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

DECLARATION OF PIERRE-YVES DROZ

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

DECLARATION OF PIERRE-YVES 

DROZ

REDACTED VERSION OF DOCUMENT 

SOUGHT TO BE SEALED

Case 3:17-cv-00939-WHA Document 24-3 Filed 03/10/17 Page 1 of 14
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-2- Case No. 3:17-cv-00939-WHA 

DECLARATION OF PIERRE-YVES DROZ

I, Pierre-Yves Droz, hereby declare as follows. 

1. I have been employed by Waymo LLC (“Waymo”), and before that, Google Inc. 

(“Google”) since October 2011. My current title is Principal Hardware Engineer, and I have been 

the technical lead on Waymo’s LiDAR project since its inception. I make this declaration in 

support of Waymo’s Motion for a Preliminary Injunction and have personal knowledge of the 

facts stated herein. 

2. I received a Masters degree in engineering from the Ecole Polytechnique in Paris, 

France in 2005, and a Masters degree in Electrical Engineering and Computer Science from the 

University of California, Berkeley in 2005. 

A. My Early Development of LiDAR Systems 

3. In 2006, I co-founded a company, along with Anthony Levandowski and Andrew 

Schultz, that was eventually called 510 Systems, LLC (“510 Systems”). I worked full time at 510 

Systems, and my role included, among other things, principal responsibility for research and 

development (analogous to the role a Chief Technology Officer would have at a larger company). 

Mr. Levandowski was leading the company on a part-time basis, providing input on major 

strategic decisions, with less involvement with day-to-day operations. 

4. In 2009, Project 

Chauffeur, the internal name of Google’s self-driving car project. 

. 

5. In April 2010, 510 Systems started developing an in-house LiDAR solution, as 

opposed to using purely third-party vendors, such as Velodyne. LiDAR stands for Light Detection 

And Ranging, and uses the principles of radar but using laser beams instead of radio waves: 

LiDAR shoots beams out into an environment, where objects reflect the beams back into the 

LiDAR, such that the LiDAR can measure the time it took for the laser beams to come back and 

figure out how far away an object is. I led our company’s efforts toward our in-house LiDAR 

solution, and by December 2010 we had a prototype 

: 

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

DECLARATION OF PIERRE-YVES DROZ

6.

 

7. In early summer 2011, 

. At the time, self-driving projects including Google’s 

used commercially available LiDAR systems from Velodyne. 

 

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

DECLARATION OF PIERRE-YVES DROZ

8. In July 2011, Google acquired 510 Systems, and I became a Google employee in 

October of that year. My initial role was technical lead of the LiDAR team, and I have maintained 

this role throughout my time at Google and now Waymo.1 The LiDAR team has grown 

consistently over the last five plus years, from 6 people when Google acquired 510 Systems to 

approximately people today. 

B. Development of Waymo’s LiDAR Systems

9. Designing and developing LiDAR systems is a difficult process. 

, early on, we realized that 

we would need different LiDAR designs for different ranges. 

10. In particular, for long ranges, 

. After 

 

1

 In this declaration, I use Google and Waymo interchangeably, understanding that the 

Chauffeur self-driving car project at Google became its own separate company, Waymo, late last 

year. 

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

DECLARATION OF PIERRE-YVES DROZ

driving hundreds of thousands of miles with this LiDAR, however, we discovered new selfdriving car scenarios that could not be satisfied with it. For example, 

. We thus iterated 

more designs , eventually settling on a version with a 360 degree field of view, which 

Waymo still uses on its self-driving fleet given the lack of viable alternatives for long-range 

LiDAR. 

11. , we also worked on 

developing a mid-range LiDAR. Beginning in early summer 2011, 

. After more than a year of hard work, 

however, this design proved not to be viable for use in self-driving cars. 

 

 

C. Waymo’s Innovative Mid-Range LiDAR Design 

12. Beginning in December 2012, 

. The design was made 

possible given all the know-how and technological capabilities my team had developed over 

several years of working on LiDAR systems, . In contrast to 

commercially available LiDAR systems, such as the Velodyne system originally used by 510 

Systems and previously Project Chauffeur, 

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

DECLARATION OF PIERRE-YVES DROZ

 

13. One of innovations was a design that, in part, used a single lens—rather than 

multiple sets of lenses—to both transmit and receive the collection of laser beams used to scan the 

surrounding environment. 

