Samsara Inc. v. U.S. International Trade Commission et al.

I'll research this case. Note upfront: the metadata describes an ITC Section 337 appeal to the Federal Circuit, not a district court infringement action — so I'll frame the procedural posture accordingly (no district court division/judge; instead an ALJ and the Commission).

Let me dig into the Federal Circuit appeal specifics, the '130 patent, and any PTAB/IPR activity.

Case Overview and Background

Samsara Inc. v. U.S. International Trade Commission, No. 26-1630 (Fed. Cir., filed Apr. 8, 2026)

Parties and posture — this is an ITC appeal, not a district court case. Both parties are San Francisco–headquartered operating companies competing head-to-head in commercial-vehicle telematics; neither is an NPE, PAE, or university. Samsara (NYSE: IOT) sells connected-operations hardware and software — AI dashcams, vehicle gateways, asset trackers, ELD/fleet-management and video-based safety platforms — with roughly $1.9B in ARR per recent filings. Motive Technologies (formerly KeepTruckin, founded 2013) is the direct rival, offering AI Dashcam/Omnicam, Vehicle Gateway, asset gateways, ELD compliance and AI safety analytics, with roughly a $500M ARR run rate as of late 2025 and a December 2025 S-1 filing signaling a planned IPO. Because the underlying matter is a Section 337 investigation rather than a civil action, there is no district court, division, or Article III judge: the tribunal was the U.S. International Trade Commission, the presiding adjudicator was ALJ Doris Johnson Hines, and the Office of Unfair Import Investigations (OUII) participated as a party. Samsara's ITC counsel was Kirkland & Ellis (Ellisen Turner, Joseph Loy, Ali-Reza Boloori, Josh Glucoft); Motive's was Fish & Richardson (Aamir Kazi, Michael Amon); OUII was represented by Megan Wantland and Anne Goalwin. The appeal now sits in the Federal Circuit, which has exclusive appellate jurisdiction over ITC determinations under section 337 (28 U.S.C. § 1295(a)(6)).

The accused technology and the patents. Samsara's Feb. 9, 2024 complaint alleged that Motive's imported AI dashcams, vehicle gateways, and associated cloud software infringe three Samsara patents — U.S. Pat. No. 11,127,130 ("Machine Vision System and Interactive Graphical User Interfaces Related Thereto," issued Sept. 21, 2021, from App. 16/567,616, expiring Sept. 11, 2039) — a machine-vision/onboard image-capture-and-processing system; U.S. Pat. No. 11,611,621 — cloud-connected camera/vehicle-monitoring features; and U.S. Pat. No. 11,190,373 — telematics data-communications and platform integration (the accused "Fuel Score" feature). Samsara sought a limited exclusion order and cease-and-desist order, i.e., an import ban on Motive hardware. The Commission instituted Inv. No. 337-TA-1393 on March 18, 2024 (89 FR 19356), narrowed the case along the way (e.g., Order No. 47 terminating '621 claims 9 and 15–19), held an evidentiary hearing in November 2024 and March 2025, and on Sept. 8, 2025, ALJ Johnson Hines issued a final initial determination (FID) of no violation. The FID found, among other things, no infringement of the '621 and '130 claims; claims 1, 2, 4 and 5 of the '621 anticipated; claims 1 and 5 of the '130 and claims 15 and 18 of the '373 patent-ineligible under § 101; only '373 claim 15 infringed (as to "Fuel Score v1/v2," not v3); and failure of the economic prong of the domestic-industry requirement for all three patents. On Feb. 5, 2026, the Commission reviewed in part and affirmed no violation, terminating the investigation (91 FR 5954, published Feb. 10, 2026). Note the metadata lists only the '130 patent as at issue on appeal — consistent with the case summary's focus on the '130's § 101 and domestic-industry rulings — though the ITC record spanned all three patents; I could not independently confirm the exact appellate scope from a primary source.

