Less than 20 days after filing a lawsuit against Motive, trucking telematics and fleet management platform Samsara filed a complaint against its rival with the International Trade Commission. The complaint relates to Samsara’s Vehicle Gateway and Dashcams and includes 77 pieces of evidence.
To Samsara, a successful ITC review and investigation would lead to “an exclusion order to prevent Motive's Vehicle Gateway and Dashcam products from being imported into the United States” and “a cease-and-desist order to prohibit Motive from selling, marketing, advertising, or distributing its Vehicle Gateway and Dashcams on the grounds that these products infringe certain of Samsara's patents,” said Aiden Ryan, SVP crisis and risk, U.S. Litigation and Legal Affairs for Edelmen, representing Samsara.
The 39-page complaint includes evidence of Motive’s alleged infringement on three of Samsara’s patents—the same patents listed in the lawsuit:
U.S. Patent No. 11,190,373 (“Vehicle Gateway Device and Interactive Graphical User Interfaces Associated Therewith”)
U.S. Patent No. 11,127,130 (“Machine Vision System and Interactive Graphical User Interfaces Related Thereto”)
U.S. Patent No. 11,611,621 (“Event Detection System”)
Along with Samsara’s two specific requests from the ITC listed above, the complaint also includes additional requests to the commission, each summarized below:
Investigate Motive for the importation and sale of products that infringe on Samsara’s patents in violation of Section 337 of the Tariff Act of 1930
Conduct a hearing to receive evidence to discover if Motive violated Section 337 of the Tariff Act of 1930
Issue an exclusion order of products “manufactured, designed, offered for sale, and/or sold” by Motive if the product infringes upon one of Samsara’s patents
Issue a permanent cease and desist order prohibiting Motive from selling, distributing, advertising, or marketing products that infringe upon Samsara’s patents
Impose a bond on Motive’s products that infringe upon Samsara’s patents throughout a 60-day investigation
Issue “further relief as the Commission deems just and proper under the law” based on the facts determined from an investigation
The complaint also mentioned the lawsuit between the companies, filed on January 24. Samsara accused Motive of ongoing intellectual property theft, patent infringement, false advertising, and other illegal conduct.
In response to the lawsuit, Motive CEO Shoaib Makani told FleetOwner via email, “Samsara’s allegations and associated campaign against Motive are meritless. They are a result of Samsara’s inability to develop competitive AI technology and the fact that they are losing customers, especially large enterprise accounts, to Motive. This courtroom tactic is an attempt to limit competition, and we will fight these baseless accusations to the fullest extent.”
Motive maintained a similar position in response to the Samsara ITC complaint filing.
“This legal maneuver is yet another attempt by Samsara to limit competition after failing to develop competitive AI technology,” Makani told FleetOwner via email. “More than 30 Samsara employees, including Samsara’s leadership team, have illegally used Motive’s product dating back to 2016 to copy its functionality. Motive will fight this anti-competitive behavior to the fullest extent.”
While the lawsuit addresses product infringement and Motive’s behavior, the ITC filing focuses solely on the products. After reviewing the complaint, the ITC will choose whether to investigate these allegations against Motive. If the ITC finds evidence that Motive violated Section 337 of the Tariff Act of 1930, the outcome would have “immediate impact on (Motive’s) ability to sell and service those products,” Ryan said.