Notice2026-02577
Certain Vehicle Telematics, Fleet Management, and Video-Based Safety Systems, Devices, and Components Thereof; Notice of a Commission Determination To Review in Part a Final Initial Determination and on Review, To Affirm a Finding of No Violation; Termination of the Investigation
Primary source
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Published
February 10, 2026
Issuing agencies
International Trade Commission
Abstract
Notice is hereby given that the U.S. International Trade Commission ("Commission") has determined to review in part a final initial determination ("FID") issued by the presiding administrative law judge ("ALJ") and, on review, to affirm a finding of no violation of section 337 of the Tariff Act of 1930, as amended. The investigation is terminated with a finding of no violation.
Full Text
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<title>Federal Register, Volume 91 Issue 27 (Tuesday, February 10, 2026)</title>
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[Federal Register Volume 91, Number 27 (Tuesday, February 10, 2026)]
[Notices]
[Pages 5954-5955]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-02577]
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INTERNATIONAL TRADE COMMISSION
[Investigation No. 337-TA-1393]
Certain Vehicle Telematics, Fleet Management, and Video-Based
Safety Systems, Devices, and Components Thereof; Notice of a Commission
Determination To Review in Part a Final Initial Determination and on
Review, To Affirm a Finding of No Violation; Termination of the
Investigation
AGENCY: U.S. International Trade Commission.
ACTION: Notice.
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SUMMARY: Notice is hereby given that the U.S. International Trade
Commission (``Commission'') has determined to review in part a final
initial determination (``FID'') issued by the presiding administrative
law judge (``ALJ'') and, on review, to affirm a finding of no violation
of section 337 of the Tariff Act of 1930, as amended. The investigation
is terminated with a finding of no violation.
FOR FURTHER INFORMATION CONTACT: Paul Lall, Office of the General
Counsel, U.S. International Trade Commission, 500 E Street SW,
Washington, DC 20436, telephone (202) 205-2043. Copies of non-
confidential documents filed in connection with this investigation may
be viewed on the Commission's electronic docket (EDIS) at <a href="https://edis.usitc.gov">https://edis.usitc.gov</a>. For help accessing EDIS, please email
<a href="/cdn-cgi/l/email-protection#dc9998958fef94b9b0ac9ca9afb5a8bff2bbb3aa"><span class="__cf_email__" data-cfemail="d792939e84e49fb2bba797a2a4bea3b4f9b0b8a1">[email protected]</span></a>. General information concerning the Commission may
also be obtained by accessing its internet server at <a href="https://www.usitc.gov">https://www.usitc.gov</a>. Hearing-impaired persons are advised that information on
this matter can be obtained by contacting the Commission's TDD
terminal, telephone (202) 205-1810.
SUPPLEMENTARY INFORMATION: On March 18, 2024, the Commission instituted
this investigation based on a complaint filed by Samsara, Inc.
(``Samsara'') of San Francisco, California. 89 FR 19356 (March 18,
2024). The complaint alleges violations of section 337 of the Tariff
Act of 1930, as amended, 19 U.S.C. 1337 (``section 337''), based upon
the importation into the United States, the sale for importation, and
the sale within the United States after importation of certain vehicle
telematics, fleet management, and video-based safety systems, devices,
and components thereof by reason of the infringement of certain claims
of U.S. Patent Nos. 11,611,621 (``the '621 patent''); 11,127,130 (``the
'130 patent''); and 11,190,373 (``the '373 patent'') (collectively, the
``Asserted Patents''). The Commission's notice of investigation named
Motive Technologies Inc. (``Motive'') of San Francisco, CA as the
respondent. Id. The Office of Unfair Import Investigations (``OUII'')
was also named as a party in this investigation. Id.
The presiding ALJ held an evidentiary hearing on November 14, 2024,
and March 18-21, 24, and 25, 2025.
On September 8, 2025, the presiding ALJ issued the FID finding that
there has been no violation of section 337. Specifically, the FID finds
regarding the '621 patent that: (1) Samsara has not shown that claims
1-5 are infringed; (2) Motive has shown that claims 1, 2, 4, and 5 are
invalid as anticipated; (3) Motive has not shown that claims 2-4 are
invalid for obviousness; and (4) Samsara has satisfied the technical
prong of the domestic industry requirement. For the '130 patent, the
FID finds that: (1) Samsara has not shown that claims 1 and 5 are
infringed; (2) Motive has not shown that claims 1 and 5 are invalid as
anticipated or obvious; (3) Motive has shown that claims 1 and 5 are
patent ineligible under 35 U.S.C. 101; and (4) Samsara has failed to
satisfy the technical prong of the domestic industry requirement.
