DEFENDANTS’ RESPONSE TO WAYMO’S SUPPLEMENTAL BRIEF REGARDING HASLIM TESTIMONY

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 

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

DEFENDANTS’ RESPONSE TO 

WAYMO’S SUPPLEMENTAL BRIEF 

REGARDING HASLIM TESTIMONY 

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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DEFENDANTS’ RESPONSE TO WAYMO’S SUPPLEMENTAL BRIEF REGARDING HASLIM TESTIMONY

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I. WAYMO’S SUPPLEMENTAL BRIEF SHOULD BE STRICKEN 

The Court invited Waymo to submit excerpts from the further deposition of Uber engineer 

James Haslim; instead, Waymo submitted a 15-page substantive brief, misrepresenting 

Mr. Haslim’s testimony, raising new issues, and rehashing Waymo’s old arguments. Waymo’s 

supplemental brief should be stricken in its entirety, except for the quotes and citations to 

Mr. Haslim’s testimony. 

At the hearing on May 3, 2017, Defendants volunteered to make Mr. Haslim available for 

additional deposition time. The Court gave Waymo four additional hours to depose Mr. Haslim 

and permitted Waymo to submit any “home run” testimony from Mr. Haslim by May 8 (Hearing 

Tr., May 3, 2017 at 1pm, p. 77): 

MR. JAFFE: So, your Honor, we will take the deposition. 

THE COURT: All right. Let’s do it tomorrow morning, 

9:00 a.m. And let’s say you’ve got four hours max. And then 

you – if you hit my [sic] home runs in there, you have submit it by 

Monday. Because I’m going to try to get an order out next week, 

so submit it by Monday. 

On May 4, 2017, Waymo deposed Mr. Haslim for 5.5 additional hours on the record. 

The Court did not authorize Waymo to file an additional substantive brief, yet that is 

exactly what Waymo has done. Even if Waymo’s submission had just included quotes and 

citations to Mr. Haslim’s testimony, it would have exceeded the Court’s authorization, as there 

was no home-run testimony or finding from Mr. Haslim’s deposition. But Waymo’s 

May 8 supplemental brief goes far beyond including just relevant excerpts from Mr. Haslim’s 

testimony—it contains 15 pages of technical arguments re-treading Waymo’s various trade secret 

theories. It is prejudicial and unfair for Waymo to grant itself additional substantive briefing 

when the Court asked only for “home run” deposition testimony. Waymo’s brief should be 

stricken. 

Alternatively, if the Court is not inclined to strike Waymo’s brief, Defendants respectfully 

request permission to respond to Waymo’s improper arguments. Below is Defendants’ proposed 

response. At minimum, Defendants respectfully request that the Court accept, for the sake of 

completeness, Defendants’ counter-designations of relevant testimony in the boxes below, so that 

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the Court may consider this testimony alongside the testimony identified by Waymo. 

II. DEFENDANTS’ RESPONSE TO WAYMO’S SUPPLEMENTAL BRIEF 

Waymo misstates Mr. Haslim’s May 4 deposition testimony1 on the alleged trade secrets 

and Anthony Levandowski’s past and current role with respect to Defendants’ LiDAR. The “rule 

of completeness” requires that Mr. Haslim’s full relevant testimony on these issues, provided 

below, be considered.2 

A. Mr. Haslim’s Testimony3

 Confirms That Fuji Does Not Use 

, As Defined by Waymo’s Own Expert 

Waymo claims Mr. Haslim confirmed that the between Fuji’s diodes 

 (Br. 4-5), but omits his testimony that the 

 as defined by Waymo’s own expert, Gregory Kintz.4 Waymo 

misleadingly quotes Mr. Haslim’s testimony concerning the 

 (Br. at 5 (quoting Haslim testimony on 

)), but that is not how Mr. Kintz defines 

 in Waymo’s alleged trade secret. At his deposition (quoted below), Mr. Kintz 

specifically defined the 

. When Mr. Haslim applied Mr. Kintz’s 

definition of the between diodes, he confirmed that Fuji’s diodes do not 

 

