DCT
1:24-cv-00084
Samsara Inc v. Motive Tech Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Samsara Inc. (Delaware)
- Defendant: Motive Technologies Inc. (Delaware)
- Plaintiff’s Counsel: Shaw Keller LLP; Kirkland & Ellis LLP
- Case Identification: 1:24-cv-00084, D. Del., 01/24/2024
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant Motive Technologies Inc. is a Delaware corporation and therefore resides in the state.
- Core Dispute: Plaintiff alleges that Defendant’s vehicle telematics and fleet management platform infringes three patents related to fuel efficiency scoring, machine vision systems, and event detection, alongside claims of false advertising, fraud, and computer abuse.
- Technical Context: The technology relates to Internet of Things (IoT) data-driven platforms for managing commercial vehicle fleets, a market focused on improving safety, efficiency, and operational visibility through telematics and AI.
- Key Procedural History: The complaint alleges that Plaintiff informed Defendant of its patent portfolio on September 26, 2023, and provided notice of the specific patents-in-suit with infringement claim charts on January 23, 2024, one day before filing suit. No prior litigation or administrative proceedings are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2018-06-01 | Motive (as KeepTruckin) allegedly launched its imitation "Smart Dashcam" |
| 2019-01-01 | Motive allegedly launched its "Motive Vehicle Gateway" |
| 2019-04-09 | Earliest Priority Date for U.S. Patent No. 11,127,130 |
| 2019-04-26 | Earliest Priority Date for U.S. Patent No. 11,611,621 |
| 2020-05-01 | Earliest Priority Date for U.S. Patent No. 11,190,373 |
| 2021-08-01 | Motive (as KeepTruckin) allegedly launched its "AI Dashcam" |
| 2021-09-21 | U.S. Patent No. 11,127,130 Issued |
| 2021-11-30 | U.S. Patent No. 11,190,373 Issued |
| 2023-03-21 | U.S. Patent No. 11,611,621 Issued |
| 2024-01-24 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,190,373 - "Vehicle Gateway Device and Interactive Graphical User Interfaces Associated Therewith," Issued Nov. 30, 2021
The Invention Explained
- Problem Addressed: The patent describes the difficulty for commercial fleet operators in determining why and how fuel and energy are used across a diverse and complex fleet of vehicles, and the technical challenges in collecting and comparing voluminous data across different fleets (Compl. ¶108; ’373 Patent, col. 1:64-2:5).
- The Patented Solution: The invention is a system comprising vehicle gateway devices and a central computing device. The gateways gather vehicle metric data, which the computing device receives from a plurality of vehicles. The computing device then determines fuel/energy usage, identifies correlations between that usage and other vehicle metrics (like idling or speeding), calculates weightings for those metrics, and generates a "fuel/energy efficiency score" for a specific vehicle that is then presented to the user (’373 Patent, col. 2:5-3:13).
- Technical Importance: The solution provides a method for standardizing and comparing fuel efficiency across different vehicles and fleets, offering operators actionable, data-driven insights beyond simple miles-per-gallon metrics (’373 Patent, col. 3:27-4:13).
Key Claims at a Glance
- Independent Claim 15 is asserted (Compl. ¶107).
- Essential elements of Claim 15 include:
- A first vehicle gateway device to gather and transmit first vehicle metric data.
- A computing device configured to:
- Receive vehicle metric data from a plurality of vehicle gateway devices.
- Determine fuel/energy usage of the plurality of vehicles over time.
- Determine correlations among other vehicle metrics and the fuel/energy usage.
- Determine weightings of the other vehicle metrics based on the correlations.
- Receive the first vehicle metric data from the first vehicle gateway device.
- Determine a fuel/energy efficiency score for the first vehicle based on the weightings and its metric data.
- Cause the score to be provided in a user interface.
- The complaint reserves the right to assert other claims (Compl. ¶129).
U.S. Patent No. 11,127,130 - "Machine Vision System and Interactive Graphical User Interfaces Related Thereto," Issued Sep. 21, 2021
The Invention Explained
- Problem Addressed: The patent addresses the difficulty of configuring, managing, and gathering data from machine vision systems (or "smart cameras"), especially for non-technical users, which rendered real-time analysis across multiple devices impossible or impractical (’130 Patent, col. 2:1-17; Compl. ¶115).
