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Case 3:17-cv-00939-WHA Document 95 Filed 03/27/17 Page 1 of 2 1 MICHAEL A. JACOBS (CA SBN 111664) [email protected] 2 ARTURO J. GONZÁLEZ (CA SBN 121490) [email protected] 3 ERIC A. TATE (CA SBN 178719) [email protected] 4 MORRISON & FOERSTER LLP 425 Market Street 5 San Francisco, California 94105-2482 Telephone: 415.268.7000 6 Facsimile: 415.268.7522 7 KAREN L. DUNN (Pro Hac Vice app. pending) [email protected] 8 HAMISH P.M. HUME (Pro Hac Vice app. pending) [email protected] 9 BOIES SCHILLER FLEXNER LLP 1401 New York Avenue, N.W. 10 Washington DC 20005 Telephone: 202.237.2727 11 Facsimile: 202.237.6131 12 Attorneys for Defendants UBER TECHNOLOGIES, INC., 13 OTTOMOTTO LLC, and OTTO TRUCKING LLC 14 UNITED STATES DISTRICT COURT 15 NORTHERN DISTRICT OF CALIFORNIA 16 SAN FRANCISCO DIVISION 17 WAYMO LLC, Case No. 3:17-cv-00939-WHA 18 Plaintiff, UBER TECHNOLOGIES, INC., OTTOMOTTO LLC, AND OTTO 19 v. TRUCKING LLC’S ADMINISTRATIVE MOTION TO 20 UBER TECHNOLOGIES, INC., SHORTEN TIME FOR HEARING ON OTTOMOTTO LLC; OTTO TRUCKING LLC, DEFENDANTS’ MOTION TO 21 COMPEL ARBITRATION Defendants. 22 23 Complaint Filed: February 23, 2017 First Am. Compl. Filed: March 10, 2017 24 Trial Date: October 2, 2017 25 26 27 28 UBER’S ADMINISTRATIVE MOTION TO SHORTEN TIME FOR HEARING ON MOTION TO COMPEL Case No. 3:17-cv-00939-WHA sf-3752161 Case 3:17-cv-00939-WHA Document 95 Filed 03/27/17 Page 2 of 2 1 As the Court knows, a preliminary injunction hearing in this matter is scheduled for 2 May 4, 2017. At the case management conference, on March 16, 2017, counsel for Uber advised 3 the Court that it would be filing a petition to compel arbitration on the basis that Google’s 4 employment agreements contain very broad arbitration provisions. This Court then stated: “I 5 don’t want to go through the pain and suffering of a preliminary injunction hearing if it has to be 6 arbitrated, is the point. Think that through.” (González Decl. Ex. A at 15:12-14.) 7 Today, Uber is filing a Motion to Compel Arbitration of, and to Stay, Trade Secrets and 8 UCL Claims (“Motion”), and will set it for hearing on May 4, the same date as the preliminary 9 injunction. By this motion, Defendants ask that the Court set the following schedule for the 10 Motion to Compel Arbitration: 11 Waymo’s Opposition to the Motion: April 3, 2017: 12 Defendants’ Reply In Support of Their Motion: April 6, 2017 13 Hearing on the Motion: April 13, 2017 14 This proposed schedule would have the Court consider this Motion three weeks before the 15 hearing on preliminary injunction. Plaintiff has advised us that it opposes this request on the 16 basis that even if this motion is granted, there will still be a hearing on its motion for preliminary 17 injunction pertaining to the four patent claims at issue. (González Decl. ¶ 3, Ex. B.) That may 18 be true, but that would be a very different hearing. 19 Dated: March 27, 2017 MORRISON & FOERSTER LLP 20 By: /s/ Arturo J. González 21 ARTURO J. GONZÁLEZ 22 Attorneys for Defendants UBER TECHNOLOGIES, INC., 23 OTTOMOTTO LLC, and OTTO TRUCKING LLC 24 25 26 27 28 UBER’S ADMINISTRATIVE MOTION TO SHORTEN TIME FOR HEARING ON MOTION TO COMPEL Case No. 3:17-cv-00939-WHA 1 sf-3752161 .

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