DCT

5:21-cv-09775

Keep Truckin Inc v. Fleet Connect Solutions LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 5:21-cv-09775, N.D. Cal., 07/28/2023
  • Venue Allegations: Venue is asserted as proper because Defendant Fleet Connect has purposefully availed itself of the jurisdiction by filing patent infringement claims and counterclaims against Plaintiff Motive in the Northern District of California.
  • Core Dispute: Plaintiff Motive seeks a declaratory judgment that it does not infringe, and that are invalid, twenty U.S. patents owned by Defendant Fleet Connect relating to fleet management, vehicle tracking, and wireless communication technologies.
  • Technical Context: The technology concerns systems for monitoring, managing, and communicating with mobile assets, a critical function in the modern logistics, transportation, and physical economy sectors.
  • Key Procedural History: This consolidated complaint arises from three separate actions involving the parties, including two prior lawsuits filed by Fleet Connect against Motive's customers, which prompted Motive to file initial declaratory judgment actions. The complaint includes detailed invalidity contentions, alleging that numerous asserted patents are invalid for adding "new matter" during prosecution in violation of 35 U.S.C. §§ 112 and 132. For U.S. Patent No. 8,494,581, the complaint notes that claims 1-20 and 24 were cancelled in prior Inter Partes Review and Ex Parte Reexamination proceedings.

Case Timeline

Date Event
1999-09-10 Priority Date for '270, '955, '896, '189, '715, '391, '304, '291, '723 Patents
2000-02-01 Priority Date for '810 Patent
2000-09-18 Priority Date for '586 Patent
2001-07-20 Priority Date for '583, '616 Patents
2002-08-06 Issue Date for U.S. Patent No. 6,429,810
2003-04-15 Issue Date for U.S. Patent No. 6,549,583
2003-10-14 Issue Date for U.S. Patent No. 6,633,616
2003-11-11 Issue Date for U.S. Patent No. 6,647,270
2004-03-02 Priority Date for '040, '845 Patents
2004-04-22 Priority Date for '153 Patent
2005-11-01 Issue Date for U.S. Patent No. 6,961,586
2006-06-06 Issue Date for U.S. Patent No. 7,058,040
2006-08-15 Issue Date for U.S. Patent No. 7,092,723
2006-09-12 Priority Date for '837 Patent
2007-04-17 Issue Date for U.S. Patent No. 7,206,837
2007-08-21 Issue Date for U.S. Patent No. 7,260,153
2008-11-11 Issue Date for U.S. Patent No. 7,450,955
2008-12-09 Issue Date for U.S. Patent No. 7,463,896
2009-05-19 Issue Date for U.S. Patent No. 7,536,189
2009-09-29 Issue Date for U.S. Patent No. 7,596,391
2009-10-06 Issue Date for U.S. Patent No. 7,599,715
2010-02-02 Issue Date for U.S. Patent No. 7,656,845
2010-06-10 Priority Date for '388 Patent
2010-06-22 Issue Date for U.S. Patent No. 7,742,388
2010-06-29 Issue Date for U.S. Patent No. 7,747,291
2010-08-24 Issue Date for U.S. Patent No. 7,783,304
2011-08-23 Issue Date for U.S. Patent No. 8,005,053
2013-07-23 Issue Date for U.S. Patent No. 8,494,581
2013-08-01 Motive (as Keep Truckin) Founded (Compl. ¶46)
2019-07-23 IPR Certificate cancels claims 1-17 of the '581 Patent (Compl. ¶27)
2019-10-29 Reexam Certificate cancels claims 18-20 and 24 of the '581 Patent (Compl. ¶27)
2020-08-27 Fleet Connect sends notice letter to Motive (Compl. ¶49)
2021-09-24 Fleet Connect files first suits against Motive customers (Compl. ¶53)
2021-12-21 Case No. 5:21-cv-09775 filed by Motive
2022-08-23 Fleet Connect files suit against another Motive customer (Compl. ¶57)
2022-10-14 Case No. 4:22-cv-06083 filed by Motive
2023-02-20 Case No. 5:23-cv-00757 filed by Fleet Connect against Motive (Compl. ¶60)
2023-05-15 Court consolidates the three actions (Compl. ¶64)
2023-07-28 Consolidated Complaint filed (Compl. p. 1)

