposes, but we never completely assembled these parts, and we never built all of the 

components needed for functional prototype, much less a complete LiDAR device. Thus, Spider 

was never made, used, sold, offered for sale, or imported, and there are no plans to revive the 

abandoned Spider project. 

3. The design concept for the Spider project was a LiDAR sensor with eight optical 

cavities, eight fiber lasers having a wavelength of approximately 1550 nanometers, and sixteen 

optical lenses (with each optical cavity having two optical lenses). The Spider design was 

intended to emit 3.2 million points or beams per second. Figure 1A and 1B, below, are true and 

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correct computer aided design (CAD) drawings of the Spider design. Figure 1A shows a 

perspective view of the design, and Figure 1B shows a top view of the design: 

Figure 1.A Figure 1.B 

4. After Uber acquired Otto in August 2016, I continued to lead my team’s efforts on 

the Spider project until we pivoted to the Fuji project in late October 2016. Although Spider was 

intended to have eight optical cavities, our team only built a single optical cavity for testing 

purposes before the Spider project was abandoned. Figure 2.A, below is a true and correct photo 

of the test Spider optical cavity. Figure 2.B, below, is a true and correct annotated CAD drawing 

of a cross-sectional side view of an optical cavity design for Spider. 

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Figure 2.A Figure 2.B 

5. The Spider design included eight fiber lasers, each of which was split into eight 

“transmit fibers” to create a total of 64 transmit channels. Each cavity had eight transmit fibers—

a single transmit fiber from each of the eight fiber lasers. Spider did not use any printed circuit 

boards (PCB) for positioning transmit fibers within a cavity. Rather, the transmit fibers were 

mounted into ceramic sleeves or ferrules which were bonded into holes drilled through a metal 

plate. Each cavity also had a flat mirror with a large hole to allow the light emitted from the 

transmit fibers to travel straight through the hole in the mirror, through two separate collimating 

lenses (an interior lens and an exterior lens) and into the environment. 

6. Each optical cavity had two optical lenses. Figures 3.A and 3.B show true and 

correct schematics of the two optical lenses for each Spider cavity. Figure 3.A shows the 

schematic of the interior lens, i.e., the lens closest to the transmit fibers, and Figure 3.B shows the 

schematic of the exterior lens, i.e., farthest from the transmit fibers. The two lenses work together 

to provide collimation of the light emitted from the transmit fibers into the environment and to 

focus the target-reflected light to the detectors. 

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Figure 3.A Figure 3.B 

7. The eight fiber lasers in the Spider design were fiber MOPA lasers. MOPA stands 

for master oscillator power amplifier and refers to a configuration consisting of a master laser 

(also known as a seed laser) that generates a low power version of the desired pulse signal and an 

optical amplifier to boost the output power of this pulse signal. A fiber MOPA laser refers to a 

MOPA laser that uses a fiber amplifier. The Spider design included 

 for its fiber lasers to obtain the power levels necessary for use as emitters in a LiDAR 

sensor. This is a well-known technique to amplify the output power of a fiber laser.1 The Spider 

design included 

, which is a commercially 

available fiber purchased from iXBlue.2 Figure 4 below is a screenshot of iXBlue’s website, 

 

1 See, e.g., RP Photonics, Fiber Amplifiers, https://www.rpphotonics.com/tutorial_fiber_amplifiers10.html; Grzegorz Sobon et al., Controlling the 1 μm 

spontaneous emission in Er/Yb co-doped fiber amplifiers, 19 Optics Express 19106 (2011), 

available athttps://www.osapublishing.org/DirectPDFAccess/FBA42477-936E-A370-

B8E0FD26AF56013C_222547/oe-19-20-19104.pdf?da=1&id=222547&seq=0&mobile=no ; 

Clémence Jollivet et al., Specialty Fiber: Multiple Applications Benefit from Advances in HighPerformance Er:Yb Co-Doped Double-Clad Fiber, Laser Focus World (Sept. 14, 2016), 

http://www.laserfocusworld.com/articles/print/volume-52/issue-09/features/specialty-fibermultiple-applications-benefit-from-advances-in-high-performance-er-yb-co-doped-double-cladfiber.html. 

