`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, D.C.
`
`Before the Honorable Doris Johnson Hines
`Administrative Law Judge
`
`
`
`In the Matter of
`
`CERTAIN VEHICLE TELEMATICS,
`FLEET MANAGEMENT, AND VIDEO-
`BASED SAFETY SYSTEMS, DEVICES,
`AND COMPONENTS THEREOF
`
`
`Investigation No. 337-TA-1393
`
`COMPLAINANT SAMSARA INC.’S UNOPPOSED MOTION TO TERMINATE
`INVESTIGATION AS TO CLAIMS 9 AND 15–19 OF ASSERTED
`U.S. PATENT NO. 11,611,621
`
`On February 9, 2024, Complainant Samsara Inc. (“Samsara”) filed a Complaint in the U.S.
`
`International Trade Commission which was instituted on March 12, 2024. The Complaint alleges
`
`that Respondent Motive Technologies, Inc. (“Motive”) violates 19 U.S.C. § 1337 in the
`
`importation into the United States, the sale for importation, and/or the sale within the United States
`
`after importation of certain vehicle telematics, fleet management, and video-based safety systems,
`
`devices and components thereof, or products containing the same by reasons of infringement of
`
`U.S. Patent No. 11,190,373, U.S. Patent No. 11,127,130, and U.S. Patent No. 11,611,621.
`
`To reduce the issues for the hearing and to streamline this Investigation as part of an effort
`
`between the private parties to voluntarily reduce the number of asserted claims and the number of
`
`asserted prior art references, Samsara moves pursuant to Commission Rule 210.21(a) to partially
`
`terminate the Investigation as to the following claims:
`
` U.S. Patent No. 11,611,621: Claims 9, 15, 16, 17, 18, and 19 (Infringement and Domestic
`Industry)
`
`1
`
`
`
`
`
`Samsara informed Motive and the Staff of its intention not to proceed with these claims on
`
`November 11, 2024. It is well established that “[i]n the absence of extraordinary circumstances,
`
`such partial termination will be granted.” Certain Laminated Floor Panels, Inv. No. 337-TA-545,
`
`Order No. 30, at (April 3, 2016). By terminating the above-referenced claims from this
`
`Investigation, Samsara does not in any way concede that Motive’s products do not infringe those
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`claims. Samsara also maintains its allegations with respect to the remaining claims of
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`U.S. Patent No. 11,190,373; U.S. Patent No. 11,127,130; and U.S. Patent No. 11,611,621.
`
`Pursuant to Ground Rule 5.1, Samsara certifies that the parties have conferred about the
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`withdrawal of asserted claims and the reduction of asserted prior art in this Investigation. Neither
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`Motive nor Staff opposes this motion. Also pursuant to Commission Rule 210.21(a)(1), Samsara
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`and Motive state there are no agreements, written or oral, express or implied, between Samsara
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`and Motive concerning the subject matter of the Investigation.
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`DATED: November 20, 2024
`
`
`
`
` Respectfully submitted,
`
` /s/ Ellisen S. Turner
`Ellisen S. Turner, P.C.
`Ali-Reza Boloori
`KIRKLAND & ELLIS LLP
`2049 Century Park East
`Los Angeles, CA 90067
`Telephone: (310) 552-4200
`Facsimile: (310) 552-5900
`
`Leslie Diaz
`KIRKLAND & ELLIS LLP
`555 South Flower Street, Suite 3700
`Los Angeles, CA 90071
`Telephone: (213) 680-8400
`Facsimile: (213) 680-8500
`
`Joseph A. Loy, P.C.
`Joshua L. Simmons
`
`2
`
`
`
`
`
`Matt Hershkowitz
`KIRKLAND & ELLIS LLP
`601 Lexington Avenue
`New York, NY 10022
`Telephone: (212) 446-4800
`Facsimile: (212) 446-4900
`
`Jeanne M. Heffernan, P.C.
`Beth Knuppel
`Connor M. Donaldson
`KIRKLAND & ELLIS LLP
`401 Congress Avenue
`Austin, TX 78701
`Telephone: (512) 678-9100
`Facsimile: (512) 678-9101
`
`Paul F. Brinkman, P.C.
`Karthik Ravishankar
`Matthew J. McIntee
`Alexandra Obiol
`KIRKLAND & ELLIS LLP
`1301 Pennsylvania Avenue NW
`Washington, DC 20004
`Telephone: (202) 389-5000
`Facsimile: (202) 389-5200
`
`Tasha Francis Gerasimow, Ph.D.
`KIRKLAND & ELLIS LLP
`333 West Wolf Point Plaza
`Chicago, IL 60654
`Telephone: (312) 862-2000
`Facsimile: (312) 862-2200
`
`Tiffany M. Knapp
`KIRKLAND & ELLIS LLP
`200 Clarendon Street
`Boston, MA 02116
`Telephone: (617) 385-7500
`Facsimile: (617) 385-7501
`
`Counsel for Complainant
`Samsara Inc.
`
`
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`3
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`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the foregoing document has been filed and
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`served on November 20, 2024, on the following:
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, S.W., Room 112-A
`Washington, D.C. 20436
`
` Via First Class Mail
` Via Hand Delivery
` Via FedEx
` Via Electronic Mail
` Via Electronic Filing (EDIS)
`
` Via First Class Mail
` Via Hand Delivery
` Via FedEx
` Via Electronic Mail
` Via Electronic Filing (EDIS)
`
` Via First Class Mail
` Via Hand Delivery
` Via FedEx
` Via Electronic Mail
` Via Electronic Filing (EDIS)
`
` Via First Class Mail
` Via Hand Delivery
` Via FedEx
` Via Electronic Mail
` Via Electronic Filing (EDIS)
`
`The Honorable Doris Johnson Hines
`Administrative Law Judge
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, S.W.
`Washington, D.C. 20436
`JohnsonHines1393@usitc.gov
`Megan Wantland
`Investigative Attorney
`Office of Unfair Import Investigations
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, S.W.
`Washington, D.C. 20436
`megan.wantland@usitc.gov
`Aamir A. Kazi
`FISH & RICHARDSON P.C.
`1180 Peachtree St. NE, 21st Floor
`Atlanta, GA 30309
`kazi@fr.com
`
`ServiceMotive-SamsaraITC1393@fr.com
`
`COUNSEL FOR MOTIVE TECHNOLOGIES, INC.
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`/s/ Vicki Merideth
`Vicki Merideth
`
`
`
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`
`
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