EXHIBIT 21

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 OF DOCUMENT

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01980-00104/9336283.1 

1 Case No. 3:17-cv-00939-JCS

PLAINTIFF WAYMO’S THIRD SET OF REQUESTS FOR PRODUCTION TO DEFENDANTS

QUINN EMANUEL URQUHART & SULLIVAN, LLP 

Charles K. Verhoeven (Cal. Bar No. 170151) 

charlesverhoeven@quinnemanuel.com 

David Perlson (Cal. Bar No. 209502) 

davidperlson@quinnemanuel.com 

Melissa J. Baily (Cal. Bar No. 237649) 

melissabaily@quinnemanuel.com 

John Neukom (Cal. Bar No. 275887) 

johnneukom@quinnemanuel.com 

Jordan R. Jaffe (Cal. 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 Plaintiff 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-JCS 

PLAINTIFF WAYMO LLC’S THIRD SET 

OF REQUESTS FOR PRODUCTION TO 

DEFENDANTS 

Honorable William H. Alsup

HIGHLY CONFIDENTIAL – 

ATTORNEYS’ EYES ONLY

PLAINTIFF’S THIRD SET OF REQUESTS FOR PRODUCTION 

TO DEFENDANTS UBER TECHNOLOGIES, INC.; OTTOMOTTO, LLC; OTTO 

TRUCKING LLC, 

Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, Plaintiff Waymo LLC 

(“Waymo”) request that Defendants Uber Technologies, Inc. (“Uber”), Ottomotto, LLC 

(“Ottomotto”), and Otto Trucking LLC (“Otto Trucking” (collectively “Defendants”), produce for 

inspection and copying within thirty days (30) hereof the documents set forth below at the offices 

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

PLAINTIFF WAYMO’S THIRD SET OF REQUESTS FOR PRODUCTION TO DEFENDANTS

of Quinn Emanuel Urquhart & Sullivan, LLP, 50 California Street, 22nd Floor, San Francisco, 

California, 94111, or at a place and time as may be agreed to by counsel. 

DEFINITIONS 

1. “WAYMO” means Waymo LLC and its officers, directors, current and former 

employees, counsel, agents, consultants, representatives, and any other persons acting on behalf 

of any of the foregoing, and WAYMO’s affiliates, parents, divisions, joint ventures, licensees, 

franchisees, assigns, predecessors and successors in interest, and any other legal entities, whether 

foreign or domestic, that are owned or controlled by WAYMO, and all predecessors and 

successors in interest to such entities, and any entity owned in whole or in part by, affiliated with,

or controlled in whole or in part by WAYMO. 

2. “GOOGLE” means Google Inc. and its officers, directors, current and former 

employees, counsel, agents, consultants, representatives, and any other persons acting on behalf of 

any of the foregoing, and GOOGLE’s affiliates, parents, divisions, joint ventures, licensees, 

franchisees, assigns, predecessors and successors in interest, and any other legal entities, whether 

foreign or domestic, that are owned or controlled by GOOGLE, and all predecessors and 

successors in interest to such entities, and any entity owned in whole or in part by, affiliated with,

or controlled in whole or in part by GOOGLE. 

3. “UBER” means Uber Technologies, Inc. and its officers, directors, current and 

former employees, counsel, agents, consultants, representatives, and any other persons acting on 

behalf of any of the foregoing, and UBER’s affiliates, parents, divisions, joint ventures, licensees, 

franchisees, assigns, predecessors and successors in interest, and any other legal entities, whether 

foreign or domestic, that are owned or controlled by UBER, and all predecessors and successors in 

interest to such entities, and any entity owned in whole or in part by, affiliated with, or controlled

in whole or in part by UBER. 

4. “OTTOMOTTO” means Ottomotto LLC and its officers, directors, current and 

former employees, counsel, agents, consultants, representatives, and any other persons acting on 

behalf of any of the foregoing, and OTTOMOTTO’s affiliates, parents, divisions, joint ventures, 

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

PLAINTIFF WAYMO’S THIRD SET OF REQUESTS FOR PRODUCTION TO DEFENDANTS

licensees, franchisees, assigns, predecessors and successors in interest, and any other legal entities, 

whether foreign or domestic, that are owned or controlled by OTTOMOTTO, and all predecessors 

and successors in interest to such entities, and any entity owned in whole or in part by, affiliated 

with, or controlled in whole or in part by OTTOMOTTO. For the avoidance of doubt, 

OTTOMOTTO includes all former names under which OTTOMOTTO operated, including 

without limitation 280 Systems, Inc., 280 Systems, LLC, and Ottomotto, Inc. 