1

 Excerpts to the Haslim transcript are attached as Yang Ex. 1, and a full transcript as Yang Ex. 6. 2

 Rule 106 of the Federal Rules of Evidence states: “If a party introduces all or part of a writing 

or recorded statement, an adverse party may require the introduction, at that time, of any other 

part — or any other writing or recorded statement — that in fairness ought to be considered at the 

same time.” See also In re Chase Bank USA, N.A. CHECK LOAN Contract Litigation, 274 

F.R.D. 286, 288 fn. 1 (N.D. Cal May 13, 2011) (granting leave to file supplemental declaration 

attaching additional deposition transcript excerpts that “provide context for the excerpts on which 

plaintiffs rely”). 

3

 While Waymo argues that Mr. Haslim had private conferences with counsel, Mr. Haslim 

confirmed on the record that he and counsel did not discuss the subject matter of his testimony or 

how he should testify, and only discussed procedural issues—specifically, how much time was 

left on the record and the expected length of the redirect, but not what the redirect questions were 

or the substance of the redirect. (Haslim Tr. 143:25-144:3, 145:6-8, 146:1-147:2.) 4

 Mr. Kintz also compared the 

. (Yang Ex. 2, Kintz Tr. 54:1-12, 89:17-90:6.) Mr. Haslim confirmed 

that looking at , Fuji diodes do not . (Haslim 

Tr. 186:14-187:1.) 

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:

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Mr. Kintz’s April 26 Deposition Mr. Haslim’s May 4 Deposition

Q By 

 is 

that correct? 

A No. I was computing the – 

. 

Q Using ? 

A Yes. 

(Yang Ex 2, Kintz Tr. at 50:16-21.) 

Q Okay. And in order to calculate 

(Yang Ex. 2, Kintz Tr. at 83:2-9.) 

Q. Could you describe generally how you 

calculated that or determined that? 

A. Yeah. So 

 I don’t know if you need any 

more -- 

Q. Is there a name for that equation that you 

just described? 

A. 

or -- yeah. 

(Haslim Tr. at 181:5-16.) 

Q. Same question for the distance between 

diodes. Is that distance 

? 

A. No. The linear distance is not 

 

(Haslim Tr. at 187:2-9; see Yang Ex. 4, Exhibit 

1060 to Haslim Dep.) 

Does the 

? 

THE WITNESS: There is a 

 (Haslim Tr. at 192:2-11; see Yang Ex. 4, 

Exhibit 1060 to Haslim Dep.)

B. Mr. Haslim Confirmed That Mr. Boehmke’s Custom Beam Spacing for Fuji 

Determined the Positioning of Fuji’s Laser Diodes 

Waymo argues that Mr. Haslim’s testimony revealed a “gap” between Mr. Boehmke’s 

custom beam spacing for Fuji ( ) and the of the 

 

5

 Inexplicably, Waymo argues that Mr. Haslim explained the “correct way” to determine 

 (Br. at 5), but it is not Mr. Haslim’s role to define in Waymo’s own 

alleged trade secret, particularly given that Mr. Haslim has no access to Waymo’s alleged trade 

secret descriptions (which is marked Waymo AEO). 

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laser diodes on the (Br. at 6-7). However, Waymo omits Mr. Haslim’s testimony 

confirming that Mr. Boehmke’s custom beam spacing drove the placement of Fuji’s laser diodes. 

Mr. Haslim’s May 4 Deposition

Q. And you were asked about whether there was any evidence that the information you received 

from Scott Boehmke referred to in this paragraph was actually used in Fuji, and you referred to 

CAD files. What did you -- what CAD files are you referring to? 

THE WITNESS: I was referring -- 

THE WITNESS: I was referring to mechanical CAD files in the SolidWorks software created 

by Gaetan that have the angles specified by Scott Boehmke that end up terminating in a set of 

points for each laser diode emitting point. He then also included a CAD model of the laser board 

outline that he developed that also had those same emitting points on there. And then, finally, 

you can see the theta angle matches the prescribed angles that we got from Scott. 

