USITC Finds No Section 337 Violation in Vehicle Telematics Patent Dispute
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On February 5, 2026, the U.S. International Trade Commission (Commission) issued a final determination in Investigation No. 337-TA-1393. The case involved alleged patent infringement related to vehicle telematics, fleet management, and video-based safety systems.
The investigation began on March 18, 2024. Samsara, Inc., based in San Francisco, California, filed a complaint alleging violations of Section 337 of the Tariff Act of 1930. Samsara claimed Motive Technologies Inc., also based in San Francisco, infringed on three U.S. patents: U.S. Patent Nos. 11,611,621 (“the ’621 patent”); 11,127,130 (“the ’130 patent”); and 11,190,373 (“the ’373 patent”).
The Commission held an evidentiary hearing over several days between November 2024 and March 2025. On September 8, 2025, the presiding Administrative Law Judge (ALJ) issued a Final Initial Determination (FID). The ALJ found no violation of Section 337.
Regarding the ’621 patent:
- Samsara did not prove infringement of claims 1 through 5.
- Motive proved that claims 1, 2, 4, and 5 are invalid as anticipated.
- Motive did not prove that claims 2 through 4 are obvious.
- Samsara met the technical prong of the domestic industry requirement.
For the ’130 patent:
- Samsara did not prove infringement of claims 1 and 5.
- Motive did not prove that the claims are invalid as anticipated or obvious.
- Motive proved the claims are patent ineligible under 35 U.S.C. 101.
- Samsara failed the technical prong of the domestic industry requirement.
For the ’373 patent:
- Samsara proved that claim 15 is infringed by “Fuel Score v1” and “Fuel Score v2,” but not by “Fuel Score v3.”
- Samsara did not prove infringement of claim 18.
- Motive did not prove anticipation or obviousness of claims 15 and 18.
- Motive proved claims 15 and 18 are patent ineligible under 35 U.S.C. 101.
- Samsara did not meet the technical prong of the domestic industry requirement.
The ALJ also stated that Samsara failed to meet the economic prong of the domestic industry requirement for all three patents.
A Recommended Determination on Remedy and Bonding was issued in case the Commission found a violation. It proposed a limited exclusion order, a cease and desist order, and a 100% bond rate during Presidential review.
On September 22, 2025, Samsara filed a petition for review of several findings. On the same day, Motive and the Office of Unfair Import Investigations (OUII) filed contingent petitions asking for review of certain favorable findings to Samsara.
Motive responded to the petitions on November 19, 2025. Samsara also responded to Motive’s petition. OUII submitted a combined response two days later.
After reviewing the records and petitions, the Commission decided to review three issues:
- Whether claims 1 and 5 of the ’130 patent are ineligible under 35 U.S.C. 101.
- Whether Samsara met the technical prong for the ’373 patent.
- Whether Samsara met the economic prong for any of the asserted patents.
The Commission chose not to make a decision on these three points. It declined to review the rest of the FID. As a result, the Commission found no violation of Section 337.
The investigation is now terminated.
Authority for the determination comes from Section 337 of the Tariff Act of 1930 (19 U.S.C. 1337) and Commission Rules of Practice and Procedure (19 CFR Part 210).
The notice was issued by Secretary to the Commission, Lisa Barton.
Federal Register Document Number: 2026-02577. Published February 10, 2026.
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