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 6,429,810 - "Integrated Air Logistics System", Issued August 6, 2002

The Invention Explained

  • Problem Addressed: The patent describes the process of tracking freight, particularly air cargo, as "extremely difficult and typically very labor intensive" due to the involvement of multiple independent companies, last-minute shipping changes, and the reliance on manual data input such as bar code scanning, which is prone to error and delay (’810 Patent, col. 1:18-2:10).
  • The Patented Solution: The invention proposes an autonomous cargo tracking system featuring a "position sensing and communication (PSC) unit" that is affixed to a shipping container (’810 Patent, col. 2:16-24; Fig. 1). This unit uses a GPS satellite constellation to determine its location and a separate communication satellite constellation to report its position and other sensor data (e.g., temperature, container status) to a ground system, which then makes the information available to users, preferably via an internet website (’810 Patent, col. 2:33-44).
  • Technical Importance: The invention describes a shift from manual, labor-intensive tracking methods to an automated, autonomous system that provides more accurate and timely cargo status information to shippers and forwarders (’810 Patent, col. 2:11-15).

Key Claims at a Glance

  • The complaint identifies exemplary independent claim 1 (Compl. ¶69).
  • Essential elements of claim 1, a method of providing container status information, include:
    • attaching an electronic communications unit to a shipping container;
    • generating a transaction identification code specific to the container and a user transaction;
    • a user initiating a status inquiry using the code;
    • a ground communications system receiving the inquiry;
    • the ground system transmitting the inquiry to the electronic unit;
    • the electronic unit obtaining a status information response;
    • the electronic unit transmitting the response back to the ground system; and
    • the ground system forwarding the response to the user.
  • The complaint notes that Fleet Connect asserts infringement of claims 1-11, 16-24, 28, 30-38, and 43-47 (Compl. ¶68).

U.S. Patent No. 6,647,270 - "Vehicletalk", Issued November 11, 2003

The Invention Explained

  • Problem Addressed: The patent addresses the limitations of conventional mobile communication systems like cellular phones and CB radios, noting the difficulty in identifying and contacting nearby vehicle operators and the lack of privacy in broadcast mediums (’270 Patent, col. 1:15-33).
  • The Patented Solution: The invention is a mobile communication system allowing vehicles to communicate with each other and with roadside networks (’270 Patent, col. 1:9-14). Each mobile unit includes a transceiver, a GPS receiver for position data, and a microprocessor (’270 Patent, Fig. 2). The microprocessor constructs data packets that include a unique identifier for the sender, information derived from its GPS position, and the address of a desired remote unit, enabling targeted inter-vehicle communication (’270 Patent, col. 6:47-7:20).
  • Technical Importance: The technology aimed to create a direct communication link among vehicles, potentially improving driving experience and safety by moving beyond the limitations of existing cellular and radio technologies (’270 Patent, col. 2:34-42).

Key Claims at a Glance

  • The complaint identifies exemplary independent claim 1 (Compl. ¶94).
  • Essential elements of claim 1, a system for transmitting communications, include a plurality of remote units, each having:
    • a memory for storing a unique identifier;
    • a transceiver for wireless communication (RF to baseband and vice versa);
    • a GPS receiver for outputting a position signal;
    • a microprocessor for receiving the position signal and downconverted communication, and for generating baseband communication;
    • whereby the microprocessor generates data packets including sender information (unique ID and position-derived info) and receiver information (the address of the desired remote unit).
  • The complaint notes that Fleet Connect asserts infringement of claims 1-6, 10, 11, 13, and 18 (Compl. ¶93).

U.S. Patent No. 7,450,955 - "System and Method for Tracking Vehicle Maintenance Information", Issued November 11, 2008

  • Technology Synopsis: The patent describes a method for a system administrator to track vehicle maintenance. The system identifies a vehicle, determines an associated warning, generates a data packet with the warning, and transmits it to a receiving mobile unit, which can then confirm receipt (’955 Patent, Abstract). The complaint alleges this patent is invalid for adding new matter during prosecution (Compl. ¶¶34-35, 139).
  • Asserted Claims: 1, 2, 4-7, 9, 10, 24, 25, 27, 28, 30, and 31 (Compl. ¶118).
  • Accused Features: The complaint alleges that Motive's Accused Products do not satisfy at least limitations 1[c], 1[e], and 1[f] of claim 1 (Compl. ¶122).