2 See, e.g., iXBlue, Specialty Fibers: Active Fibers: Erbium / Ytterbium Double Clad Doped 

Fibers, https://photonics.ixblue.com/products-list-detail/erbium-ytterbium-double-clad-dopedfibers; Newport, Erbium & Ytterbium Co-Doped Fibers, https://www.newport.com/f/erbium-&-

ytterbium-doped-fibers; Fibercore, Erbium Doped Fiber IsoGainTM, http://fibercore.com/product/erbium-doped-fiber-isogain.

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

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which discloses that its Erbium Ytterbium double clad doped fiber is an ideal component for a 

“high power laser” (i.e., “1550 nm band”) and lists “LIDAR” as an intended application for this 

fiber. 

Figure 4 

8. As mentioned above, we abandoned the Spider project before we completed a 

prototype device. Spider was designed to have eight optical cavities, but we had only built one 

optical cavity for testing purposes, and never mounted that single test optical cavity onto the 

rotating base. For the one test optical cavity that we built, we were unable to place the transmit 

fibers accurately enough to align the eight transmit fibers to the eight photodetectors. 

9. My team worked on the Spider project until late October 2016. Spider proved to 

be undesirable and was abandoned because of the complexities of the design, the anticipated 

difficulty of scaling the manufacturing of the design, and its large size, heavy weight, and high 

power requirement. As designed, Spider would likely have weighed approximately 165 pounds, 

which would have been about six times heavier than a Velodyne HDL-64. While the large size 

and heavy weight of the Spider design was less of a consideration for a semi-truck, the weight of 

Spider design, along with the additional components that would have been required to mount a 

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

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completed Spider onto the roof of a passenger vehicle, would have likely exceeded the rated 

payload of the roof of a Volvo XC90 (220 pounds). 

10. The LiDAR team’s decision to abandon Spider and pivot to Fuji was made by the 

engineering team and was based on design considerations. When I met Scott Boehmke and Eric 

Meyhofer in October 2016 to discuss my team’s work on Spider, we concluded that the Spider 

design would be undesirable for use in Uber’s vehicles because of the reasons explained above 

(i.e., the complexity of the design, anticipated difficulty with scaling, and its large size, heavy 

weight, and high power requirement). Anthony Levandowski did not direct the LiDAR team to 

pivot from Spider to Fuji, but instead deferred to the engineers on the LiDAR team’s 

recommendation and judgment to pursue a bistatic, diode-based LiDAR design. Exhibit A, 

attached hereto, is an email exchange between Eric Meyhofer, Scott Boehmke, Dan Gruver, and 

me regarding the feasibility of pivoting from (i.e., Spider) to (i.e., a new diode-based 

design, which became Fuji).3

 In this email, Eric Meyhofer stated that he had spoken with 

Anthony and had promised Anthony that the team would 

 As I had explained during my deposition, I did not even know if 

Anthony was aware that Eric, Scott and I had already committed to pivoting from Spider to Fuji 

when I announced the pivot to the rest of the LiDAR team on October 28, 2016 in San Francisco.4 

The LiDAR team’s decision to abandon the Spider project to work on Fuji was based on the 

aforementioned design considerations and was not at the instructions of Uber’s legal team or due 

to any legal issues. 

The Fuji Device 

11. As I explained in my earlier declaration, Fuji is a LiDAR sensor having two 

optical cavities each with 32 channels oriented at different vertical angles to capture the field of 

view necessary for applications in self-driving cars. Specifically, Fuji has a total vertical field of 

 

3

 A true and correct copy of this document was provided to Waymo as UBER00008592 and was 

introduced and designated by Waymo as Exhibit 62 in my April 18, 2017 deposition in this case. 