14. Traditionally, a LiDAR system used lens assemblies with multiple elements (such 

as 3 lens elements—or a triplet lens—for transmit side and another triplet lens for the receive 

side), but this approach was not practical in a LiDAR system meant for self-driving cars because 

the size and cost of the system would be very large due to the complexity of manufacturing 

numerous complex lens elements. Another option that Velodyne actually used was putting 

multiple singlet lenses next to each other. However, this required using two separate lenses for 

two separate sets of beams, thereby splitting the field of view of the LiDAR into two separate 

fields of view, slightly getting around the problem of handling multiple beams but not 

significantly decreasing the cost or size of the system. (Velodyne’s 64-beam LiDAR previously 

used by Google costs over $70,000, well above the cost of most cars.) 

15. A key insight we had at Waymo was that using one lens for both transmit and 

receiving is simpler and allows for a smaller and less expensive LiDAR unit. Using one lens 

better ensures that focal lengths are equal for both sending laser beams out (transmit side) and for 

receiving reflected light back (receive side) so that the transmit and receive arrays can match 

perfectly. If the two arrays don’t match, they would not line up and you would only be able to 

align a few channels, making all others channels useless for detection. Waymo first pioneered a 

single-lens design . While using a multiple-element lens in a LiDAR makes the focal plane 

flat like a pancake rather than curved like a bowl, complicating the optical layout, we developed 

Case 3:17-cv-00939-WHA Document 24-3 Filed 03/10/17 Page 6 of 14
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-7- Case No. 3:17-cv-00939-WHA 

DECLARATION OF PIERRE-YVES DROZ

many innovations to deal with the curved focal plane that allowed us to get the small-size and lowcost benefits of a single-lens system. 

16. I was one of the primary people who conceived and developed the single-lens 

design concept. This design greatly simplified the manufacturing process by eliminating the need 

to painstakingly align pairs of transmit and receive elements, with even a slight miscalibration 

would significantly affect the accuracy of the system. Waymo was awarded a patent on its design 

in 2014: United States Patent No. 8,836,922 (“the ‘922 patent”), entitled “Devices and Methods 

for a Rotating LiDAR Platform with a Shared Transmit/Receive Path.” I am a named inventor on 

this patent. My colleagues at the time, Anthony Levandowski, Gaetan Pennecot, and Daniel 

Gruver were among the other named co-inventors. I understand that all now are employed by 

Otto/Uber. 

D. Perfecting for Use in Self-Driving Cars 

17. With the goal of making this new design accurate and robust enough to use on selfdriving cars, Waymo’s LiDAR Team continued to invest resources into developing its LiDAR 

systems over several months. 

 Again, compared to off-the-shelf solutions, the 

design was groundbreaking. It dramatically reduced the cost and size of the 

LiDAR system while increasing resolution and performance for self-driving vehicles. To get to 

this point, it had taken us nearly two years from when we first set out to build a mid-range LiDAR 

accurate and robust enough to provide the data required for a car to drive itself and thus to replace 

the Velodyne LiDARs we used at the time. 

18. Development required solving innumerable issues. For example, 

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

DECLARATION OF PIERRE-YVES DROZ

. Issues like these are something a LiDAR designer not 

previously familiar with Waymo’s designs could not foresee in advance.

19. Through our many months of design and development, we finally had a successful 

and cost-effective mid-range LiDAR for self-driving cars. We finally switched from off-the-shelf 

Velodyne LiDAR systems to our in-house LiDAR 

, almost three years after we first set out to do so and 

approximately a year after we first came up with the single-lens concept . 

E. Waymo’s Current-Generation Mid-Range LiDAR 

20. Waymo’s current-generation mid-range LiDAR, 

 are specifically 

designed—based on Waymo’s years of testing, simulation, experimentation, and optimization for 

different test scenarios—for use in self-driving cars. 

 Yet implementing these designs was not easy. As one example of the difficulty 

of implementing 

. 

21.

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-9- Case No. 3:17-cv-00939-WHA 

DECLARATION OF PIERRE-YVES DROZ

22.

F. Waymo’s Current-Generation Short-Range LiDAR 

23. In 2013, we noticed a problem with 

. To solve this problem, we designed and developed a very simple 

short-range LiDAR system . 

Waymo’s fleet now uses four LiDAR units on each car to cover the main mid-range LiDAR 

unit’s blind spots very close to the car. 

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-11- Case No. 3:17-cv-00939-WHA 

DECLARATION OF PIERRE-YVES DROZ

 Having this knowledge would allow a competitor to save time, money, 

and effort that would otherwise have been spent addressing the various risks encountered during 

LiDAR design and development. 