U.S. Patent No. 7,463,896 - "System and Method for Enforcing a Vehicle Code", Issued December 9, 2008

  • Technology Synopsis: The patent discloses a method for enforcing a vehicle code. A first mobile unit receives a wireless signal from a second mobile unit associated with a vehicle, determines a vehicle identifier and GPS position, and allows a system administrator to determine the vehicle's status for code enforcement (’896 Patent, Abstract). The complaint alleges this patent is invalid for adding new matter during prosecution (Compl. ¶¶36-37, 165).
  • Asserted Claims: 1-4, 8, 11, 12, 14-17, 19, 21-23, 27, and 29-30 (Compl. ¶144).
  • Accused Features: The complaint alleges that Motive's Accused Products do not satisfy at least limitation 1[f] of claim 1 (Compl. ¶148).

U.S. Patent No. 7,536,189 - "System and Method For Sending Broadcasts in a Social Network", Issued May 19, 2009

  • Technology Synopsis: The patent describes a method for a system administrator to broadcast an advisory communication to remote units via a website. The method involves accessing the website, filtering a plurality of remote units based on an information field, assembling a data or voice message packet, and transmitting it to the filtered units (’189 Patent, Abstract). The complaint alleges this patent is invalid for adding new matter during prosecution (Compl. ¶¶38-39, 189).
  • Asserted Claims: 1, 3, 4, 6, 7, 9, 14, 15, 17, 20, 29, 31-33, 35-37, 39, 44, 45, 49, 51, and 53 (Compl. ¶170).
  • Accused Features: The complaint alleges that Motive's Accused Products do not satisfy at least limitations 1[b], 1[c], and 1[e] of claim 1 (Compl. ¶174).

U.S. Patent No. 7,596,391 - "System and Method for Wireless Communication Between a Vehicle and a Mobile Unit", Issued September 29, 2009

  • Technology Synopsis: This patent relates to a method of wireless communication where a mobile unit receives a signal from a vehicle's transceiver, determines if the signal is authorized by parsing a security field, accepts a control instruction from the user, and transmits it to the vehicle (’391 Patent, Abstract). The complaint alleges this patent is invalid for lacking written description (Compl. ¶214).
  • Asserted Claims: 1, 7-11, 15, and 28 (Compl. ¶194).
  • Accused Features: The complaint alleges that Motive's Accused Products do not satisfy at least limitations 1[c] and 1[g] of claim 1 (Compl. ¶198).

U.S. Patent No. 7,599,715 - "System and Method for Matching Wireless Devices", Issued October 6, 2009

  • Technology Synopsis: The technology involves tracking vehicle maintenance information by receiving a signal with a vehicle identifier and status, determining associated maintenance information, constructing a communication packet, and transmitting it over the Internet to a specified address (’715 Patent, Abstract). The complaint alleges this patent is invalid for adding new matter during prosecution (Compl. ¶¶40-41, 239).
  • Asserted Claims: Claim 31 (Compl. ¶219).
  • Accused Features: The complaint alleges that Motive's Accused Products do not satisfy at least limitation 31[d] of claim 31 (Compl. ¶223).

U.S. Patent No. 7,742,388 - "Packet Generation Systems and Methods", Issued June 22, 2010

  • Technology Synopsis: The patent describes a method of increasing the size of a data packet for network transmission by adding subcarriers to a training symbol within the packet's preamble, creating an "extended packet" for transmission (’388 Patent, Abstract).
  • Asserted Claims: 1, 3-5, 7-9, 11, 12, and 20 (Compl. ¶244).
  • Accused Features: The complaint broadly alleges non-infringement of all asserted claims (Compl. ¶246).

U.S. Patent No. 7,783,304 - "Wireless Communication Method", Issued August 24, 2010

  • Technology Synopsis: This patent describes a method for a first mobile unit to communicate with a second mobile unit via a website. It involves establishing a link, searching a user list, constructing a communication with addresses for both units, and transmitting it through the website (’304 Patent, Abstract). The complaint alleges this patent is invalid for adding new matter during prosecution (Compl. ¶¶42-43, 281).
  • Asserted Claims: 1-3, 8-11, and 16-18 (Compl. ¶263).
  • Accused Features: The complaint alleges that Motive's Accused Products do not satisfy at least limitations 1[d] and 1[e] of claim 1 (Compl. ¶267).