Why it matters. Substantively, this is a high-stakes, competitor-vs-competitor IP fight in a fleet-telematics market variously valued at ~$10.4B (2025) heading toward ~$22B by 2032, and the appeal tees up two recurring Federal Circuit issues: the § 101 eligibility of AI/machine-vision and telematics claims, and the domestic-industry "technical prong" analysis — both areas where the Commission's rulings have been appealed with some frequency. Procedurally, it is one front in a multi-forum war: Samsara's D. Del. patent suit (1:24-cv-00084) was transferred to the N.D. Cal. by Judge Noreika under § 1404(a) in August 2024; Motive's own N.D. Cal. case against Samsara (3:24-cv-00902) asserts IP theft and false advertising; a Samsara trade-secrets action pends in San Francisco Superior Court; and a newer Samsara suit (7:26-cv-00225, W.D. Tex., removed/transferred to N.D. Cal.) asserts additional patents such as the '445 and '546. The ITC outcome was the most immediate commercial threat — had Samsara won, an exclusion order could have halted imports of Motive devices that serve ~100,000 customers and 1M+ drivers — and the ITC loss was paired with a $30.3M confidential arbitration award to Samsara over Motive's Virginia Tech/Strategy Analytics dashcam benchmarking claims (disclosed in Samsara's March 16, 2026 Form 10-K).

Sourcing caveats. The ITC record (institution notice, FID summary, and Feb. 5, 2026 Commission notice) is well documented in the Federal Register and USITC notices. The Federal Circuit docket number and filing date are confirmed by third-party docket aggregators (UniCourt), but I could not retrieve the Federal Circuit docket itself, so the appellate briefing schedule, the exact statement of issues, and appellate counsel are unverified. Attorney names, the ALJ, and party roles come from ITC filings and hearing transcripts. Market-size figures are from a news report citing a third-party market study and should be treated as approximate. The parallel district court docket numbers beyond 1:24-cv-00084 and 3:24-cv-00902 come from secondary litigation-analytics sources and warrant direct docket confirmation.

I'll research this case across the ITC docket, Federal Circuit, PTAB, and legal press. Let me start with several parallel searches.

Good initial harvest. Now let me drill into the Federal Circuit appeal, the ITC procedural milestones, the parallel district court cases, and the PTAB IPRs.

I'll search across multiple angles to find press coverage of this case.

Good coverage found. Let me search additional angles — the Federal Circuit appeal itself, legal trade press, and analyst coverage.

Press coverage of Samsara Inc. v. ITC (Fed. Cir. 26-1630) and the underlying ITC investigation

The ITC loss and how it was reported. The press coverage of this appeal is almost entirely downstream of the underlying ITC investigation, Inv. No. 337-TA-1393. FreightWaves reported on 2025-09-09 that "the U.S. International Trade Commission has ruled in favor of Motive, rejecting Samsara's claims of patent infringement," and later recapped that after the March 2025 evidentiary hearing, "the administrative law judge issued an initial determination on Sept. 8, 2025, finding no Section 337 violation" (FreightWaves). That article, by Thomas Wasson, reported that "eight of nine asserted claims were ruled invalid or non-infringed," that "Samsara failed the domestic industry requirement," and that "the full commission affirmed the no-violation finding in February 2026 and terminated the investigation" — with the practical consequence that "no import ban took effect" and "Motive hardware continues flowing freely into the U.S. market." The Commission's own determinations confirm the substance: the ALJ's 2025-09-08 final initial determination found no violation, including that claims 1 and 5 of the '130 patent were not infringed, were patent-ineligible under § 101, and that Samsara failed the technical prong of the domestic-industry requirement for that patent, plus failure of the economic prong for all three asserted patents (ITC notice of FID; see also the Commission's termination notice at 91 FR 5954). FreightWaves attributed to Motive CEO Shoaib Makani that "the ITC affirmed Judge Johnson Hines' decision that Motive does not infringe any valid Samsara patent claims," and quoted Motive chief legal officer Shu White calling the September ruling decisive: "Samsara falsely accused Motive of patent infringement in the ITC to stifle competition and disrupt our business... But they failed." Notably, on the § 101 issue that is central to the now-pending appeal, the Commission "determined to review" the '130 patent's § 101 ineligibility finding but then "take no position on the issues under review" — a nuance no press account I found explains.

