US 11611621

I'll search for authoritative information on US 11,611,621 and any related 2026 CAFC docket activity.

Let me retrieve the actual claim text and check the litigation dockets.

I have the litigation picture. Now let me pull the actual claim text from a full-text patent database.

US 11,611,621 — "Event detection system"

I searched for the exact number 11,611,621. Note: I was unable to retrieve the verbatim claim text from a full-text claims source before hitting my search limit — the patent's own full text supplied to me is truncated at the end of the written description (before the claims). Everything below on the claims is therefore grounded in the specification, abstract, and the ITC's findings about which claims were litigated, with the uncertainty flagged explicitly.

Bibliographic data (corroborated across Google Patents, Unified Patents, Patents-Review, idiyas)

The small date offsets (Apr 25 vs Apr 26; Apr 8 vs Apr 9) are consistent with UTC-vs-local-time rendering differences between the two databases, not with different legal dates. Treat 2019-04-26 / 2021-04-09 as the operative dates per Google Patents.

Abstract (verbatim)

"Example embodiments described herein therefore relate to an event detection system that comprises a plurality of sensor devices, to perform operations that include: generating sensor data at the plurality of sensor devices; accessing the sensor data generated by the plurality of sensor devices; detecting an event, or precursor to an event, based on the sensor data, wherein the detected event corresponds to an event category; accessing an object model associated with the event type in response to detecting the event, wherein the object model defines a procedure to be applied by the event detection system to the sensor data; and streaming at least a portion of a plurality of data streams generated by the plurality of sensor devices to a server system based on the procedure, wherein the server system may perform further analysis or visualization based on the portion of the plurality of data streams."

Plain-language overview of the independent claims

Important caveat. The full text I was given stops before the claims, and my searches returned the abstract and specification but not the numbered claim language. Based on the ITC litigation record, at least claims 1–5 were asserted, with claim 1 treated as the lead claim. I cannot state with confidence how many independent claims the patent contains or their exact wording. The following is a plain-language reconstruction of the likely independent-claim scope from the specification, the abstract (which closely tracks the claim language in this family), and FIG. 3/method 300:

1. Lead claim (likely claim 1) — object-model-driven event detection and selective streaming. A system/method performed across networked nodes that: (a) generates sensor data at multiple sensor devices (e.g., front-facing and cabin-facing cameras on a fleet vehicle); (b) accesses that sensor data; (c) detects an event or a precursor to an event from the data, where the event maps to an event category/type (e.g., roll-over, crash, speeding, rolling stop, distracted driver); (d) in response to detection, accesses an "object model" tied to that event type/category, the object model defining a procedure — the data flow, processing operations, data rate/resolution, visualization and notification instructions — to be applied to the sensor data; and (e) streams at least a portion of the plurality of data streams to a server system according to that procedure, where the server performs further analysis or visualization. The "precursor" concept is the notable hook: recognizing a partial/leading condition (e.g., spotting a stop sign in a video frame) triggers retrieval of additional sensor inputs (inertial, GPS, ECU) to confirm whether the full event occurred.

2. Two-network-node variant (method 300 of FIG. 3). A counterpart independent claim in the specification's method flow: sensor data from at least one sensor device is accessed at a first network node (baseline data rate); the event/precursor is detected; the corresponding object model is accessed; and then at a second network node (e.g., the vehicle gateway), sensor data from a portion of the sensor devices — the subset identified by the object model — is accessed and streamed onward. The claims may also recite the data-rate switch: baseline rate/resolution under normal conditions, elevated rate and resolution (and activation of secondary sensors) once an event or precursor is detected.

I could not confirm whether the patent separately claims (a) the adaptive data-rate change, (b) the notification/GUI presentation features of FIGS. 8–10, or (c) the neural-network/feature-extraction detection of FIG. 6 as independent claims. Treat any such characterization as unverified.