- The Patented Solution: The patent describes a machine vision system that locally acquires, processes, and evaluates an image to identify features. The system then locally stores the image and its evaluation, transmits both for remote storage, and includes a web server to provide secure remote access to the stored image and evaluation (’130 Patent, Abstract; col. 3:22-56).
- Technical Importance: This architecture enables a centrally managed, easy-to-deploy system where smart cameras can operate autonomously but also be monitored and configured remotely, combining local processing with cloud-based access and analysis (’130 Patent, col. 3:50-62).
Key Claims at a Glance
- Independent Claim 1 is asserted (Compl. ¶114).
- Essential elements of Claim 1 include:
- An image sensor.
- A computer-readable storage medium with program instructions, including a web server for communication.
- One or more processors configured to execute instructions to cause the system to:
- Acquire an image via the image sensor.
- Process the image to identify one or more features.
- Determine an evaluation of the image based on the features.
- Locally store the image and the evaluation.
- Transmit the image and evaluation for remote storage.
- Execute the web server to provide secure remote access to the image and evaluation.
- The complaint reserves the right to assert other claims (Compl. ¶155).
U.S. Patent No. 11,611,621 - "Event Detection System," Issued March 21, 2023
- Patent Identification: U.S. Patent No. 11,611,621, "Event Detection System," Issued March 21, 2023 (Compl. ¶119).
- Technology Synopsis: The patent addresses the shortcomings of prior event data recorders (EDRs), which lacked the ability to efficiently detect safety events in real-time (Compl. ¶123). The patented method uses a first sensor (e.g., a camera) to detect an image feature corresponding to an event type (e.g., a traffic sign) and, based on that detection, selects and accesses a data stream from a second sensor to augment the event detection and present a notification (Compl. ¶¶122, 124).
- Asserted Claims: Method Claim 8 is asserted (Compl. ¶122).
- Accused Features: The complaint alleges infringement by Motive's "safety event detection service," which uses a dashcam and a Vehicle Gateway to identify driving events (Compl. ¶¶174-175).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are the Motive Vehicle Gateway, AI Dashcam, AI Omnicam, and associated cloud-based software services, including the Motive Dashboard, Motive Safety Hub, and Motive Driver Fuel Score (Compl. ¶125).
Functionality and Market Context
The complaint alleges that Motive's products form an "integrated platform" that mimics Samsara Inc's "Connected Operations Cloud" (Compl. ¶44). This platform consists of three layers: (i) IoT devices like the Vehicle Gateway and AI Dashcam that collect data from vehicles; (ii) a "Motive Data Platform" for data processing; and (iii) "Motive AI-Powered Applications" that provide analyses and features to customers, such as fuel scoring and safety event detection (Compl. ¶¶131, 157). The complaint provides a diagram of the accused system architecture, which it alleges mimics Samsara's own platform structure. A diagram from Motive's literature shows the accused three-layer "Integrated platform" (Compl. p. 59).