(Haslim Tr. 198:23-199:16.) 

Q. Can you explain step by step the process from going from the angles that you received from 

Scott -- 

A. Okay. 

Q. -- to what ultimately ended up being the diode placement angles reflected in Exhibit B of 

your original declaration and marked as Exhibit 155 for your deposition? 

THE WITNESS: My understanding of the process that led to the coordinates we have in Exhibit 

155, starting with angles that Scott Boehmke provided, was that Gaetan designed a lens in 

Zemax. We had decided on 150 millimeter focal length, chosen material for the lens. From the 

lens optimization provided by the Zemax software, we had the focal length behind the lens to the 

beginning of a focal surface. And he had a radius of curvature for the focal surface. From that 

information in Zemax, you can take that into SolidWorks software, model up a curved surface 

with the same radius of curvature as the focal surface defined by Zemax. That could be -- he 

modeled that at a location behind the lens with a consistent focal length developed in Zemax. 

He then, as I understand it, created lines or rays in the CAD geometry that reflected the vertical 

angles specified by Scott Boehmke, one by one, individually, for the different beam angles 

for the boards in the mid-range cavity. He extended those lines or rays until it 

intersected this curved focal surface. The point of intersection defined the location for the laser 

diodes emitting surface. He then put that into his model, modeled a PCB behind that. 

(Haslim Tr. 199:18-201:4.)

C. Mr. Haslim’s Lack of Knowledge About Mr. Boehmke’s Pre-Ottomotto 

Documents Does Not Discredit Mr. Boehmke’s Independent Development 

Work 

In an effort to undermine Mr. Boehmke’s independent development work that led to Fuji, 

Waymo points to Mr. Haslim’s lack of knowledge about Uber’s “Plan B” design mentioned in a 

May 2016 document created by Mr. Boehmke. Mr. Haslim cannot be expected to testify about 

Mr. Boehmke’s document from May 2016, months before Mr. Haslim joined Uber as part of 

Uber’s acquisition of Ottomotto in August 2016. Mr. Boehmke explained at his deposition that 

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Uber’s Plan B design, referenced in his May 2016 “LiDAR Thoughts” document, became Fuji6: 

Mr. Haslim’s May 4 Deposition Mr. Boehmke’s Testimony

Q. I’ve marked as Exhibit 157 a document with 

the slip sheet labeled “Exhibit H.” And then 

the document underlying that says, “LiDAR 

Thoughts.” Is this a document that you were 

referring to before that Mr. Levandowski, 

Anthony Levandowski that is, called you about 

and discussed? 

THE WITNESS: No, this is not, to my 

recollection, the same document. There does 

appear to be some features in here, but for 

reasons I don’t understand, there seems to be 

pages I’m not familiar with. 

(Haslim Tr. at 138:14-24.) 

Q. And, actually, before we get there, going 

back to the first page, it’s dated May 16th, 

2016. You worked at Otto at that time; right? 

A. I believe I did, yes. 

Q. And you had had conversations with Mr. 

Boehmke by that time? 

A. Probably not. 

(Haslim Tr. at 139:6-12.)

Q Plan B was -- did it have a name other than 

plan B? 

A It turned into Fuji. 

Q And then what was plan C? 

A Plan C was the Spider. 

(Yang Ex. 3, Boehmke Tr. at 58:18-22) 

D. Mr. Haslim Confirmed His Independent Development of Fuji’s 

Transmit Block Configuration 

Waymo claims that Mr. Haslim “discredits” Defendants’ independent development of 

Fuji’s configuration (Br. at 8-9), but Mr. Haslim confirmed that he came up with the 

 transmit block configuration: 

Mr. Haslim’s May 4 Deposition

Q. Who was involved in coming up with ?

A: In coming up with ? I would say that was primarily me and the electrical engineer, 

Florin. 

(Haslim Tr. 72:15-20.) 

Q: Where did the idea to have come from? 