Regarding the '373 patent, the FID finds that: (1) Samsara has shown
that claim 15 is infringed as to Motive's ``Fuel Score v1'' and ``Fuel
Score v2,'' but not as to Motive's ``Fuel Score v3;'' (2) Samsara has
not shown that claim 18 is infringed; (3) Motive has not shown that
claims 15 and 18 are invalid as anticipated or obvious; (4) Motive has
shown that claims 15 and 18 are patent ineligible under 35 U.S.C. 101;
and (5) Samsara has not satisfied the technical prong of the domestic
industry requirement. The FID also finds that Samsara has failed to
satisfy the economic prong of the domestic industry requirement for any
of the Asserted Patents.
The FID includes a Recommended Determination on Remedy and Bonding
(``RD''). The RD recommends that if the Commission finds a violation,
it should issue a limited exclusion order and a cease and desist order
against Motive, and that the Commission should impose a one hundred
percent (100%) bond during the period of Presidential review.
On September 22, 2025, Samsara filed a petition for review of the
FID, requesting review of the findings that: (1) Samsara has not shown
that the accused products infringe claims 1-5 of the '621 patent; (2)
Motive has shown that claims 1, 2, 4, and 5 of the '621 patent are
invalid under 35 U.S.C. 102; (3) Samsara has not shown that the
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accused products infringe claims 1 and 5 of the '130 patent; (4)
Samsara has not satisfied the technical prong of the domestic industry
requirement for the '130 patent; (5) Motive has shown that claims 1 and
5 of the '130 patent are invalid as patent ineligible under 35 U.S.C.
101; (6) Samsara has not shown that Motive's ``Fuel Score v3''
infringes claim 15 of the '373 patent; (7) Samsara has not shown that
the accused products infringe claim 18 of the '373 patent; (8) Motive
has shown that claims 15 and 18 of the '373 patent are invalid as
patent ineligible under 35 U.S.C. 101; (9) Samsara has not satisfied
the technical prong of the domestic industry requirement for the '373
patent; and (10) Samsara has not satisfied the economic prong of the
domestic industry requirement for any of the Asserted Patents.
Also on September 22, 2025, Motive filed a contingent petition
requesting review of the FID's findings that: (1) the accused products
and asserted domestic industry products satisfy certain limitations of
the '130 patent; (2) claims 1 and 5 of the '130 patent are not invalid
under 35 U.S.C. 103 as obvious over certain prior art; and (3) the
accused products satisfy certain limitations of the '373 patent. On the
same day, OUII also filed a contingent petition requesting review of
the FID's findings that the accused products satisfy certain
limitations of the '130 patent and the '373 patent.
On November 19, 2025, Motive filed a combined response to Samsara's
and OUII's petitions for review. On the same day, Samsara filed a
response to Motive's contingent petition for review. On November 21,
2025, OUII filed a combined response to Samsara's and Motive's
petitions.
Having reviewed the record of the investigation, including the FID,
the parties' petitions for review, and related submissions, the
Commission has determined to review the FID in part. Specifically, the
Commission has determined to review the FID's findings that: (1) Motive
has shown that claims 1 and 5 of the '130 patent are patent ineligible
under 35 U.S.C. 101; (2) Samsara has not satisfied the technical prong
of the domestic industry requirement for the '373 patent; and (3)
Samsara has failed to satisfy the economic prong of the domestic
industry requirement for any of the Asserted Patents. On review, the
Commission has determined to take no position on the issues under
review. The Commission declines review of the remaining issues in the
FID and has determined that there has been no violation of section 337.
The Commission vote for this determination took place on February
5, 2026.
The authority for the Commission's determination is contained in
section 337 of the Tariff Act of 1930, as amended (19 U.S.C. 1337), and
in Part 210 of the Commission's Rules of Practice and Procedure (19 CFR
part 210).
Practice and Procedure (19 CFR part 210).
By order of the Commission.
Issued: February 5, 2026.
Lisa Barton,
Secretary to the Commission.
[FR Doc. 2026-02577 Filed 2-9-26; 8:45 am]
BILLING CODE 7020-02-P
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