The numbers: a $30 million arbitration award, not a patent damages figure. The only hard dollar figure in the coverage is unrelated to the patent case. FreightWaves, Transport Topics (2026-03-19), and FleetOwner all reported that Samsara was awarded roughly $30.3 million in a confidential arbitration over false-advertising claims tied to 2023 Virginia Tech Transportation Institute and Strategy Analytics AI-dashcam benchmarking studies. Transport Topics reported that "publicly traded Samsara disclosed it was awarded $30.3 million in damages in accordance with the arbitration decision" in its annual report filed March 16. FreightWaves quoted Makani telling employees the arbitrator "awarded Samsara a permanent injunction and damages in part related to the Virginia Tech and Strategy Analytics AI benchmarking studies," and both FleetOwner and Transport Topics reported that Motive removed the studies and now posts a corrective statement that its benchmark claims were ruled "literally false in violation of the Lanham Act." No damages were sought or awarded in the ITC patent case itself (the ITC's remedy is exclusion/cease-and-desist relief, which never issued), and I found no reported settlement terms.

Where accounts go beyond the record or diverge. The accounting of the two proceedings is sometimes elided: FreightWaves frames the period as "the latest legal salvo saw Samsara awarded $30.3 million... [while] Motive won the ITC case," and FleetOwner similarly headlines "Both Motive and Samsara share wins and losses" — a framing that blurs the fact that the $30.3M is a non-ITC, non-patent arbitration award. FleetOwner and Transport Topics both quote Samsara CLO Adam Eltoukhy going beyond the court record with characterizations ("Motive committed fraud"), and FleetOwner noted that "details of Samsara's damages to be paid by Motive have yet to be released" — i.e., the award figure came only from Samsara's 10-K, not from the sealed arbitration ruling. The clearest extra-judicial "analyst take" is financial, not legal: TipRanks via Business Insider Markets reported on 2025-09-09 that JPMorgan kept a Neutral rating on Samsara (IOT) after the ITC ruling, saying "the judge ruled that no Samsara patents were violated" and that the bank "sees risk of increased competition for Samsara following the ruling." One date discrepancy worth flagging: several Chinese trade-remedy bulletins (MOFCOM/CACS, CCCME) date the FID to 2025-09-22, which conflicts with the ITC's own notice (2025-09-08); the earlier date appears correct, with September 22 being the date Samsara's petition for review was filed.

Coverage gaps. I found no article by Reuters, Bloomberg Law, Law360, Ars Technica, The Verge, IPWatchdog, Patently-O, EFF Deeplinks, or JD Supra on this case, and no coverage at all specifically of the Federal Circuit appeal docketed as 26-1630. The only trace of the appeal's filing date (2026-04-08) is a docket aggregator entry, UniCourt. FreightWaves is the only outlet I found that flags the appeal going forward — "Samsara notes they plan to appeal the decision in a federal circuit court" — and neither Motive's nor Samsara's public statements in these articles address the § 101 or domestic-industry issues that the Federal Circuit will actually confront. The § 101/DI-centric legal-trade analysis one would expect for a Federal Circuit IP appeal is, as of this writing, simply absent from the press record; the coverage is overwhelmingly from freight/trucking trade press and financial wires, framed as a commercial rivalry story rather than a patent-law one. Related parallel proceedings (Samsara's IPRs against Motive's '580/'276/'243 patents, and the parties' dueling district-court cases) surfaced only in docket materials, not press reporting.