Litigation status — this is the notable part for 2026

ITC Investigation No. 337-TA-1393 — Certain Vehicle Telematics, Fleet Management, and Video-Based Safety Systems, Devices, and Components Thereof. Samsara Inc. filed the § 337 complaint on 2024-02-09 against Motive Technologies Inc., asserting US 11,611,621 ("the '621 patent"), US 11,127,130, and US 11,190,373. The Commission instituted on 2024-03-12/18, 2024, with an evidentiary hearing from Nov 2024 to Mar 2025.

• Final Initial Determination (2025-09-08, as summarized 2025-09-22): no violation of § 337. For the '621 patent specifically, the ALJ found: Samsara did not prove infringement of claims 1–5; Motive proved claims 1, 2, 4 and 5 invalid as anticipated under 35 U.S.C. § 102; Motive did not prove claims 2–4 obvious; and Samsara did satisfy the technical prong of the domestic-industry requirement. (Samsara also failed the economic prong for all three patents.)
• Commission determination (2026-02-05, published 2026-02-10): the Commission reviewed only three issues (the '130 § 101 eligibility question, the '373 technical prong, and the economic prong), declined to reach them, affirmed the no-violation finding, and terminated the investigation. 81 Fed. Reg. (2026-02-10).

Court of Appeals for the Federal Circuit — appeal No. 26-1630, Samsara Inc. v. ITC, filed 2026-04-08 (per UniCourt's U.S. Courts of Appeals filings). This is Samsara's appeal of the ITC's adverse determination; I have not located a merits decision or briefing order as of today's date.

Other litigation flags on the Google Patents page (not independently corroborated here): N.D. Cal. 4:24-cv-06049; D. Del. 1:24-cv-00084; and an ITC case labeled "337-TA-3722." The 337-TA-1393 number is well corroborated by ITC/Federal Register sourcing and matches the patents asserted; I could not corroborate a 337-TA-3722 investigation involving this patent, and the number's format is unusual for a modern § 337 case — I'd treat that entry as a likely database artifact and would not rely on it without pulling the ITC docket directly. I also could not confirm the two district-court matters' current status.

Explicit uncertainties

• Verbatim claim language and total claim count: not verified. My conclusions about independent claims are inference, not quotation.
• Whether claims 4 and/or 5 are independent or dependent is unclear; the ITC's mixed treatment of claims 2–4 suggests at least one additional independent claim beyond claim 1, but I cannot confirm it.
• The Federal Circuit appeal 26-1630 is confirmed as filed; I have no information on its docketing status, briefing, or outcome.
• For authoritative claim text, the primary sources are Google Patents US11611621B2, USPTO PatentCenter for application 17/301,658, and the ITC's Federal Register notices for Inv. No. 337-TA-1393.

I'll search for litigation involving US 11611621.

Let me dig into the specific cases.

Now let me check the CAFC appeal and the other referenced case numbers.

Litigation Involving U.S. Patent No. 11,611,621 ("the '621 patent")

Important framing note: The '621 patent (Event detection system; Samsara Inc., San Francisco, CA) is not an NPE-asserted patent. It is a product-company offensive patent asserted by Samsara against a direct competitor, Motive Technologies, Inc. (formerly KeepTruckin), in a multi-front dispute (district court + ITC + private JAMS arbitration). I found no third-party/NPE suits against this patent. Below is every proceeding I could verify that actually implicates the '621 patent.

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1. ITC Investigation No. 337-TA-1393 (the lead '621 proceeding)

Outcome (final): Termination of the investigation with a finding of no violation of Section 337 — i.e., Samsara lost.

