EXHIBIT 1 

REDACTED VERSION OF 

DOCUMENT FILED 

UNDER SEAL 

Case 3:17-cv-00939-WHA Document 1160-2 Filed 08/11/17 Page 1 of 11
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UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

---oOo--- 

WAYMO LLC, 

Plaintiff, 

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

UBER TECHNOLOGIES, INC.; 

OTTOMOTTO LLC; OTTO TRUCKING, 

INC., 

Defendants. 

/ 

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VIDEOTAPED DEPOSITION OF DMITRI DOLGOV 

PALO ALTO, CALIFORNIA 

TUESDAY, AUGUST 8, 2017 

BY: ANDREA M. IGNACIO, CSR, RPR, CRR, CCRR, CLR ~ 

CSR LICENSE NO. 9830 

JOB NO. 2664656 

Pages 1 - 156 

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Case 3:17-cv-00939-WHA Document 1160-2 Filed 08/11/17 Page 2 of 11
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UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

---oOo--- 

WAYMO LLC, 

Plaintiff, 

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

UBER TECHNOLOGIES, INC.; 

OTTOMOTTO LLC; OTTO TRUCKING, 

INC., 

Defendants. 

/ 

Videotaped Deposition of Dmitri Dolgov, 

taken on behalf of the Defendants, on August 8, 

2017, at Morrison & Foerster LLP, 950 Page Mill 

Road, Palo Alto, California, beginning 2:11 p.m., 

and commencing at 6:00 p.m., Pursuant to Notice, 

and before me, ANDREA M. IGNACIO, CSR, RPR, CRR, 

CLR ~ License No. 9830. 

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Case 3:17-cv-00939-WHA Document 1160-2 Filed 08/11/17 Page 3 of 11
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A I'm not aware of that. 17:49 

MR. LIN: Okay. That's all I have. 17:49 

MR. JAFFE: So I -- I have some brief 17:49 

questions. I can do it from this seat, or we can -- 17:49 

we can trade spots. Up to you guys. I don't care. 17:49 

MR. LLEWELLYN: I'm fine with you doing it 17:49 

from there. 17:49 

MR. JAFFE: Okay. 17:49 

17:49 

EXAMINATION 17:49 

BY MR. JAFFE: 17:49 

Q Dr. Dolgov, I'm -- I'm going to make this go 17:49 

as quickly as humanly possible. 17:49 

Can you please grab 1360 from your stack. 17:49 

A (Witness complies.) 17:49 

Q It's the e-mail thread with the subject line: 17:49 

"Laser/camera thoughts." 17:50 

A Yeah. 17:50 

Q So I want to take you to the e-mail at the -- 17:50 

at the bottom of the page, dated June 19, 2015. 17:50 

Do you see that? 17:50 

A I do. 17:50 

Q Okay. What was your position on the 17:50 

self-driving project as of June 15, 2015? 17:50 

A I led the software team. 17:50 

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Case 3:17-cv-00939-WHA Document 1160-2 Filed 08/11/17 Page 4 of 11
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Q Okay. So in your e-mail, it says: 17:50 

"Bryan, we just had 

." 17:50 

Do you see that? 17:50 

A I do. 17:50 

Q As the head of the software team, why were 17:50 

you doing ? 17:50 

Q Do you remember an MBr LiDAR device? 17:51 

A I do. 17:51 

Q Okay. Do you know what -- what it stands 17:51 

for? 17:51 

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A I think Mama Bear. 17:51 

Q Did Waymo, or Project Chauffeur before that, 17:51 

17:52 

Q And what was your role personally in that -- 17:52 

in those discussions? 17:52 

A I'm not sure I can recall those directly. I 17:53 

think those were in pretty early days of the team. I 17:53 

think, at that time, I worked or maybe led the effort 17:53 

that was focused on planning at -- maybe at that point 17:53 

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Case 3:17-cv-00939-WHA Document 1160-2 Filed 08/11/17 Page 6 of 11
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I led the on-board software team. 17:53 