4 See Haslim Dep. 88:6-21, April 18, 2017. A true and correct excerpt of this section of my 

deposition is attached as Exhibit B to this declaration. 

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view of 30.23 degrees, from -22.0 degrees to 8.23 degrees. Each cavity has a separate transmit 

lens and receive lens. The transmit lens has a focal length of 150 mm. Figures 5.A and 5.B, 

below, are a true and correct photos of Fuji as of March 2017. As Figures 5.A and 5.B show, the 

two optical cavities are mounted on a rotating base that spins the optical cavities to capture a 360 

degree horizontal field of view. The rotating base includes a stationary portion that will couple to 

the roof of a vehicle. As I had also stated in my earlier declaration, no Fuji device has ever been 

mounted on any vehicle for testing. Above the optical cavities is the timing board, which 

measures the time between transmitted pulses and received target-reflected pulses. The yellow 

cable in the Figures 5.A. and 5.B is a commercially available 

.

5

 

Figure 5.A Figure 5.B 

12. There are transmit printed circuit boards (PCBs) within each cavity in Fuji. 

Each channel represents light from a single laser diode, and the 32 laser diodes are distributed 

over . As I had explained in my prior declaration, I came up with the idea of 

 

5 See, e.g., Princetel, FORJ: Miniature fiber rotary joints (MicroJx Series), http://princetel.com/forj_mjx.asp. 

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The document excerpted above clearly shows that we independently came up with the idea to use 

 and in two optical cavities Scott created this 

document after the LiDAR team realized that 32 laser diodes would need to be distributed across 

 boards to provide sufficient spacing. I communicated this to Scott, who then calculated 

beam spacing and angles for Fuji using the assumptions of distributed 64 beams in two cavities 

with boards per cavity, which is reflected in the above document. 

14. As I mentioned in my earlier declaration, Fuji uses commercially available edgeemitting laser diodes. A known technique of mounting laser diodes onto PCBs is to die attach 

and wire bond the laser diodes that are integrated into the PCBs. As I explained in 

my earlier declaration, the transmit PCBs are mounted onto the transmit block using two 

dowel pins that go through the mounting holes in each PCB. I understand that Waymo alleges in 

its reply brief that Uber uses both dowel pins and fiducials to position laser diodes. This is 

incorrect. As I had stated in my earlier declaration and again at my deposition, the mounting 

holes and dowel pins in Fuji are not used as reference points from which we position the laser 

diodes on any of the transmit boards.8

 

15. As I mentioned in my earlier declaration, Fuji uses commercially available laser 

diodes that emit light with a wavelength of approximately 905 nm. It is publicly well known that 

a fast axis collimating (“FAC”) lens can be used to pre-collimate the light emitted from a laser 

diode in order to focus and redirect the light towards a transmit lens.9

 I understand that although 

Waymo has not raised any arguments in its opening or reply briefs about Uber’s FAC lens, I also 

understand that Waymo’s expert has discussed this commonly used component in his reply 

declaration. Figure 12.A illustrates a true and accurate 3-D rendering of the FAC lens used in 

Fuji. 

. Figure 12.B illustrates a 

 

8 See Haslim Dep. 64:24-65:10. A true and correct excerpt of this section of my declaration is 

attached as Exhibit B to this declaration. 

9 See Hamamatsu, FAC Lens (Fast-Axis Collimating Lens) J10919 Series, available at 

https://www.hamamatsu.com/resources/pdf/etd/J10919_TOTH1005E.pdf. 