Sources

• UNITED STATES INTERNATIONAL TRADE COMMISSION
• Secretary to the Commission. - U
• UNITED STATES INTERNATIONAL TRADE COMMISSION Washington, D.C.
• News Archives
• The information in these confidential exhibits consists of proprietary commercial information, including, at least: (i) propriet...
• Recent News Archives
• After consultation with the Secretary of the Interior, BOEM is required to withhold the location, character, or ownership of his...
• 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 | 91 FR 5954 - Document
• Samsara awarded $30M over Motive’s marketing claims; Motive beats patent infringement case - Skip to navigation Skip to main content Skip to right column
• UNITED STATES INTERNATIONAL TRADE COMMISSION Washington, D.C.
• USITC Institutes Section 337 Investigation of Certain Vehicle Telematics, Fleet Management, and Video-Based Safety Systems, Devices, and Components Thereof
• Complaint analysis | 7:26-cv-00225 | Samsara Inc v. Motive Tech Inc | Ex Parte

I'll research this. Note upfront: this is a Federal Circuit appeal from an ITC investigation, not a district court case, so "counsel of record" means the attorneys who appeared for Samsara in the ITC proceeding and/or on the CAFC docket. Let me dig.

Now let me find Samsara's counsel specifically — in the ITC investigation and on the Federal Circuit docket.

Good — I've confirmed Samsara's ITC counsel was Kirkland & Ellis. Now let me pin down the Federal Circuit appeal docket and any separate appellate counsel.

Bottom line

The "plaintiff" here is Samsara Inc., and this is a Federal Circuit appeal (No. 26‑1630, filed 4/8/2026) from the ITC's no‑violation determination in Inv. No. 337‑TA‑1393, Certain Vehicle Telematics, Fleet Management, and Video‑Based Safety Systems — not a district court case. So the operative counsel of record are (a) whoever entered an appearance on the CAFC docket, and (b) the attorneys who represented Samsara as complainant below. I was not able to retrieve the CAFC docket sheet or appearance entries for 26‑1630, so the identities below are the counsel of record in the underlying ITC proceeding (and the parallel district court litigation) — the same team one would expect to carry the appeal, but I cannot confirm the CAFC appearances. Flagging that up front rather than guessing.

Samsara's counsel of record in the ITC investigation (Inv. No. 337‑TA‑1393)

Firm: Kirkland & Ellis LLP — this is the firm that filed and litigated Samsara's § 337 complaint. Samsara's Feb. 8, 2024 EDIS transmittal letter enclosing the verified complaint is signed by a Kirkland partner over the block "Counsel for Complainant Samsara Inc."

Source for the on-the-record appearances: Aug. 14, 2024 CMC transcript, Inv. No. 337‑TA‑1393 (ALJ Doris Johnson Hines) — "MR. LOY: Joseph Loy on behalf of the Complainant. Together with me today is Karthik Ravishankar, as well as Joshua Glucoft." Reproduced in Samsara's Motion to Declassify and exhibits: https://www.innovationprotection.com/wp-content/uploads/2024/11/Samsaras-Motion-to-Declassify-Memo-ISO-and-Exhibits-1.pdf

Source for the Kirkland filing signature block and the firm's ITC ranking: the EDIS filing letter (Kirkland & Ellis, Ellisen Shelton Turner, Feb. 8, 2024) as reproduced at https://tmsnrt.rs/4ev8Y1F ; Legal 500 ITC ranking listing Samsara Inc. as a Kirkland key client: https://www.legal500.com/rankings/ranking/c-united-states/intellectual-property/patents-litigation-international-trade-commission/50540-kirkland-ellis-llp