A: . The 

need to developed quickly between Florin and I. Looking at the size of 

the circuit, knowing when Scott Boehmke defines a certain 

, when Gaetan has designed a lens that has a 150 millimeter focal length, it becomes 

apparent that the 

. It was obvious to me that wasn't going to 

work and we would have to . Later we went back and looked closer, 

 

6

 Waymo argues that Mr. Boehmke is silent on the authorship of “LiDAR Thoughts” document 

(Br. at 13), but Mr. Boehmke confirmed that he “documented my thoughts for the 

dual-stack (‘Plan A’) and the Fuji device (‘Plan B’) in the May 2016 ‘LiDAR Thoughts.’” (Supp. 

Boehmke ¶ 15; see Boehmke Decl. Ex. H at 1 (Boehmke name and email on title page).) 

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and I realized, wait a minute, . So we can't put circuits on 

. Furthermore, 

we were starting to look at components on the receiver. We saw components on the receiver that 

were themselves . Those were high voltage components. They needed 

additional space between them as well. So it seemed pretty clear at the time 

 was not going to work, so we said ? Florin thought he could 

 So that ended up with . We already had decided two cavities to 

make 64 channels, so that ended up with in the sensor. 

(Haslim Tr. 77:15-78:21.)

Instead of addressing this evidence, Waymo mischaracterizes Mr. Haslim’s testimony and 

the demonstrative evidence in his declaration.7 Waymo touts Mr. Haslim’s statement that his 

October 28, 2016 email was “not indicative” of a design, but Mr. Haslim has always 

stated that the email showed a per cavity design. (Br. at 8; Haslim Decl. ¶ 11.) Waymo 

claims Mr. Haslim concedes there is “no documentary evidence” of the development timeline, but 

Mr. Haslim clarified that there were documents showing the beam angles, lens designs, and 

circuit design that led to the configuration: 

Mr. Haslim’s May 4 Deposition

Q. Okay. So there are no -- there's no documentary evidence to evidence -- to support what you 

just said? 

A. Not quite. We have documents showing and indicating to us what the vertical angles were to 

be for the sensor as specified by Scott Boehmke. We have a lens design that's documented from 

Gaetan. We have the original circuit Florin had developed for testing out lasers. At that point, the 

documentation stopped. And we don't have documents for discussions describing how 

. 

(Haslim Tr. 78:25-79:11.)

Finally, Waymo misstates Mr. Haslim’s testimony regarding Anthony Levandowski’s lack 

of involvement in the configuration: 

Waymo’s Supplemental Brief (Br. at 8-9) Mr. Haslim’s May 4 Deposition

Mr. Haslim explained that it was former 

Waymo engineer Gaetan Pennecot who 

primarily was responsible for the 

. (Id. at 262:3-

264:2.) 

Q. And so Mr. Pennecot was the one who 

actually came up with 

 based on Mr. Boehmke’s beam 

angles; isn’t that right? 

A. No, I don’t think so. 

( . . . .)

 

7

 Waymo attacks an annotated table included in Mr. Haslim’s declaration that demonstrates how 

the custom beam angles that were independently derived and provided by Mr. Boehmke in 

November 2016 are actually distributed across the (Figure 8.A) and the 

 (Figure 8.B) in the Fuji design. (Br. at 8-9) Mr. Haslim’s declaration clearly describes 

this annotation in his declaration, and Mr. Haslim never identifies the table as contemporaneous 

evidence of the configuration. (Supp. Haslim ¶ 17.) While Waymo makes much of the 

fact that this table was initially prepared by Uber’s counsel, Mr. Haslim testified that he checked 

to confirm the accuracy of these annotations before he signed his declaration. (Haslim Tr. 

234:1-235:16.) 

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Q. Who told Mr. Pennecot to use ? 

A. I told Mr. Pennecot to use in 

the optical cavity. 

(Haslim Tr. 262:14-263:11.)

And Mr. Haslim admitted that he did not know 

whether Mr. Pennecot discussed the design 

with Anthony Levandowski. (Id. at 74:1-10.) 