IV. Analysis of Infringement Allegations
'373 Infringement Allegations
| Claim Element (from Independent Claim 15) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first vehicle gateway device configured to gather and transmit first vehicle metric data associated with a first vehicle | The Motive Vehicle Gateway is a device that collects and transmits vehicle metric data (e.g., speed, fuel, fault codes) from a vehicle. | ¶132 | col. 2:35-42 |
| [a computing device configured to] receive vehicle metric data from a plurality of vehicle gateway devices associated with a plurality of vehicles | Motive’s Data Platform and AI-Powered Applications, running on cloud computers, receive metric data from multiple Motive Vehicle Gateways in a fleet. | ¶135 | col. 3:2-5 |
| determine, from the vehicle metric data, fuel/energy usage of the plurality of vehicles over various periods of time | The Motive Data Platform and AI-Powered Applications determine a "Fuel Score" for drivers and vehicles based on collected metric data such as idling, speeding, and RPM over time. | ¶136 | col. 5:24-27 |
| determine correlations among one or more other vehicle metrics and the fuel/energy usage of the plurality of vehicles over the various periods of time | Motive's platform allegedly determines correlations by comparing a driver's performance to other drivers in the Motive network with similar vehicles and conditions to normalize for external factors. | ¶140 | col. 5:44-50 |
| determine weightings of the one or more other vehicle metrics based at least in part on the determined correlations | Motive's AI-Powered Applications allegedly determine weightings for vehicle metrics (e.g., engine performance, idling duration) in the calculation of its Fuel Score after removing the effect of other variables. | ¶142 | col. 5:51-54 |
| receive, from the first vehicle gateway device, the first vehicle metric data associated with the first vehicle | Motive's platform receives metric data (e.g., average MPG, total distance, fuel cost) associated with an individual vehicle. | ¶143 | col. 3:2-5 |
| determine, based on the determined weightings and the first vehicle metric data, a fuel/energy efficiency score associated with the first vehicle | The Motive platform determines a Fuel Score or vehicle performance score for a specific vehicle based on the weightings and its individual metric data. A screenshot shows a "Vehicle Performance" leaderboard ranking vehicles (Compl. p. 70). | ¶146 | col. 5:55-61 |
| cause the fuel/energy efficiency score to be provided in an alert, report, or interactive graphical user interface | Motive's platform provides the Fuel Score and related metrics in the interactive Motive Fleet Dashboard. | ¶147 | col. 6:1-5 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether Motive’s process of "normaliz[ing] variables" by "compar[ing] your drivers to other drivers in our network" (Compl. ¶140) meets the claim limitation "determine correlations." The analysis may turn on whether "correlations" requires a specific statistical calculation or can be construed more broadly to cover Motive’s alleged cross-fleet comparison and normalization methodology.
- Technical Questions: The complaint alleges that determining the Fuel Score "entails determining weightings of vehicle metrics" (Compl. ¶142). A factual question will be what technical evidence supports the allegation that Motive's system explicitly calculates and applies "weightings" based on determined "correlations" as required by the claim sequence, versus using a different algorithmic approach to generate a score.
'130 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an image sensor | The Motive AI Dashcam has a road-facing and a driver-facing digital camera, each with an image sensor. The AI Omnicam has one image sensor. | ¶158 | col. 1:41-42 |
| a computer readable storage medium having program instructions embodied therewith, the program instructions including at least a web server configured to provide communication with other computer devices | The Motive system (Dashcam, Vehicle Gateway, cloud platform) includes computer readable storage mediums (e.g., RAM). The software and firmware providing connectivity (e.g., 4G LTE) and remote access between the devices and the cloud platform are alleged to constitute a web server. | ¶159 | col. 2:47-49 |
| [processors configured to] acquire an image via the image sensor | Processors in the Motive AI Dashcam and AI Omnicam execute software to acquire digital images using their digital cameras. | ¶161 | col. 4:1-2 |
| process the image to identify one or more features in the image | Software on the AI Dashcam and AI Omnicam processes captured images to identify features related to unsafe driving, such as distracted driving, hard brakes, or unsafe lane changes. A screenshot shows "Hard Brake Detected" as a feature (Compl. p. 75). | ¶162 | col. 4:3-5 |
| determine an evaluation of the image based at least in part on the one or more features | The AI Dashcam and AI Omnicam determine evaluations of images, such as classifying an event as "unsafe driving" or "distracted driver events." | ¶163 | col. 1:53-55 |
| locally store the image and the evaluation | The AI Dashcam and AI Omnicam locally store images that may contain significant events. A Motive blog post diagram shows dashcams locally "save video[s]" of potentially severe events (Compl. p. 77). | ¶164 | col. 4:12-14 |
| transmit the image and evaluation for remote storage | The AI Dashcam and AI Omnicam transmit images and their associated evaluations (e.g., detected high-risk events) to the Motive cloud for remote storage via the Vehicle Gateway. | ¶165 | col. 1:51-53 |
| execute the web server to provide secure remote access to the image and evaluation | The Motive Vehicle Gateway provides remote access for the Motive cloud to "fetch" videos stored on the dashcams, and subsequently provides access to customers via the cloud platform dashboard. | ¶166 | col. 4:18-20 |
- Identified Points of Contention:
- Scope Questions: The construction of "web server" will likely be a key issue. The complaint alleges that firmware providing 4G connectivity and secure access to a cloud platform meets this limitation (Compl. ¶159). The defense may argue for a narrower construction requiring traditional web server protocols (e.g., HTTP).
