This litigation is focused on Motive’s infringement of three of Samsara’s patents, covering the company’s innovative solutions in fleet management and driver safety, including:

• U.S. Patent No. 11,190,373 (“Vehicle Gateway Device and Interactive Graphical User Interfaces Associated Therewith”)
• U.S. Patent No. 11,127,130 (“Machine Vision System and Interactive Graphical User Interfaces Related Thereto”)
• U.S. Patent No. 11,611,621 (“Event Detection System”)

Motive has infringed, and continues to infringe Samsara’s IP by making, using, selling, offering for sale, and/or importing into the U.S. products and services covered by Samsara patents. These Motive products and features include Motive’s Fuel Score feature, Motive’s Safety Event Detection service, and Motive’s AI Dash Cam and AI Omnicam used together with the Motive Vehicle Gateway.

Motive has also repeatedly sold, produced and distributed products and software that are nearly identical to Samsara’s patented technology. For example, in 2016, Samsara introduced its Vehicle Gateway product, a single integrated platform consisting of a device that connects directly to a vehicle’s engine to read vehicle diagnostic information, track GPS location, and support temperature monitoring while transmitting this vital information wirelessly to the cloud. Three years later, in 2019, Motive released its own version of this product, copying Samsara’s product so closely that it even has the same name: Vehicle Gateway.

Additionally, in 2019, Samsara released its AI-Dash Cam, the CM31 (front-facing) and CM32 (dual-facing), capable of performing real-time AI analysis onboard the device. Two years later, in August 2021, KeepTruckin introduced its imitation product: the AI Dash Cam. Like the Samsara Dash Cam released two years earlier, Motive’s AI Dash Cam includes an AI processor and computer vision algorithms that are designed to detect unsafe driving and alert drivers in real-time.

Please refer to Samsara’s complaint for further detail about Motive’s copying and infringement of Samsara’s patents.

Motive has commissioned at least two flawed studies to compare the functionality and efficacy of Samsara and Motive’s products and services. As stated in Samsara’s complaint, we believe Motive knew the methodology used in the testing for these studies was flawed to skew the results in Motive’s favor to the detriment of Samsara. In one of these studies, the seatbelt alert for Samsara’s video-based safety solution was not properly enabled during testing, ensuring it would never issue an alert in response to detecting the driver failing to wear a seatbelt. However, Motive’s advertisements that cite to this report make no mention of that fact and instead claim Samsara had “0% success” in the seatbelt test, compared to Motive’s “100% success rate.”

As described in Samsara’s complaint, since at least 2017, Motive has infiltrated Samsara’s platform using multiple false customer accounts that its personnel, including its CEO and members of its product leadership team, have hidden behind to study integral pieces of Samsara’s products. That this has been done secretly, through fictitious company names to avoid detection, demonstrates the duplicitous intent behind the conduct. Motive employees would even contact Samsara’s Customer Support team, posing as employees of real Samsara customers, to ask questions about Samsara’s products, features, and third-party integrations.

The conduct described in Samsara’s complaint is not the result of one rogue actor, nor is it isolated to a handful of instances. Rather, Samsara alleges that many Motive employees – including its CEO and senior level employees – have deliberately and repeatedly engaged in this conduct over the course of multiple years. Indeed, Motive personnel used these fake accounts to view the Samsara dashboard over 20,000 times.

Samsara tried to resolve these issues with Motive directly, even by bringing evidence of infringement to the attention of Motive’s Board of Directors. Through its lawyers, Motive failed to acknowledge its actions, made counterfactual and bad-faith arguments that Samsara had engaged in similar behavior, and used other stalling tactics. Behind the scenes, Motive was doubling down and continuing its unlawful and deceitful business practices.

No. Under certain circumstances, looking at what a competitor is doing can be proper and productive in that it might spur innovation to help better serve customers. But that is not what Motive has done. As alleged in our complaint, we found that over a four year period, Motive viewed the Samsara Dashboard over 20,000 times in total. That activity stopped only when we discovered and disabled access to the known Motive accounts. And beyond this extensive access, Samsara has seen Motive copy its patented technology, its product experience, its marketing, and even its mission statement.

And Samsara is not alone. In the fall of 2023, Omnitracs filed a lawsuit against Motive, claiming that Motive stole Omnitracs’ IP – hiring a senior engineer who was an inventor of Omnitracs’ patent technology – and that Motive’s telematics and safety products infringe seven Omnitracs patents. These lawsuits show that Motive’s actions have repeatedly crossed the line from competition to unlawful conduct.

We uncovered this footage as part of our detailed investigation into Motive’s misconduct, after we brought Motive’s unlawful access to the attention of Motive’s Board and CEO and they responded by denying any wrongdoing. Samsara included this image in the context of our lawsuit as evidence to support our assertion that Motive’s CEO, Shoaib Makani, and other senior leaders endorsed, directed, and in this case personally participated in schemes to illegally access and infringe Samsara’s intellectual property.