Important caveats and other appearances you should know about

• No confirmed CAFC appearance list. I could not pull the 26‑1630 docket sheet, so I cannot state which Kirkland (or other) attorneys formally appeared on the appeal, and no briefs appear in my search results. Treat the table above as "counsel of record below," not as confirmed appellate counsel. If appellate-only counsel (e.g., a dedicated Supreme Court/appellate group) has been retained, I did not find it.
• Gibson, Dunn & Crutcher LLP also appears for Samsara in the parallel district court case. In Motive Technologies, Inc. v. Samsara Inc., N.D. Cal. No. 3:24‑cv‑00902‑JD, Gibson Dunn attorneys — Jaysen S. Chung (San Francisco), Josh Krevitt (San Francisco), Nathaniel R. Scharn (Irvine), and Hannah L. Bedard and Wendy W. Cai (Washington, D.C.) — filed Samsara's Rule 12(c) motion for judgment on the pleadings (i.e., they signed as "Attorneys for Defendant and Counterclaim Plaintiff Samsara Inc."). Kirkland also appears in that same docket, so this looks like a mid‑case handoff or divided responsibility between the two firms; the docket numbers (Kirkland at Dkt. 86, Gibson Dunn at Dkt. 197/199) are consistent with a substitution. I could not confirm the mechanics of that transition, so please treat it as an inference.
• In‑house counsel: Adam Eltoukhy is Samsara's Chief Legal Officer and is the company's public spokesperson on this litigation (quoted in FreightWaves and Fleet Maintenance), but he is not shown as counsel of record in the ITC or the appeal.
• Adverse/other parties (for completeness, not your answer): Motive's ITC counsel was Fish & Richardson P.C. (service address ServiceMotive-SamsaraITC1393@fr.com; Aamir Kazi, Atlanta), with Michael McKeon, Noah Graubart, Aamir Kazi, and Mike Amon appearing at the CMC. In the PTAB IPRs (e.g., IPR2025‑00574), Motive is represented by Marton Ribera Schumann & Chang LLP (Hector J. Ribera, C.J. Alice Chuang, Carolyn Chang, Ryan J. Marton, San Francisco). The ITC's own interests are represented by the Office of the General Counsel / OUII (Megan Wantland, Anne Goalwin, Sidney Rosenzweig, Paul Lall) — i.e., the Commission's counsel, not Samsara's.

Subject‑matter context (why this matters for the appeal)

The Commission's Feb. 5, 2026 notice (91 FR 5954) reviewed in part and affirmed no violation, terminating 337‑TA‑1393. On review, the Commission took no position on three issues: (1) whether claims 1 and 5 of the '130 patent (U.S. 11,127,130 — the sole patent in your case caption) are patent‑ineligible under § 101; (2) whether Samsara satisfied the technical prong of domestic industry for the '373 patent; and (3) whether Samsara satisfied the economic prong for any asserted patent. Those are the rulings squarely on appeal to the Federal Circuit.
Sources: https://thefederalregister.org/documents/2026-02577/ ; https://www.usitc.gov/sites/default/files/secretary/fed_reg_notices/337/337_1393_notice08142025sgl.pdf ; https://www.freightwaves.com/news/samsara-motive-lawsuit-arbitration-award-itc-ruling-2026

Confidence summary: High confidence on Kirkland & Ellis as Samsara's ITC counsel of record and on the individual names/offices listed (drawn from on‑the‑record appearances and signed filings). Low confidence / unverified on the Federal Circuit appearances for 26‑1630 and on the exact Gibson Dunn–Kirkland division of labor in the district court case. I did not find any sealed‑filing indication specific to counsel in the CAFC appeal.

I'll research the defense side — Motive Technologies and the ITC as appellees on the Federal Circuit appeal. Let me start with several parallel searches.

Now let me drill into the Federal Circuit appeal docket itself, Motive's appellate counsel, and the ITC's appellate representation.

Note on framing and a metadata caveat

In this appeal the "defendants" are the appellees: the U.S. International Trade Commission (the federal agency whose no-violation determination is under review) and Motive Technologies, Inc. (the successful respondent below, which will appear as intervenor/respondent in the Federal Circuit). Because the underlying matter is a Section 337 investigation, there is no district court and no "patent infringement case" in the Article III sense — so "counsel of record for the defendants" means (a) whoever entered an appearance for Motive and the Commission on the CAFC docket in No. 26‑1630, and (b) the teams those parties used below (ITC, PTAB, and the parallel district court litigation).

Critical sourcing caveat up front: I was not able to retrieve the Federal Circuit docket sheet or the appearance/brief entries for No. 26‑1630. The only confirmation of the appeal being docketed is a third-party aggregator (Patexia), which lists "2026‑1630 | Samsara Inc. v. ITC | Apr 8, 2026" (Patexia case list). That entry confirms the metadata's docket number and filing date but contains no counsel information. Accordingly, everything below is counsel of record in the proceedings below (which is the same group one would expect to carry the appeal), and I flag explicitly where an appellate appearance is unverified.