U.S. Patent No. 8,005,053 - "Channel Interference Reduction", Issued August 23, 2011

  • Technology Synopsis: The patent discloses an apparatus with two wireless transceivers configured for different wireless protocols. A controller selects one transceiver to communicate data of both protocols, encoding the data from the unselected protocol into the protocol of the selected transceiver to mitigate interference (’053 Patent, Abstract).
  • Asserted Claims: 1, 3, 6, 7, 10-12, 15, 16, and 19 (Compl. ¶286).
  • Accused Features: The complaint alleges that Motive's Accused Products do not satisfy at least limitation 1[d] of claim 1 (Compl. ¶290).

U.S. Patent No. 6,549,583 - "Optimum Phase Error Metric for OFDM Pilot Tone Tracking in Wireless LAN", Issued April 15, 2003

  • Technology Synopsis: The technology relates to a method of pilot phase error estimation in an Orthogonal Frequency Division Multiplexed (OFDM) receiver. It involves estimating an aggregate phase error of a data symbol relative to pilot reference points using a maximum likelihood-based estimation to improve signal tracking (’583 Patent, Abstract).
  • Asserted Claims: 1, 3, 4, 13-15, and 25 (Compl. ¶309).
  • Accused Features: The complaint alleges that Motive's Accused Products do not satisfy at least limitation 1[c] of claim 1 (Compl. ¶313).

U.S. Patent No. 6,633,616 - "OFDM Pilot Tone Tracking for Wireless LAN", Issued October 14, 2003

  • Technology Synopsis: The patent describes a method of pilot phase error estimation in an OFDM receiver where the phase error estimate is determined in a parallel path to Fast Fourier Transform processing. This is intended to complete the phase error estimate before the data symbol processing is completed, improving tracking (’616 Patent, Abstract).
  • Asserted Claims: 12-14 (Compl. ¶327).
  • Accused Features: The complaint alleges that Motive's Accused Products do not satisfy at least limitation 12[b] of claim 12 (Compl. ¶331).

U.S. Patent No. 7,092,723 - "System and Method for Communicating Between Mobile Units", Issued August 15, 2006

  • Technology Synopsis: The patent describes a vehicle configured to communicate data packets. The vehicle includes a GPS receiver, a remote unit with memory for a unique ID, and a microprocessor that generates a baseband communication including sender ID, position-derived information, and a destination address (’723 Patent, Abstract).
  • Asserted Claims: 1, 2-7, 9-12, 14-17, 19, and 20 (Compl. ¶344).
  • Accused Features: The complaint alleges that Motive's Accused Products do not satisfy at least limitation 1[g] of claim 1 and the Preamble of claim 19 (Compl. ¶349).

U.S. Patent No. 7,206,837 - "Intelligent Trip Status Notification", Issued April 17, 2007

  • Technology Synopsis: The technology involves a method for providing trip status by estimating time-of-arrival bounds for a mobile device in transit. The estimation is based on the device's location and at least one historical travel time statistic, with the bounds then sent to the device (’837 Patent, Abstract).
  • Asserted Claims: 1, 2, 3, and 6 (Compl. ¶362).
  • Accused Features: The complaint alleges that Motive's Accused Products do not satisfy at least limitation 1[b] of claim 1 (Compl. ¶366).

U.S. Patent No. 7,260,153 - "Multi Input Multi Output Wireless Communication Method...", Issued August 21, 2007

  • Technology Synopsis: The patent describes a method for evaluating a channel in a multiple-input multiple-output (MIMO) wireless system. It involves defining a channel matrix metric related to cross-talk signal-to-noise ratio and calculating a crosstalk measure for data sub-streams using singular value decomposition (SVD) of the channel matrix (’153 Patent, Abstract).
  • Asserted Claims: 1, 2, 3, 19, 28, 29, and 30 (Compl. ¶379).
  • Accused Features: The complaint alleges that Motive's Accused Products do not satisfy at least the Preamble of claim 1 (Compl. ¶383).