5. “OTTO TRUCKING” means Otto Trucking LLC and its officers, directors, 

current and former employees, counsel, agents, consultants, representatives, and any other persons 

acting on behalf of any of the foregoing, and OTTO TRUCKING’s affiliates, parents, divisions, 

joint ventures, licensees, franchisees, assigns, predecessors and successors in interest, and any 

other legal entities, whether foreign or domestic, that are owned or controlled by OTTO 

TRUCKING, and all predecessors and successors in interest to such entities, and any entity owned 

in whole or in part by, affiliated with, or controlled in whole or in part by OTTO TRUCKING. 

6. “DEFENDANTS” means UBER, OTTOMOTTO, and OTTO TRUCKING. 

7. “LEVANDOWSKI” means Anthony Levandowski. 

8. “FUJI” means each version or generation of the LIDAR system(s) DEFENDANTS 

have identified by the name Fuji, including any “precursor” or related projects such as LIDAR 0 

or Mr. Fast Lens. 

9. “SPIDER” means each version or generation of the LIDAR system(s) 

DEFENDANTS have identified by the name Spider. 

10. “OWL” means each version or generation of the LIDAR system(s) DEFENDANTS 

have identified by the name Owl. 

11. “KSHIRSAGAR” means Sameer Kshirsagar. 

12. “RADUTA” means Radu Raduta. 

1. “MISAPPROPRIATED MATERIALS” refers to all GOOGLE and WAYMO 

DOCUMENTS and materials, whether digital or physical, and regardless of the manner stored, for 

which any current or former employee of DEFENDANTS retained possession, without 

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

PLAINTIFF WAYMO’S THIRD SET OF REQUESTS FOR PRODUCTION TO DEFENDANTS

authorization of either GOOGLE or WAYMO, after the employee ended his or her employment 

with GOOGLE/WAYMO. Without limitation, MISAPPROPRIATED MATERIALS includes at 

least: (i) each of the more than 14,000 digital files downloaded by LEVANDOWSKI on or about 

December 11, 2015 from the SVN repository; (ii) each file copied by LEVANDOWSKI from his 

GOOGLE laptop to an RDF5 USB 3.0 card reader on or about December 14, 2015; (iii) each of 

the five files that were exported by LEVANDOWSKI from Google Drive to a personal device on 

or about January 4, 2016; (iv) the file exported by LEVANDOWSKI from Google Drive to a 

personal device on or about January 11, 2016; (v) the file that was exported by LEVANDOWSKI 

from Google Drive to a personal device on or about November 19, 2016; (vi) the file that was 

exported by LEVANDOWSKI from Google Drive to a personal device on or about November 4, 

2016; each of the five files that were exported by KSHIRSAGAR from Google Drive in or around 

June and July 2016; (vii) each of the three files that were exported by RADUTA from Google 

Drive on or around July 28, 2016. 

13. “LiDAR” means Light Detection and Ranging. 

14. “ASSERTED PATENTS” means U.S. Patent Nos. 8,836,922; 9,368,936; 

9,285,464; and 9,086,273. 

15. “PCB” means printed circuit board. 

16. “DOCUMENTS” shall INCLUDE, without limitation, all written, graphic or 

otherwise recorded material, INCLUDING without limitation, electronically stored information 

regardless of the form of storage medium, microfilms or other film records or impressions, tape 

recordings or computer cards, floppy disks or printouts, any and all papers, photographs, films, 

recordings, memoranda, books, records, accounts, communications, letters, telegrams, 

correspondence, notes of meetings, notes of conversations, notes of telephone calls, inter-office 

memoranda or written communications of any nature, recordings of conversations either in 

writings or upon any mechanical or electrical recording devices, INCLUDING e-mail, notes, 

papers, reports, analyses, invoices, canceled checks or check stubs, receipts, minutes of meetings, 

time sheets, diaries, desk calendars, ledgers, schedules, licenses, financial statements, telephone 

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

PLAINTIFF WAYMO’S THIRD SET OF REQUESTS FOR PRODUCTION TO DEFENDANTS

bills, logs, and any differing versions of any of the foregoing, whether so denominated, formal, 

informal or otherwise, as well as copies of the foregoing which differ in any way, INCLUDING 

by the addition of handwritten notations or other written or printed matter of any nature, from the 

original. The foregoing specifically INCLUDES information stored in a computer database and 

capable of being generated in documentary form, such as electronic mail, text messages (i.e., SMS 

messages), other electronic messages including messages sent or received via Slack, WhatsApp, 

Google Hangouts, Facebook Messenger, and the like. 