Q. So you’re not saying that Mr. Levandowski 

has never had discussions or input into the idea 

to use ; right? 

THE WITNESS: What I am saying is that 

Anthony never had input into my decision with 

my electrical engineer to put 

. 

(Haslim Tr. 74:11-17.) 

E. Mr. Haslim’s Testimony Does Not Discredit Mr. Gruver’s 

Testimony 

Waymo claims that Mr. Haslim discredited Mr. Gruver’s testimony that a 

 used . (Br. at 9-10; Yang Ex. 5, Gruver Tr. 51:4-52:1.) 

Mr. Haslim was , prior to the launch of the 

. (Haslim Decl. ¶ 3.) Nothing in his testimony discredits Mr. Gruver’s 

testimony. 

F. Mr. Haslim Confirmed That Fuji Does Not Use 

Waymo misstates Mr. Haslim’s testimony regarding the on the Fuji PCBs (Br. 

at 10). Mr. Haslim confirmed again that the : 

Mr. Haslim’s May 4 Deposition

Q. So the original idea was to ? 

A. No.

(Haslim Tr. 116:11-13.) 

Q. Are on Fuji boards? 

THE WITNESS: No. As I understand it, the 

 

BY MR. KIM: 

Q. Do you have an understanding as to why there are listed there? 

A. Yeah. As I was discussing earlier, my understanding is these coordinates referencing the 

 were generated early in the development of Fuji when 

. More specifically, these coordinates were given to the electrical engineer before the 

electrical engineer had laid out the circuits onto the board and added the fiducial mark onto the 

board. 

Q. Are there any plans at Uber to use on any transmit boards 

for Fuji? 

A. Not that I’m aware of. 

(Haslim Tr. 195:21-196:16.)

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G. Mr. Haslim’s Testimony Confirms That Is a 

Publicly Known Technique, Not a Waymo Trade Secret 

Waymo’s claim that Mr. Levandowski communicated a 

 to Mr. Haslim that “bears a striking resemblance to Waymo’s trade secret” (Br. 11-12) 

ignores Mr. Haslim’s testimony revealing that this design was “publicly-available information”: 

Mr. Haslim’s May 4 Deposition

Q. When you were asked whether or not he gave you any confidential information, you said you 

thought it was general information. What did you mean by that? 

A. I believe information Anthony provided regarding a was 

information that I’ve seen other places on the Internet as white papers, as publicly-available 

information in terms of architect or configuration for a laser. 

(Haslim Tr. 222:6-15.)

The circuit Mr. Haslim sketched at his deposition would bear a “striking resemblance” to 

any because the basic technique is standard and well-known in the 

fiber laser field. (Supp. Haslim Decl. ¶ 7; Supp. Lebby Decl. ¶ 42-44.) In his declaration, 

Mr. Haslim cited a 2011 published article that discusses 

and includes a diagram of the .

8

 Below is a comparison of Mr. Haslim’s 

sketch with: (1) Waymo’s alleged trade secret (left) and (2) 

from the 2011 published article (right). The components of the in 

Mr. Haslim’s sketch are present in the public diagram, including the 

. In fact, Mr. Haslim’s sketch more 

closely resembles the public diagram than it does Waymo’s alleged trade secret, since the sketch 

and the public diagram each contain only 

. In any event, the basic technology of is not proprietary 

to Waymo. 

 

8 See Grzegorz Sobon et al., Controlling the 1 μm spontaneous emission in Er/Yb co-doped fiber 

amplifiers, 19 Optics Express 19106 (2011) (Supp. Haslim ¶ 7 fn. 1) (publicly available at 

https://www.osapublishing.org/oe/fulltext.cfm?uri=oe-19-20-19104&id=222547. 