U.S. Patent No. 7,058,040 - "Channel Interference Reduction", Issued June 6, 2006

  • Technology Synopsis: This patent describes a method for data transmission over two media that overlap in frequency. It involves computing and allocating shared time-division multiple access (TDMA) time-slot channels between the two media to manage interference and dynamically adjusting the allocation based on a desired level of service (’040 Patent, Abstract).
  • Asserted Claims: 1-3, 7-9, and 11 (Compl. ¶396).
  • Accused Features: The complaint makes a general allegation of non-infringement (Compl. ¶397).

U.S. Patent No. 7,656,845 - "Channel Interference Reduction", Issued February 2, 2010

  • Technology Synopsis: The patent discloses an apparatus with two transceivers for different media. A controller selects one medium as a common medium for data transmission and instructs both transceivers to communicate through it to avoid interference (’845 Patent, Abstract).
  • Asserted Claims: 12 and 18 (Compl. ¶410).
  • Accused Features: The complaint makes a general allegation of non-infringement (Compl. ¶411).

U.S. Patent No. 7,747,291 - "Wireless Communication Method", Issued June 29, 2010

  • Technology Synopsis: The patent covers a method of communicating with a mobile unit by determining its status, constructing a data packet with an address and identifier, and transmitting it. The status determination involves parsing a received signal to identify the unit and its status (’291 Patent, Abstract). The complaint alleges this patent is invalid for adding new matter during prosecution (Compl. ¶¶44-45, 436).
  • Asserted Claims: 1-3, 5-9, 11-18, and 20-22 (Compl. ¶425).
  • Accused Features: The complaint makes a general allegation of non-infringement (Compl. ¶426).

U.S. Patent No. 8,494,581 - "System and Methods for Management of Mobile Field Assets...", Issued July 23, 2013

  • Technology Synopsis: This patent describes systems for conducting field assessments using handheld devices. The system provides assessors with portable access to industry-specific programs and data, with data synchronization enabled by wireless capabilities (’581 Patent, Abstract). The complaint notes that most asserted claims have been cancelled through post-grant proceedings (Compl. ¶27).
  • Asserted Claims: 1-3, 5-22, and 24 (now cancelled) (Compl. ¶440).
  • Accused Features: The complaint alleges non-infringement of all asserted claims (Compl. ¶441).

U.S. Patent No. 6,961,586 - "Field Assessments Using Handheld Data Management Devices", Issued November 1, 2005

  • Technology Synopsis: This patent is related to the '581 patent and describes systems for executing field assessments using handheld devices. It enables assessors to access industry-specific programs and data, with wireless capabilities allowing for data synchronization with a remote server (’586 Patent, Abstract).
  • Asserted Claims: 1-11, 13-16, 18-21, 23-26, and 28 (Compl. ¶457).
  • Accused Features: The complaint alleges non-infringement of all asserted claims (Compl. ¶458).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the "Accused Products" as a suite of fleet management hardware and software, including the Motive/KeepTruckin Asset Tracking System, Asset Gateway, Vehicle Gateway, AI Dashcam, Smart Dashcam, GPS Tracking Application, and the Motive/KeepTruckin Driver app (Compl. ¶66).

Functionality and Market Context

  • The complaint describes Motive as a leader in fleet management technology, providing AI-powered hardware and cloud-based software to automate business operations in the "physical economy" (Compl. ¶46).
  • The functionality of the accused products includes video-based driver safety, Electronic Logging Device (ELD) compliance, GPS tracking, dispatch, and fuel and maintenance management (Compl. ¶46). These products are sold to a range of customers from small trucking companies to large enterprises (Compl. ¶46).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

The complaint, a declaratory judgment action, does not contain detailed infringement allegations from the patentee, Fleet Connect. It references claim charts sent in a pre-suit letter but does not attach them (Compl. ¶51). Instead, the complaint lays out the language of exemplary claims and then makes categorical denials of infringement for specific limitations without mapping accused product features to the claims. Therefore, a claim chart summarizing the infringement theory cannot be constructed from the complaint. The analysis below summarizes Motive's stated non-infringement positions.

  • '810 Patent Infringement Allegations

    • Motive alleges that its Accused Products do not infringe because they fail to satisfy at least limitations 1[Preamble], 1[a], 1[b], and 1[c] of claim 1 (Compl. ¶72). These elements relate to a method of providing container status, attaching a unit to a shipping container, generating a transaction code specific to that container, and a user initiating an inquiry.
    • Identified Points of Contention: A central question may be one of scope: whether Motive's systems, which are generally associated with vehicles like trucks rather than standalone shipping containers, practice the specific steps of the claimed method. The dispute may turn on whether attaching a gateway to a truck or trailer can be construed as "attaching an electronic communications unit to a shipping container" as required by claim 1[a].