• ALJ's Final Initial Determination (Sept. 8, 2025): no violation. As to the '621 patent specifically — claims 1–5 not shown to be infringed; claims 1, 2, 4, and 5 shown to be invalid as anticipated; claim 3 not shown invalid; Samsara did satisfy the technical prong of the domestic-industry requirement for the '621 patent. (FID notice PDF)
• Evidentiary hearings: Nov. 14, 2024 and March 18–21, 24–25, 2025.
• Commission determination (vote Feb. 5, 2026; published 91 FR 5954 / FR Doc. 2026-02577): reviewed the FID in part (on '130 §101 ineligibility, '373 technical prong, and economic prong for all asserted patents), took no position on the reviewed issues, declined review of the rest, affirmed no violation, and terminated the investigation. (Federal Register notice)
• Recommended remedy/bonding (never imposed): limited exclusion order + cease-and-desist order + 100% bond, only if a violation had been found.

Note on your source list: The Google Patents family page for US11611621 also lists a second ITC entry, "337-TA-3722." I was unable to verify that number as a live investigation involving this patent family, and it does not appear in the Federal Register docket for the Samsara/Motive vehicle-telematics dispute. Per your instruction not to auto-correct identifiers, I am reporting it as listed but flagging it as unverified.

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2. Samsara, Inc. v. Motive Technologies, Inc. — District Court

This is a single case that moved venues, so it appears under two numbers.

Outcome / status:

• Samsara's original complaint asserted patent infringement plus Lanham Act false advertising, fraud, CFAA, and California UCL claims. An amended complaint (March 20, 2024) added a UCL false-advertising claim and a Delaware Deceptive Trade Practices Act claim.
• On August 14, 2024, Judge Noreika (D. Del.) granted Motive's § 1404(a) motion to transfer to N.D. Cal., finding the convenience factors "weigh strongly in favor of transfer" because both parties and their witnesses are in the Bay Area. She notably observed that Samsara's decision to file at the ITC shortly after filing in Delaware "calls into question whether Samsara ever fully intended to litigate in [Delaware] at all," and that Samsara's own TOS forum-selection clause (San Francisco County, California) weighed against it. (D. Del. D.I. 60, ECF 60)
• The patent claims in the transferred action were stayed under 28 U.S.C. § 1659(a) pending completion of the ITC investigation (Samsara did not contest the stay). Samsara's related non-patent claims were referred to JAMS arbitration before Judge Ware.
• Current status (as of early 2026): With the ITC investigation terminated in February 2026, the § 1659 stay has no continuing basis, but reporting from FreightWaves (March 2026) indicates the remaining district-court patent and trade-secret pieces were sitting in stayed proceedings with no trial date set. Samsara also stated it plans to appeal the ITC loss to the Federal Circuit. (FreightWaves, "Samsara awarded $30M over Motive's marketing claims; Motive beats patent infringement case")

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3. Samsara Inc. v. International Trade Commission — Federal Circuit

This is the appeal of the February 5, 2026 Commission determination and is the vehicle through which the '621 patent's validity/non-infringement holdings would be reviewed. Reported on the Unified Patents litigation portal and docketed via UniCourt. I did not locate a merits decision; as of today it is a pending appeal.

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4. Related proceedings that do NOT assert the '621 patent (context only)

• Motive Technologies, Inc. v. Samsara Inc., N.D. Cal. No. 3:24-cv-00902 (filed February 15, 2024). Motive's mirror-image action asserting U.S. 11,875,580 (the "'580 patent") plus Lanham Act, fraud, trade-secret (CUTSA/DTSA), defamation, and tortious-interference claims. Samsara counterclaimed on U.S. 11,975,685, 10,033,706, and 12,069,041. The '621 patent is not asserted in this case.
• JAMS arbitration (Samsara v. Motive, arbitrator Judge Ware). Arbitrator's sealed decision in February 2026 awarded Samsara $30.3 million on contract/fraud/unfair-competition/false-advertising claims; disclosed in Samsara's 10-K. This is arbitration, not litigation, and does not involve the '621 patent. (Samsara 10-K disclosure)
• Motive Technologies, Inc. v. Associated Industries Insurance Co. et al. (D. Del., Judge Sheldon K. Rennie). Insurance-coverage action arising from the Samsara litigation; court ordered insurers to defend Motive in the Samsara action. Not a patent case involving the '621 patent.

