DEFENDANT OTTO TRUCKING LLC’S NOTICE TO JOIN REPLY TO MOTION TO DISMISS FILED BY UBER TECHNOLOGIES, INC.

AND OTTOMOTTO LLC (CASE NO. 3:17-CV-00939-WHA) 

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Neel Chatterjee (SBN 173985) 

nchatterjee@goodwinlaw.com 

GOODWIN PROCTER LLP

135 Commonwealth Drive 

Menlo Park, California 94025-1105 

Tel.: +1 650 752 3100 

Fax.: +1 650 853 1038 

Brett Schuman (SBN 189247) 

bschuman@goodwinlaw.com

Rachel M. Walsh (SBN 250568) 

rwalsh@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., et al., 

Defendants. 

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

OTTO TRUCKING LLC’S NOTICE TO 

JOIN AND ADOPT DEFENDANTS UBER 

TECHNOLOGIES, INC’S AND 

OTTOMOTTO LLC’S REPLY IN 

SUPPORT OF MOTION TO DISMISS 

UNFAIR COMPETITION LAW CLAIM 

Date: June 7, 2017 

Time: 8:00 a.m. 

Ctrm: 8, 19th Floor 

Judge: The Honorable William Alsup 

Trial Date: October 2, 2017 

Case 3:17-cv-00939-WHA Document 479 Filed 05/19/17 Page 1 of 4
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DEFENDANT OTTO TRUCKING LLC’S NOTICE TO JOIN REPLY TO MOTION TO DISMISS FILED BY UBER TECHNOLOGIES, INC.

AND OTTOMOTTO LLC (CASE NO. 3:17-CV-00939-WHA) 

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TO THE COURT, ALL PARTIES AND THEIR COUNSEL OF RECORD: 

PLEASE TAKE NOTICE THAT Defendant Otto Trucking LLC (“Otto Trucking”) hereby 

joins and adopts Defendants Uber Technologies, Inc.’s (“Uber”) and Ottomotto LLC’s (“Ottomotto”) 

Reply in Support of Motion to Dismiss Waymo’s Unfair Competition Law Claim. The hearing on 

the Motion is set for June 7, 2017 at 8:00 a.m. before the Honorable William Alsup. In support, Otto 

Trucking states as follows: 

1. Waymo filed a Complaint on February 23, 2017 (Dkt. No. 1) and an Amended Complaint 

on March 10, 2017 (Dkt. No. 23) asserting seven causes of action equally against all 

Defendants, alleging trade secret misappropriation, patent infringement, and unfair 

competition. 

2. On April 28, 2017, Defendants Uber, Ottomotto, and Otto Trucking filed a Motion to 

Dismiss Waymo’s Unfair Competition Law Claim. 

3. On May 3, 2017, the Court entered an order approving of the Notice of Change in Counsel 

for Defendant Otto Trucking LLC. 

4. On May 19, 2017, Co-Defendants Uber and Ottomotto filed their Reply in Support of 

Motion to Dismiss Waymo’s Unfair Competition Claim. 

5. Otto Trucking joins and adopts, as if set out verbatim herein, the arguments, authorities, 

contentions, exhibits, attachments, and prayers of Co-Defendants Uber and Ottomotto set 

forth in Co-Defendants’ Reply in Support of Motion to Dismiss Waymo’s Unfair 

Competition Law Claim, filed with this Court on May 19, 2017, for the reason that said 

motion and reply are equally applicable to this Defendant in the above captioned matter. 

6. Otto Trucking joins and adopts Co-Defendants’ Reply Brief in order to best serve justice 

and avoid unnecessary or duplicative effort, time, or expense to the parties involved. 

WHEREFORE, Defendant Otto Trucking LLC hereby joins and adopts Co-Defendants’ 

Reply in Support of Motion to Dismiss Waymo’s Unfair Competition Law Claim. 

Case 3:17-cv-00939-WHA Document 479 Filed 05/19/17 Page 2 of 4
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DEFENDANT OTTO TRUCKING LLC’S NOTICE TO JOIN REPLY TO MOTION TO DISMISS FILED BY UBER TECHNOLOGIES, INC.

AND OTTOMOTTO LLC (CASE NO. 3:17-CV-00939-WHA) 

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Dated: May 19, 2017 Respectfully submitted,

By: /s/ Neel Chatterjee 

Neel Chatterjee 

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 

bschuman@goodwinlaw.com

Rachel M. Walsh 

rwalsh@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 

Case 3:17-cv-00939-WHA Document 479 Filed 05/19/17 Page 3 of 4
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DEFENDANT OTTO TRUCKING LLC’S NOTICE TO JOIN REPLY TO MOTION TO DISMISS FILED BY UBER TECHNOLOGIES, INC.

AND OTTOMOTTO LLC (CASE NO. 3:17-CV-00939-WHA) 

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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 

May 19, 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 May 19, 2017. 

/s/ Neel Chatterjee 

Neel Chatterjee 

Case 3:17-cv-00939-WHA Document 479 Filed 05/19/17 Page 4 of 4