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 Mr. Haslim’s Sketch

Waymo’s Alleged Trade Secret 2011 Public Diagram 

H. Mr. Levandowski Did Not Have Substantive Technical Input to Fuji 

Waymo touts Mr. Levandowski’s personal involvement in Defendants’ LiDAR in terms 

of managerial activities (e.g., staff meetings), but omits Mr. Haslim’s testimony confirming the 

limited nature of Mr. Levandowski’s input on technical issues.9

Mr. Haslim’s May 4 Deposition

Q. Did Mr. Levandowski have any technical input for the Fuji design? 

A. To my recollection, the only potentially technical input Anthony Levandowski had on the 

Fuji design were telling us to make it as good as the Velodyne or better. To under-regard any 

concerns given to us from people in Pittsburgh regarding size and weight, that that should not be 

a prioritized requirement. 

(Haslim Tr. 221:15-24.)

Waymo challenges Mr. Haslim’s “investigation” of Mr. Levandowski’s involvement (Br. at 13), 

but Mr. Haslim, a non-30(b)(6) witness, properly testified based on his personal knowledge.10 

I. Mr. Haslim Had Limited Knowledge About Anthony Levandowski’s Laptop 

Waymo misrepresents Mr. Haslim’s testimony regarding Mr. Levandowski’s laptop 

(Br. 13-14). Contrary to Waymo’s suggestion, Mr. Haslim testified that he did not know if 

 

9

 Haslim Tr. at 133:2-6. 

10 Defendants described Mr. Levandowki’s LiDAR-related work in their Interrogatory Response 

No. 3 (ECF No. 264-4 at 3-5.) 

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Mr. Levandowksi brought his personal laptop to work: 

Mr. Haslim’s May 4 Deposition

Q. How often did Mr. Levandowski bring his personal laptop to work with him? 

THE WITNESS: I couldn’t possibly know. 

Q. Every day? 

THE WITNESS: The reason I couldn’t possibly know is I don’t know whether the laptop he may 

have carried was his personal laptop or the work laptop. 

(Haslim Tr. 41:1-10.) 

Q. You saw him at work with the personal laptop; right? 

A. I’m sure I’ve seen him at work with a laptop. 

(Haslim Tr. 41:19-21 (emphasis added.)

J. Anthony Levandowski Has Been Recused from All LiDAR Development 

Waymo claims that Mr. Levandowski’s recusal is ineffective because Mr. Haslim was 

unaware of a “formal company policy” restricting Mr. Levandowki’s work. (Br. at 14.) But 

Mr. Haslim, a key engineer in LiDAR development, confirmed that he “received an email” with 

instructions (Haslim Tr. 54:18-21): 

Mr. Haslim’s May 4 Deposition

 

(Haslim Tr. 55:6-12.) 

III. CONCLUSION11

The Court invited Waymo to submit any “home run” testimony it obtained from 

Mr. Haslim. In truth, there was none. Instead, Waymo presents a distorted, incomplete version 

of what Mr. Haslim said. And takes liberty with the Court’s limited invitation by submitting a 

substantive brief consisting of 15 pages of technical arguments, when no such leave was given. 

Accordingly, Waymo’s supplemental brief should be stricken. 

Alternatively, Defendants’ response to Waymo’s misrepresentations should be accepted, 

and at minimum, Defendants’ counter-designations of relevant testimony should be considered to 

complete the record. 

 

11 Waymo also makes irrelevant arguments relating to discrepancies between Mr. Haslim’s 

identification of LiDAR-related employees and suppliers with the list submitted to the Court by 

Defendants on April 5, 2017. (Br. 14-15.) At the Court’s request, Defendants will make an 

additional submission providing reasonable explanations for these discrepancies. 

Case 3:17-cv-00939-WHA Document 410 Filed 05/09/17 Page 11 of 12
DEFENDANTS’ RESPONSE TO WAYMO’S SUPPLEMENTAL BRIEF REGARDING HASLIM TESTIMONY

CASE NO. 3:17-cv-00939-WHA 11

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Dated: May 9, 2017 MORRISON & FOERSTER LLP

By: /s/Michael A. Jacobs

MICHAEL A. JACOBS 

Attorneys for Defendants 

UBER TECHNOLOGIES, INC. 

and OTTOMOTTO LLC 

Case 3:17-cv-00939-WHA Document 410 Filed 05/09/17 Page 12 of 12