But regardless of that role, I think I was 17:53 

one of the experienced -- more experienced software 17:53 

engineers on the team. 17:53 

So, I was involved in kind of the discussions 17:53 

Q Okay. So going back to 1360. 17:54 

Actually, before we get there, if you can 17:54 

look at 1361. 17:54 

A (Witness complies.) 17:54 

Got it. 17:55 

Q So in the -- in the middle e-mail here, there 17:55 

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is a -- there is a list of items the follow-on actions 17:55 

are. 17:55 

Do you see that? 17:55 

A I do. 17:55 

Q And No. 2 says: 17:55 

Do you see that? 17:55 

A I do. 17:55 

Q What does refer to here? 17:55 

A I -- my understanding is that this is a 17:55 

MR. JAFFE: All right. 17:56 

Let's mark this next document as 602. And 17:56 

it's a big piece of paper, so hat's off to the -- the 17:56 

file room for printing this off. 17:56 

MR. LLEWELLYN: Counsel, I just want to 17:56 

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Q Are these that were 17:56 

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clarify. Do you think this redirect is responsive to 17:56 

something that was raised in the course of his 17:56 

deposition? 17:56 

MR. JAFFE: Yep. 17:56 

(Document marked Exhibit 602 17:56 

for identification.) 17:56 

MR. JAFFE: Dr. Dolgov, I've marked as 17:56 

Exhibit 602. 17:56 

referred -- that you just referred to? 17:56 

A I can't be exactly confident, but that 17:57 

mention in the e-mail looks like it has a link. I 17:57 

can't be, you know, confident. I can't know for sure 17:57 

if it links to that document, that spreadsheet. But 17:57 

the spirit of it, as I described it, is -- is -- is 17:57 

accurate, yeah. 17:57 

Q Okay. So, in just looking at the information 17:57 

on the left-hand side, in the left-hand-most column, 17:57 

where did these 17:57 

entries in the leftmost column come from? 17:57 

MR. LLEWELLYN: So Counsel, I'm going to 17:57 

object to all of this as beyond the scope of proper 17:57 

redirect. 17:57 

MR. JAFFE: Q. Go ahead. 17:57 

17:57 

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17:58 

Q Is the information in this document, such as 17:58 

in the left-hand corner, is -- is this kept -- kept 17:58 

confidential within Waymo? 17:58 

A I would expect so. I mean, by default, 17:58 

everything that we have to do, especially things that 17:58 

17:58 

are essence as the -- 

are kept confidential. 

Q And why are the -- 

-- why is that in particular 17:58 

sensitive? 17:58 

A Oh, this is, in a way, a product of the 17:58 

experience that the team has accumulated over the 17:58 

years of working on this technology, understanding, 17:58 

17:59 

you know, 

Q Would Waymo share the information in 17:59 

Exhibit 602 with a competitor? 17:59 

A Not unless there were really good reasons to 17:59 

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do so. 17:59 

Q And do you have any personal knowledge 17:59 

regarding the value of -- of this information to Waymo 17:59 

in the self-driving car project? 17:59 

A I can't -- I'm not sure if I can quantify the 17:59 

value. But it -- as I just mentioned, it's -- in my 17:59 

mind, the value is tremendous because it captures the 17:59 

experience accumulated over the course of developing 17:59 

the system and trying different ideas and 18:00 

understanding, you know, 

18:00 

Q And, to your knowledge, is the information 18:00 

contained in this document, Exhibit 602 -- does it 18:00 

reflect -- is it in the public domain? 18:00 

A Not that I'm aware of. 18:00 

Q Okay. 18:00 

MR. JAFFE: All right. No further questions. 18:00 

MR. LLEWELLYN: I have a further question. 18:00 

18:00 

FURTHER EXAMINATION 18:00 

BY MR. LLEWELLYN: 18:00 

Q You testified that you couldn't be sure 18:00 

whether this newly marked exhibit was, in fact, the 18:00 

that were specifically called out in 18:00 

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