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true and accurate Zemax simulation of the beam output from Fuji’s FAC lens. As shown in 

Figure 12.B, the FAC lens pre-collimates the light emitted from the laser diode such that 

 Figure 7.A Figure 7.B 

Beam Spacing in Fuji 

16. I understand that in its reply brief, Waymo contends that there is no evidence to 

support the fact that Uber independently developed Fuji, and its transmit boards, based on the 

work Uber had started in late October 2016. As I discussed in my earlier declaration, the position 

and orientation of the laser diodes in Fuji is based on the custom beam spacing and angle 

summary provided by Scott Boehmke in November 2016, which I included as Exhibit E in my 

earlier declaration. This summary provided the required beam angles for a 64 channel LiDAR 

with two cavities and boards per cavity, on a vehicle traveling at 30 mph, 35 mph, 40 mph, 

and 45 mph. As I had previously explained, the current Fuji design is based on the beam angles 

for a vehicle traveling up to approximately 35mph. My team imported the angles in this summary 

into Zemax, a commonly known ray tracing simulation software program, to determine the 

resultant emitting points of the laser diodes. This data was then exported into SolidWorks CAD 

software as the basis for the initial optical cavity designs and transmit PCB designs.10

17. Figure 8.A is a true and correct annotated excerpt of the initial Fuji beam angles, 

and the difference or “delta” between each angle, for what I had previously referred to in my 

 

10 True and correct CAD drawings of the optical cavity and transmit PCBs are disclosed as 

Figures 2A-B and 6A-F in my original declaration. 

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there is an additional downwards tilt of 12 degrees in the “medium-ranged” cavity containing 

transmit boards the theta for transmit boards must also be adjusted by 12 degrees. For 

example, 

. As the chart below confirms, there is no more than a 0.06 

degree difference between initial Fuji beam angles in the November 16 document provided by 

Scott and the beam angles in the transmit boards in Fuji’s “medium-range” cavity. 

18. Below is a chart comparing the initial beam angles for the “long-range” cavity 

provided by Scott in his November 2016 document (illustrated above in annotated Figure 13.B) 

with the angular orientation of the diodes in transmit boards previously provided in Exhibit 

E of my earlier declaration. Referring to transmit boards , the theta represents the angular 

orientation of the diodes relative to the central axis through the transmit board. Originally, Scott 

had provided diode angles which contemplated overlapping one beam in the long-range cavity 

with one beam in the medium-range cavity to compensate for any gaps in beam spacing that 

might arise due to manufacturing tolerances. I, however, believed that we could control the 

manufacturing tolerances such that we would not have to overlap beams (and effectively waste an 

entire channel), and accordingly shifted his proposed beam spacing. As the shown in the chart 

below, there is a consistent 0.18 to 0.24 degree shift between Scott’s initial proposed beam angles 

and the beam angles in the transmit boards in Fuji’s “long-range” cavity. 

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Comparison between Spider and Fuji 

19. Below is a comparison of design specifications of the proposed Spider design and 

the Fuji device. 

Spider Fuji 

Type of Laser Fiber lasers Direct diode lasers 

# of Channels 64 64 

# of Cavities 8 2 

# of transmit PCBs per 

cavity 

None 

# & Type of Transmit 

and Receive Lens 

Total: 16 lenses total 

Per cavity: 2 lens that both 

transmit and receive 

Total: 4 

Per cavity: 1 lens for transmit 

and 1 lens for receive11

Pre-collimation Lens 

(i.e. FAC lens) 

None 64 FAC lenses, one per diode 

# & Type of Mirrors One flat mirror with a hole None 

Weight 75 kg 

(approximately 165 lbs) 

Maximum of 20 kg 

(approximately 44 lbs) 

Beams or Points per 

second 

3.2 million 1.5 million 

Inspection of Spider Components

20. On Friday, April 14, 2017 and Monday, April 17, 2017, I oversaw the collection of 

existing components associated with the abandoned Spider project for Waymo’s inspection on 

Wednesday, April 19, 2017. Esther Kim Chang of Morrison Foerster and Aaron Bergstrom of 

Uber assisted in this process. 

 

11 Not including the field flattening lens in the receive compartment within a cavity. 

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