17. “COMMUNICATIONS” shall mean, without limitation, any transmission, 

conveyance or exchange of a word, statement, fact, thing, idea, DOCUMENT, instruction, 

information, demand or question by any medium, whether by written, oral or other means, 

including but not limited to, electronic communications and electronic mail (“e-mail”). 

18. “THING” means any tangible object, other than a DOCUMENT. 

19. “PERSON” means to any individual, corporation, proprietorship, association, joint 

venture, company, partnership or other business or legal entity, including governmental bodies and 

agencies. The masculine includes the feminine and vice versa; the singular includes the plural and 

vice versa. 

20. “REGARDING” shall mean relating to, referring to, mentioning, reflecting, 

pertaining to, evidencing, involving, describing, discussing, commenting on, embodying, 

responding to, supporting, contradicting, or constituting (in whole or in part), as the context makes 

appropriate. 

21. “INCLUDE” and “INCLUDING” shall mean including without limitation. 

22. Use of the singular also INCLUDES the plural and vice-versa. 

23. The words “or” and “and” shall be read in the conjunctive and in the disjunctive 

wherever they appear, and neither of these words shall be interpreted to limit the scope of these 

Requests for Production. 

24. The use of a verb in any tense shall be construed as the use of the verb in all other 

tenses. 

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

PLAINTIFF WAYMO’S THIRD SET OF REQUESTS FOR PRODUCTION TO DEFENDANTS

25. The term “any” shall include “all” and “all” shall include “any.” 

INSTRUCTIONS 

The following instructions shall apply to each of the Requests herein: 

1. In answering the following Requests, furnish all available information, including 

information in the possession, custody or control of any of DEFENDANTS’ attorneys, directors, 

officers, agents, employees, representatives, associates, investigators, divisions, affiliates, 

partnerships, parents, subsidiaries and PERSONS under DEFENDANTS’ control, who have the 

best knowledge, not merely information known to DEFENDANTS based on DEFENDANTS own 

personal knowledge. If DEFENDANTS cannot fully respond to the following Requests after 

exercising due diligence to secure the information requested thereby, so state, and specify the 

portion of each Request that cannot be responded to fully and completely. In the latter event, state 

what efforts were made to obtain the requested information and the facts relied upon that support 

the contention that the Request cannot be answered fully and completely; and state what 

knowledge, information or belief DEFENDANTS have concerning the unanswered portion of any 

such Request. 

2. All documents must be produced in accordance with the requirements of Federal 

Rule of Civil Procedure 34(b). 

3. Electronic records and computerized information shall be produced in an 

intelligible format, together with a description of the system from which they were derived 

sufficient to permit rendering the records and information intelligible. 

4. Selection of documents from the files and other sources and the numbering of such 

documents shall be performed in such a manner as to ensure that the source of each document can 

be determined. 

5. File folders with tabs or labels or directories of files identifying documents shall be 

produced intact with such documents. 

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

PLAINTIFF WAYMO’S THIRD SET OF REQUESTS FOR PRODUCTION TO DEFENDANTS

6. Documents attached to each other shall not be separated. All documents that 

respond, in whole or in part, to any portion of any request shall be produced in their entirety, 

including all addenda, appendices, attachments and enclosures. 

7. If DEFENDANTS’ response to a particular Request is a statement that 

DEFENDANTS lack the ability to comply with that Request, DEFENDANTS shall specify 

whether the inability to comply is because the particular item or category of information never 

existed, has been destroyed, has been lost, misplaced or stolen, or has never been, or is no longer 

in DEFENDANTS’ possession, custody or control, in which case DEFENDANTS shall identify 

the name and address of any person or entity known or believed by DEFENDANTS to have 

possession, custody or control of that information or category of information. 