27. Mr. Levandowski personally told me in January 2016 he was interested in 

implementing long-range LiDAR at his new company and was thus interested in the design, 

which is not available in any commercially available LiDAR system that I know of. I distinctly 

remember taking a walk around our Mountain View office one-on-one with Mr. Levandowski on 

or around January 5, 2016. During this walk, he told me specifically that he wanted his new 

company to have a long-range LiDAR, which is very useful for self-driving truck applications he 

was interested in. He also told me that he planned to “replicate” this Waymo technology at his 

new company. 

28. This conversation did not surprise me. Mr. Levandowski had previously told me, 

in or around the summer of 2015, that he had talked with Brian McClendon, an Uber executive 

involved with their self-driving car project. We were having dinner at a restaurant near the office, 

and he told me that it would be nice to create a new self-driving car startup and that Uber would be 

interested in buying the team responsible for the LiDAR we were developing at Google. 

29. Later in January 2016, a colleague told me that Mr. Levandowski had been seen at 

Uber’s headquarters in mid January. I asked Mr. Levandowski about this, and he admitted he had 

met with Uber, and the reason he was there was that he was looking for investors for his new 

company. 

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-12- Case No. 3:17-cv-00939-WHA 

DECLARATION OF PIERRE-YVES DROZ

H. Waymo’s LiDAR Trade Secrets Are Protected 

30. Waymo takes robust measures to protect its LiDAR trade secrets. As a condition of 

employment, I understand Waymo requires all employees—including members of the LiDAR 

team who have left Waymo to work for Defendants—to enter into written agreements to maintain 

the confidentiality of proprietary and trade secret information, and not to misuse such information. 

In addition, Waymo enforces an employee code of conduct that explains employees’ strict 

obligations to maintain the secrecy of confidential information. 

31. For example, employees are required to complete annual information security 

training. I understand that Waymo tracks whether I have completed the training (and re-training) 

on an annual basis. 

32. Waymo also employs network security measures and access policies that restrict 

the access and dissemination of certain confidential and proprietary trade secret information to 

only teams that are working on projects related to that information. For example, Google 

employees working on projects with no relation to Waymo or self-driving cars could not (and 

cannot) access Waymo’s confidential and proprietary schematics (e.g., the “SVN” repository). 

They are distributed on a “need to know” basis. 

33. Networks hosting confidential and proprietary information include numerous 

safeguards, such as encryption, passwords and dual-authentication. 

34. Waymo also takes reasonable measures to mark confidential and proprietary 

information, such as documents and other materials, with visible legends designating them as such 

when sharing them outside of Waymo (subject to NDAs). 

35. Waymo employs reasonable efforts to secure physical facilities by restricting 

access and employing locks, cameras, guards, and other security measures. 

36. In my experience, Waymo also requires consultants, vendors, and manufacturers to 

sign confidentiality agreements that require that they undertake reasonable efforts to maintain, and 

not to disclose, any confidential or trade secret information. 

37. Though sharing technical information with vendors is sometimes necessary, 

Waymo closely guards and never discloses our LiDAR systems’ overall specifications (such as 

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-13- Case No. 3:17-cv-00939-WHA 

DECLARATION OF PIERRE-YVES DROZ

), or our desired target specifications to satisfy different selfdriving test scenarios, to any vendors, even under an NDA. 

I. Potential Harm to Waymo 

38. Google and now Waymo has spent an enormous amount of time developing its 

self-driving car technology, including its custom-built LiDAR systems. In my team alone (now a 

team of approximately people), we’ve spent 5-7 years working on our LiDAR designs to get to 

our current-generation design, . This has included Google and Waymo spending several 

millions as well as thousands of hours of time. I personally have the last six years working almost 

entirely on custom LiDAR solutions for self-driving cars. 

39. Our current design, , reflects these years and millions of dollars of research 

and development that no one else in the industry has access too. Waymo is unique in the industry 

in its long history researching and pioneering LIDAR designs for self-driving cars. This is one 

reason that I believe Waymo is the industry leader in self-driving cars. 

40. For example, and as discussed above, our development time (while still ongoing in 

some respects) took the team about six months to develop the design even with the 

design already done (and three years after we first started working on our original mid-range 

LiDAR, ). Also as discussed above, provides a number of benefits not present in the 

 design or disclosed in our patents, including being less expensive for better resolution, a 

smaller design, more robust—all important criteria for self-driving cars. 

41. In my opinion, the self-driving car market is a nascent market in which the cost and 

energy required to deploy at large scale in a new region are significant. The growth, profitability, 

and even survival of individual companies will likely be determined by what happens in the next 

few years. If another company, such as Otto/Uber, were to use Waymo’s intellectual property, I 

believe that would greatly harm Waymo during this embryonic market formation process by 

providing direct competitors with essentially a multi-year “head start” in their development of 

self-driving car technology. 

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