## Facts

- Waymo LLC, a self-driving technology company, developed LiDAR-related technology used in autonomous vehicles and treated related design and engineering information as confidential.
- Waymo sued Uber Technologies, Inc. and related defendants, including former Waymo engineer Anthony Levandowski, alleging misappropriation of Waymo trade secrets (and related claims) tied to LiDAR development.
- Waymo presented evidence suggesting that shortly before leaving Waymo, Levandowski downloaded a large volume of files from Waymo’s secure systems, then departed under suspicious circumstances.
- After leaving, Levandowski helped start a competing venture (Otto/Ottomotto), and Uber quickly acquired the venture and installed Levandowski in a leadership role connected to Uber’s LiDAR efforts.
- Waymo’s preliminary showing was largely circumstantial but substantial, supporting inferences that Levandowski took confidential Waymo information and that Uber recruited and hired him with reason to suspect he possessed that information.
- Waymo sought broad preliminary injunctive relief that would, as a practical matter, derail Uber’s LiDAR work while the case proceeded, arguing that continued competition using Waymo’s information would cause harm not readily repaired by money damages.
- Uber opposed a sweeping injunction and argued that its work was, at least in significant part, independently developed and that Waymo had not justified stopping Uber’s overall LiDAR program at the preliminary stage.

## Issues

1. Whether Waymo satisfied the requirements for preliminary injunctive relief by showing a likelihood of success on its trade-secret misappropriation claims, a likelihood of irreparable harm, that the balance of equities favored relief, and that relief would serve the public interest.
2. If some preliminary relief was warranted, whether the court should impose Waymo’s requested broad restraints on Uber’s LiDAR program or instead craft narrower restrictions aimed at preventing use of Waymo’s alleged trade secrets and limiting Levandowski’s involvement.

## Decision

- The court **granted in part and denied in part** Waymo’s motion for a preliminary injunction.
- The court found Waymo’s preliminary evidence **strong but not airtight**, supporting a likelihood of success as to misappropriation or threatened use regarding at least some asserted LiDAR-related trade secrets.
- The court **declined to order a program-wide shutdown** of Uber’s LiDAR research and development based on the preliminary record.
- The court instead entered a **targeted injunction** focused on preventing use of Waymo’s confidential information, including restrictions centered on Levandowski’s role in LiDAR work at Uber and measures intended to prevent access to, retention of, or reliance on Waymo materials.
- The court ordered **compliance and verification steps** aimed at ensuring Waymo’s information was not used going forward (including measures commonly used in trade-secret cases such as segregation, return/non-use directives, and technical or forensic safeguards tailored to the record before the court).

## Legal Principles

- A preliminary injunction is an extraordinary remedy requiring the movant to show (1) likelihood of success on the merits, (2) likelihood of irreparable harm without relief, (3) that the balance of equities favors relief, and (4) that an injunction is in the public interest.
- In trade-secret cases, a plaintiff seeking interim relief must make a persuasive showing that it possesses protectable trade secrets and that the defendant acquired, used, or threatens to use them through improper means or in breach of a duty.
- When the record supports some risk of misuse but does not justify broad restraints, a court may craft narrower equitable relief aimed at preventing use or disclosure (for example, restricting an individual’s participation in certain work, requiring separation from sensitive projects, and ordering return/non-use and verification measures).
- In assessing irreparable harm, courts may credit evidence that loss of secrecy and loss of competitive lead in fast-moving technology markets can be difficult to repair with damages alone.
- The public interest includes both enforcing trade-secret law and avoiding unnecessary restraints on lawful competition; interim relief should be no broader than reasonably necessary to prevent threatened harm.

## Conclusion

In *Waymo LLC v. Uber Technologies*, the Northern District of California granted limited preliminary relief after finding Waymo’s evidence of LiDAR trade-secret theft compelling enough to justify safeguards, but not strong enough on the full requested scope to warrant halting Uber’s LiDAR program outright; the court therefore imposed narrower restrictions aimed at preventing use of Waymo information and limiting Levandowski’s involvement pending further proceedings.


Waymo LLC v. Uber Technologies, 2017 WL 2123560 (2017)