8. DEFENDANTS’ obligation to respond to these Requests is continuing, and their 

responses are to be supplemented to include subsequently acquired information in accordance with 

the requirements of Rule 26(e) of the Federal Rules of Civil Procedure. 

DOCUMENT REQUESTS 

REQUEST FOR PRODUCTION NO. 153: 

All DOCUMENTS and COMMUNICATIONS REGARDING the Project Chauffeur 

Bonus Program. 

REQUEST FOR PRODUCTION NO. 154: 

All agreements between any DEFENDANT and Nevada ATCF LLC. 

REQUEST FOR PRODUCTION NO. 155: 

All DOCUMENTS and COMMUNICATIONS REGARDING any agreements between 

any DEFENDANT and Nevada ATCF LLC. 

REQUEST FOR PRODUCTION NO. 156: 

All COMMUNICATIONS between LEVANDOWSKI and any PERSON (INCLUDING 

DEFENDANTS) REGARDING Nevada ATCF LLC. 

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

PLAINTIFF WAYMO’S THIRD SET OF REQUESTS FOR PRODUCTION TO DEFENDANTS

REQUEST FOR PRODUCTION NO. 157: 

DOCUMENTS sufficient to show the reasons behind DEFENDANTS’ and/or OTTO 

TRUCKING’s decision not to deploy self-driving trucks in Texas. 

REQUEST FOR PRODUCTION NO. 158: 

DOCUMENTS sufficient to show DEFENDANTS’ past, present, and future plans to test 

self-driving trucks in any state, INCLUDING (without limitation) Ohio, Nevada, Texas, Colorado, 

Pennsylvania, Arizona, and California. 

REQUEST FOR PRODUCTION NO. 159: 

DOCUMENTS sufficient to show the total number of miles DEFENDANTS’ self-driving 

trucks have traveled each month in each state, broken out by month and by state. 

REQUEST FOR PRODUCTION NO. 160: 

DOCUMENTS sufficient to show DEFENDANTS’ past, present, and future plans to test 

self-driving trucks in any state, INCLUDING (without limitation) Ohio, Nevada, Texas, Colorado, 

Pennsylvania, Arizona, and California. 

REQUEST FOR PRODUCTION NO. 161: 

All DOCUMENTS and COMMUNICATIONS REGARDING the naming of FUJI. 

REQUEST FOR PRODUCTION NO. 162: 

All DOCUMENTS and COMMUNICATIONS REGARDING the naming of SPIDER. 

REQUEST FOR PRODUCTION NO. 163: 

All DOCUMENTS and COMMUNICATIONS REGARDING the naming of OWL. 

REQUEST FOR PRODUCTION NO. 164: 

All COMMUNICATIONS between Brian McClendon and any PERSON REGARDING 

LiDAR, OTTOMOTTO, OTTO TRUCKING, or LEVANDOWSI. 

REQUEST FOR PRODUCTION NO. 165: 

All COMMUNICATIONS between Travis Kalanick and any PERSON REGARDING 

LiDAR, OTTOMOTTO, OTTO TRUCKING, or LEVANDOWSI. 

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

PLAINTIFF WAYMO’S THIRD SET OF REQUESTS FOR PRODUCTION TO DEFENDANTS

REQUEST FOR PRODUCTION NO. 166: 

All COMMUNICATIONS between John Bares and any PERSON REGARDING 

OTTOMOTTO, OTTO TRUCKING, or LEVANDOWSI. 

REQUEST FOR PRODUCTION NO. 167: 

All COMMUNICATIONS between Cameron Poetzscher and any PERSON REGARDING 

LiDAR, OTTOMOTTO, OTTO TRUCKING, or LEVANDOWSI. 

REQUEST FOR PRODUCTION NO. 168: 

All minutes of meetings of any of DEFENDANTS’ Board of Directors, or any committee 

thereof, during which LiDAR was discussed. 

REQUEST FOR PRODUCTION NO. 169: 

All minutes of meetings of UBER’s Board of Directors, or any committee thereof, during 

which OTTOMOTTO, OTTO TRUCKING, or LEVANDOWSKI was discussed. 