  • '270 Patent Infringement Allegations

    • Motive alleges its products do not satisfy at least limitations 1[Preamble] and 1[g] of claim 1 (Compl. ¶97). These elements relate to a system for communication between a plurality of remote units, where the generated data packet includes "the address of the desired remote unit."
    • Identified Points of Contention: An issue may arise regarding the architecture of the accused system. The dispute may focus on whether Motive's system, which likely involves communication between a vehicle gateway and a central server, constitutes communication between "remote units" where one unit's transmission packet includes the "address" of another remote unit as required by claim 1[g], or if it operates on a different client-server model.

V. Key Claim Terms for Construction

  • For the '810 Patent:

    • The Term: "shipping container" (from claim 1[a])
    • Context and Importance: The construction of this term appears central to the infringement analysis. Practitioners may focus on this term because the patent's context is air logistics and cargo containers, while Motive's products are primarily for vehicle fleet management. The dispute may turn on whether a truck, trailer, or other vehicle asset falls within the scope of a "shipping container."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent does not appear to provide an explicit definition limiting the term. A party might argue that in the context of logistics, any vessel that contains goods for transport, including a truck's trailer, could be considered a "shipping container."
      • Evidence for a Narrower Interpretation: The specification repeatedly refers to "air cargo" (’810 Patent, col. 1:12), "cargo unit load device (ULD)" (’810 Patent, col. 2:36–37), and illustrates the invention in the context of items loaded onto aircraft (’810 Patent, Fig. 5). This context may support a narrower construction limited to intermodal containers or ULDs used in air and sea freight.

  • For the '270 Patent:

    • The Term: "remote unit" (from claim 1 Preamble)
    • Context and Importance: The claim requires communication "between a plurality of remote units." The nature of the accused system's architecture will be critical. The dispute may hinge on whether a vehicle gateway and a back-end server are both considered "remote units" in the sense contemplated by the patent, or if the patent requires a more peer-to-peer style of communication.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the system as allowing "mobile vehicles to communicate with neighboring vehicles and roadside communication networks" (’270 Patent, col. 1:11-14). A party could argue that a "remote unit" is any distinct node in the communication system, including a fixed roadside network component or a central server.
      • Evidence for a Narrower Interpretation: The title "Vehicletalk" and the background's focus on "vehicle to vehicle communication" suggest the invention's focus is on direct or indirect communication between mobile entities (’270 Patent, col. 1:15-18). Embodiments describe communication between mobile units 16 and base stations 14, which could be argued to represent two distinct types of entities, rather than a homogenous group of "remote units" that includes servers (’270 Patent, Fig. 1).

VI. Other Allegations

  • Indirect and Willful Infringement: Motive does not plead facts supporting these claims, as it is the plaintiff seeking a declaratory judgment. However, the complaint notes that in its counterclaims and infringement contentions, Fleet Connect has alleged that Motive "has directly, indirectly and willfully infringed" the patents-in-suit (Compl. ¶¶68, 93, 118). The basis for these allegations is not detailed in Motive's complaint.

VII. Analyst’s Conclusion: Key Questions for the Case

  • A primary issue will be one of invalidity based on prosecution history: can the numerous patents challenged by Motive for allegedly adding "new matter" during prosecution survive scrutiny under 35 U.S.C. §§ 112 and 132? This question will require a detailed analysis of the original patent applications versus the issued claims, and if Motive's allegations are substantiated, it could invalidate entire families of the asserted patents.
  • A second core issue will be one of definitional scope and technological mismatch: does the terminology used in patents directed at discrete technologies (e.g., "shipping container" in air logistics, peer-to-peer "Vehicletalk") read on the functionality of Motive's integrated, server-based fleet management platform? The outcome will likely depend heavily on claim construction.
  • A final key question will be validity over prior art: for the patents not challenged on "new matter" grounds, the dispute will center on whether the claimed inventions were truly novel and non-obvious. Motive's complaint provides exemplary prior art references for each patent family, setting the stage for a conventional, but technically complex, invalidity battle.