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Defendant/Appellee 1 — Motive Technologies, Inc.

A. ITC counsel of record (Inv. No. 337‑TA‑1393) — Fish & Richardson P.C.

Fish & Richardson was Motive's counsel of record throughout the 337 investigation and is the most likely firm to carry the Federal Circuit appeal.

Service block for Motive in the investigation: ServiceMotive-SamsaraITC1393@fr.com, "COUNSEL FOR MOTIVE TECHNOLOGIES, INC."

Source: Aug. 14, 2024 CMC transcript, Inv. No. 337‑TA‑1393, reproduced in Samsara's Motion to Declassify and exhibits: https://www.innovationprotection.com/wp-content/uploads/2024/11/Samsaras-Motion-to-Declassify-Memo-ISO-and-Exhibits-1.pdf ; investigation service list as reproduced at https://tmsnrt.rs/4ev8Y1F.

Firm context (relevant experience): Fish & Richardson is one of the largest patent-litigation and ITC practices in the country. On the CMC record the Fish attorneys identified themselves only by firm and surname, so I cannot tie individual matters to Kazi/Amon/McKeon/Graubart from primary sources here — treat the firm-level ITC experience as well documented (Fish's Section 337 practice is extensive; e.g., firm bios reference long ITC track records for matters such as the Aspen Aerogels and Macronix investigations), but treat individual case credit as not independently verified.

B. PTAB counsel (parallel IPRs, e.g., IPR2025‑00574) — Marton Ribera Schumann & Chang LLP

Motive is the patent owner in Samsara's IPR challenges to Motive's own patents (the '580/'276/'243 family), and its counsel there is a different boutique:

Source: Motive's Updated Mandatory Notices, IPR2025‑00574 (Sept. 16, 2025), via Docket Alarm: https://www.docketalarm.com/cases/PTAB/IPR2025-00574/Samsara_Inc._v._Motive_Technologies_Inc/

C. District court counsel (N.D. Cal. No. 3:24‑cv‑00902‑JD, Motive Technologies, Inc. v. Samsara Inc.) — Greenberg Traurig LLP + Williams & Connolly LLP

In the parallel N.D. Cal. case (Motive is plaintiff and counterclaim defendant), Motive is represented by two firms — a regional litigation team (Greenberg Traurig) plus an elite D.C. trial firm (Williams & Connolly):

Sources: Greenberg Traurig/Williams & Connolly signature blocks in the N.D. Cal. docket (Dkt. 189, via Internet Archive: https://www.archive.org/download/gov.uscourts.cand.[424943](/patent/424943)/gov.uscourts.cand.424943.189.0.pdf); Dkt. 228 case-management statement ("Attorney for Plaintiff: David Bloch, Chris Mandernach") via https://www.archive.org/download/gov.uscourts.cand.424943/gov.uscourts.cand.424943.228.0.pdf. Note the earlier "Plaintiff representatives" section of this case noted these firms appearing on the Motive side; this entry confirms Motive, not Samsara, is their client in that docket.

D. In-house

Shu White — Chief Legal Officer, Motive Technologies. Ms. White is Motive's public spokesperson on this litigation (quoted in WorkTruck/Transport Topics/FreightWaves, e.g., "Samsara falsely accused Motive of patent infringement in the ITC to stifle competition and disrupt our business. But they failed."). She is not shown as counsel of record in the ITC or (as far as I can verify) on the CAFC docket. Shoaib Makani (Motive CEO/founder) is a party/executive spokesperson, not counsel.

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Defendant/Appellee 2 — U.S. International Trade Commission

The Commission is the agency appellee. In Section 337 appeals the Commission is represented by its own Office of General Counsel ("OGC") on the Federal Circuit (28 U.S.C. § 1295(a)(6) gives the Federal Circuit exclusive jurisdiction; the agency appears through OGC, not the Department of Justice). Below, the investigative arm of the agency — the Office of Unfair Import Investigations ("OUII") — participated as a named party.