Samsara is committed to ensuring the privacy and security of our customers’ data. To learn more about Samsara’s policies around privacy and trust, please visit: https://www.samsara.com/company/privacy/.

Over 20,000 Samsara Dashboard views from the fake customer accounts created by Motive are not associated with any known product benchmarking studies.  Approximately 600 Samsara Dashboard views are associated with the Samsara customer account created by the research firm Strategy Analytics. This firm purchased a Samsara dash cam via a fake company name, “S.D. Logistics”, and carried out a Motive-commissioned study that utilized a flawed methodology, ensuring the results would favor Motive, to the detriment of Samsara.

At no point did Motive invite Samsara to participate in any of its commissioned benchmark reports that were published.

Competition fosters excellence and innovation, but blatant copying and IP infringement is not only illegal, it also disincentivizes innovation, harming customers and the industry overall. This conduct is particularly dangerous in this industry where we are building products that companies rely on daily to keep people safe and critical infrastructure secure.

Samsara is asking the district court to order Motive to stop making, selling, or using its Vehicle Gateway and Dash Cam products, as well as the associated software, which we allege infringe Samsara’s patented intellectual property. We are also seeking to put an end to Motive’s false and misleading advertising claims about Samsara’s products.

Samsara is asking the ITC to issue an exclusion order to prevent Motive’s infringing Vehicle Gateway and Dashcam products from entering the U.S. We are also asking the Commission to issue cease and desist orders to stop the sale of Motive’s infringing products that are already in the U.S.

We have filed these lawsuits not only to protect Samsara’s business and the hard work and innovations of thousands of Samsara employees, but also to help safeguard fair and sustainable competition and innovation for the entire industry.

The International Trade Commission (ITC) is a federal agency that conducts investigations into unfair trade practices, including practices involving the importation of goods that infringe intellectual property rights. The ITC has the authority to hear certain cases involving companies that import allegedly infringing products into the U.S. and can issue exclusion orders directing U.S. Customs and Border Protection to stop infringing imports at the U.S. border. The Commission may also issue cease and desist orders against named importers to prevent them from selling infringing products that are already in the U.S.

Samsara filed a complaint with the ITC to seek an exclusion order to prevent Motive from importing into the U.S. the products that are infringing Samsara’s patent rights. We are also asking the Commission to issue cease and desist orders to stop Motive from selling, marketing, advertising, or distributing its Vehicle Gateway and Dashcams that are already in the U.S. and which we assert are infringing our IP rights.

We take intellectual property rights very seriously, and we believe that holding Motive accountable for its unfair practices and infringement through the ITC serves the interests of our company, our customers, and our industry.

Rather than stopping its unlawful conduct, Motive has decided to copy Samsara’s litigation claims. As demonstrated in the complaints we’ve filed in federal court and at the ITC, this is the same copycat tactic Motive uses for its product development. We believe that the allegations in Motive’s suit are a deliberate distraction meant to divert attention away from our legal claims and the detailed allegations we’ve presented regarding their wrongdoing and the extensive involvement of members of their leadership team – including their CEO, CPO, and CTO – in that conduct for many years.

We have every confidence in our defense and remain focused on putting an end to Motive’s ongoing infringement and unlawful conduct to ensure fair competition, innovation, and safety for the entire industry.

Samsara is bringing this action against Motive – in addition to actions already filed in Federal Court and before the International Trade Commission – to put an end to what it views as Motive’s concerted strategy to steal and exploit Samsara’s trade secrets to unfairly and unlawfully compete with Samsara.

The lawsuit alleges that Motive continues to profit from Samsara’s trade secrets, to Samsara’s detriment, by leveraging the same sales, business, and product strategies to sell to businesses with physical operations.

Samsara firmly believes in the benefits of fair competition, but we think Motive’s conduct has been far from fair. We believe that without court intervention, Motive will continue its unlawful behavior and harm Samsara’s business and reputation, all at the expense of Samsara and its customers.

As alleged in Samsara’s Complaint, Motive, at the direction of its CEO and co-founder, Shoaib Makani, has been engaged in a “massive, years-long scheme of trade secret theft” and has done so to “unlawfully compete with Samsara.”

Makani is alleged to have been at the center of this conduct. He is alleged to have both personally obtained and directed Motive employees to obtain Samsara trade secrets to use them to build Motive’s business. Some of Makani’s specific actions discussed in the complaint include:

• Directing Motive employees to hire former Samsara employees and grill them for confidential information about every aspect of Samsara’s internal business, sales strategies, and product plans, and then use that information to help Motive sell products.
• Participating in in-person, detailed interviews with former Samsara employees – even employees in junior to mid-level roles – to get confidential trade secret information.  
•  Texting and meeting in person with Samsara’s mid-level sales representatives to lure them to Motive and pressure them to share Samsara’s trade secrets.