REQUEST FOR PRODUCTION NO. 170: 

All DOCUMENTS REGARDING LiDAR that were prepared for or received by any of 

DEFENDANTS’ Board of Directors, or any committee thereof. 

REQUEST FOR PRODUCTION NO. 171: 

All DOCUMENTS REGARDING OTTOMOTTO, OTTO TRUCKING, or 

LEVANDOWSKI that were prepared for or received by UBER’s Board of Directors, or any 

committee thereof. 

REQUEST FOR PRODUCTION NO. 172: 

All roadmaps, timelines, and development schedules REGARDING LiDAR. 

REQUEST FOR PRODUCTION NO. 173: 

All roadmaps, timelines, and development schedules REGARDING self-driving vehicles. 

REQUEST FOR PRODUCTION NO. 174: 

All forecasts, market analyses, or market projects REGARDING self-driving vehicles. 

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19 Case No. 3:17-cv-00939-JCS

PLAINTIFF WAYMO’S THIRD SET OF REQUESTS FOR PRODUCTION TO DEFENDANTS

REQUEST FOR PRODUCTION NO. 242: 

DOCUMENTS sufficient to show any sequence of steps for LiDAR calibration considered 

or implemented by DEFENDANTS. 

REQUEST FOR PRODUCTION NO. 243: 

DOCUMENTS sufficient to show any techniques for thermal calibration for a LiDAR 

system’s photodetectors considered or implemented by DEFENDANTS. 

REQUEST FOR PRODUCTION NO. 244: 

DOCUMENTS sufficient to show any techniques for mirror angle calibration for a LiDAR 

system considered or implemented by DEFENDANTS. 

REQUEST FOR PRODUCTION NO. 245: 

DOCUMENTS sufficient to show any techniques for walk calibration for a LiDAR system 

considered or implemented by DEFENDANTS. 

REQUEST FOR PRODUCTION NO. 246: 

DOCUMENTS sufficient to show any instructions for transmit and receive alignment and 

tuning of a LiDAR system considered or implemented by DEFENDANTS. 

REQUEST FOR PRODUCTION NO. 247: 

DOCUMENTS sufficient to show any instructions for calibrating the intensity of a LiDAR 

system considered or implemented by DEFENDANTS. 

REQUEST FOR PRODUCTION NO. 248: 

DOCUMENTS sufficient to show any instructions for running extrinsic calibration of a 

LiDAR system considered or implemented by DEFENDANTS. 

REQUEST FOR PRODUCTION NO. 249: 

DOCUMENTS sufficient to show any techniques for thermal rotary coupling in a LiDAR 

system considered or implemented by DEFENDANTS. 

REQUEST FOR PRODUCTION NO. 250: 

DOCUMENTS sufficient to show any techniques for amplifying a fiber laser in a LiDAR 

system considered or implemented by DEFENDANTS. 

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LLP 

435 Tasso Street 

Suite 205 

Palo Alto, CA 94301 

Hamish Hume 

Jessica E Phillips 

Karen Leah Dunn 

Kyle N. Smith 

Martha Lea Goodman 

BOIES SCHILLER FLEXNER 

LLP 

1401 New York Ave., NW 

Washington, DC 20005 

I. Neel Chatterjee (SBN 173985) 

GOODWIN PROCTER LLP 

135 Commonwealth Drive 

Menlo Park, CA 94025 

Tel.: +1 650 752 3100 

Fax: +1 650 853 1038 

nchatterjee@goodwinlaw.com 

Brett M. Schuman (SBN 189247) 

Shane Brun (SBN 179079) 

Rachel M. Walsh (SBN 250568) 

GOODWIN PROCTER LLP 

Three Embarcadero Center 

San Francisco, California 94111 

Tel.: +1 415 733 6000 

Fax.: +1 415 677 9041 

bschuman@goodwinlaw.com 

sbrun@goodwinlaw.com 

rwalsh@goodwinlaw.com 

BY ELECTRONIC MAIL TRANSMISSION: by electronic mail transmission from 

jamesjudah@quinnemanuel.com on May 31, 2017, by transmitting a PDF format copy of such 

document(s) to each such person at the e mail address listed above. The document(s) was/were 

transmitted by electronic transmission and such transmission was reported as complete and 

without error. 

Executed on May 31, 2017, at San Francisco, California. 

 /s/ James D. Judah

James D. Judah

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