- Technical Questions: The claim requires the system to "locally store the image and the evaluation." The complaint cites a blog post indicating that Motive dashcams "save video[s]" of potentially severe events (Compl. ¶164). Factual discovery may focus on how frequently this local storage occurs, for how long, and whether an "evaluation" is stored alongside the image on the device itself, as required by the claim.
V. Key Claim Terms for Construction
'373 Patent, Claim 15
- The Term: "determine correlations"
- Context and Importance: This term is critical because the complaint's infringement theory relies on mapping it to Motive's alleged process of comparing drivers across its network to "normalize variables" that are outside a driver's control (Compl. ¶140). The viability of the infringement claim may depend on whether this normalization process falls within the construed scope of "determine correlations."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that "correlations, recommendations, and the like may be determined" (’373 Patent, col. 2:29-31). This general phrasing could support a broader meaning that includes any identified relationship or trend, not just a formal statistical correlation.
- Evidence for a Narrower Interpretation: The specification discusses determining correlations "among vehicle metrics and fuel/energy efficiencies" (’373 Patent, col. 2:25-27) and then using those correlations to determine "weightings" (col. 5:51-54). This context suggests a more structured, potentially mathematical relationship, which could support a narrower definition requiring a specific type of analysis.
'130 Patent, Claim 1
- The Term: "web server"
- Context and Importance: Practitioners may focus on this term because infringement hinges on whether the software and firmware that provide connectivity between the dashcam, gateway, and cloud platform constitute a "web server" (Compl. ¶159). This is a technical and definitional question central to the dispute.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes "one or more web-servers, for communicating with other devices/systems" (’130 Patent, col. 2:47-49) and enabling "remote access to live image data and analyses via a web-server operating on the machine vision devices" (col. 3:38-40). This functional language could support reading the term on any component that provides such remote, web-based access, regardless of its specific implementation.
- Evidence for a Narrower Interpretation: The claim requires the web server to "provide secure remote access to the image and evaluation." A defendant may argue this implies a server that directly responds to client requests for that specific data, potentially contrasting it with firmware that primarily manages data transmission to a separate cloud platform that in turn provides user access.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement for all three patents, asserting that Motive instructs and encourages its customers, through product documentation and training, to use the accused products in an infringing manner (Compl. ¶¶148, 167, 184). It also alleges contributory infringement, stating the accused products are especially made or adapted for infringement and are not staple articles of commerce with substantial non-infringing uses (Compl. ¶¶149, 168, 186).
- Willful Infringement: Willfulness is alleged based on Motive's knowledge of the patents-in-suit. The complaint states Samsara Inc informed Motive of its patent portfolio on September 26, 2023, and provided specific notice of the asserted patents and infringement allegations via claim charts on January 23, 2024 (Compl. ¶126). This forms a basis for willfulness for any infringement occurring after those dates.
VII. Analyst’s Conclusion: Key Questions for the Case
- Definitional Scope: A core issue will be one of claim construction. Can terms like "determine correlations" from the '373 Patent and "web server" from the '130 Patent be construed broadly enough to read on the accused functionalities of cross-fleet driver normalization and device connectivity firmware, respectively, or does the intrinsic evidence limit them to more specific technical implementations?
- Evidentiary Sufficiency: A key factual question will be whether the operational details of Motive's platform match the specific steps recited in the claims. For example, what evidence will demonstrate that the Motive system "locally store[s] the image and the evaluation" on the dashcam itself, as required by Claim 1 of the '130 Patent, and how does Motive's algorithm technically generate its "Fuel Score" in a way that satisfies the "correlations" and "weightings" limitations of the '373 Patent?
- Narrative and Intent: Beyond the technical infringement analysis, a central element of the case will be the extensive allegations of systematic copying, fraudulent access to Plaintiff's platform, and misleading advertising. A key question will be how this narrative may influence the court's and jury's perception of the dispute, particularly regarding the legally distinct but practically related issues of intent for willfulness and indirect infringement.