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Case-number key (as you requested, kept literal and not auto-corrected)

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Caveats

• The '621 patent was asserted in only one substantive forum — ITC 337-TA-1393 — plus the parallel district-court case that carried the same three patents and was stayed in its favor.
• Two of nine asserted '621/'130/'373 claims at the ITC were found infringed ('373 claim 15 as to Fuel Score v1/v2), but every asserted claim was either found non-infringed or invalid, and Samsara failed the domestic-industry economic prong for all three patents.
• I found no litigation asserting the '621 patent against any party other than Motive Technologies, and no final appellate decision on the '621 patent.
• The ITC "337-TA-3722" entry and any IPR proceedings specifically challenging the '621 patent are items I could not confirm; I am flagging them rather than asserting them as fact.

I'll verify the PTAB picture with targeted searches, since the ODP block says no AIA trials are on file.

Let me dig deeper, since the Samsara–Motive dispute has produced IPRs and the ODP block says none target this patent.

PTAB proceedings on file — US 11,611,621 ("Event detection system")

Canonical source check. The structured "PTAB proceedings on file" block for this patent (USPTO Open Data Portal) returns zero AIA trial proceedings — no IPR, no PGR, no CBM. My independent web searches of PTAB filings, docket aggregators, and the Samsara–Motive litigation record surfaced no petition naming U.S. Patent No. 11,611,621 as the challenged patent. The IPRs actually on file in the Samsara–Motive fight run the other direction: Samsara is the petitioner challenging Motive's patents (e.g., IPR2025-00574 on U.S. 11,875,580; IPR2026-00108), not the reverse. So the ODP "no AIA trials" result is corroborated, not contradicted.

I am flagging this explicitly because the temptation here is to treat the dense parallel litigation as PTAB activity. It is not. Below I separate the two categories cleanly.

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Proceedings overview

Total AIA trial proceedings on file against US 11,611,621: 0 (0 active / 0 claims invalidated / 0 claims sustained / 0 settled / 0 institution-denied). The bottom-line defensive posture for a defendant is not "the patent has survived IPRs and is hardened" and not "the claims are canceled" — it is that the patent has never been tested at the PTAB at all, while it has been tested hard in the ITC and lost. The '621 patent has never been narrowed by any AIA trial; zero claims are canceled; every claim (1–N) is untested at the PTAB. Its validity record comes entirely from non-PTAB forums — most importantly an ITC Final Initial Determination holding several asserted claims anticipated.

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There are no PTAB proceedings to enumerate.

The three AIA trial types (IPR / PGR / CBM) are absent for US 11,611,621. There is therefore no judge panel, no institution decision, no FWD, no settlement, and no § 315(e)(2) estoppel to report. I will not manufacture proceeding numbers to fill the template.

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Closest analogues (NOT PTAB — flagged so you don't mis-cite them)

These are the parallel proceedings that actually adjudicated the '621 patent's validity/infringement. Treat them as district-court/ITC evidence, not as AIA-trial records.

ITC Inv. No. 337-TA-1393 — Samsara Inc. v. Motive Technologies, Inc.

• Type: Section 337 investigation (not an AIA trial; not conducted at the PTAB)
• Filed: 2024-02-08 (complaint); instituted 2024-03-18 (89 FR 19356)
• Patents asserted: U.S. 11,611,621 ('621), 11,127,130 ('130), 11,190,373 ('373)
• Status (verbatim): "…the Commission has determined to review in part a final initial determination … and, on review, to affirm a finding of no violation of section 337 … The investigation is terminated with a finding of no violation." (Federal Register, 2026-02-10)
• Adjudicator: Presiding ALJ (evidentiary hearing 2024-11-14 and 2025-03-18–25); Commission review 2026-02-05
• Findings on the '621 patent (FID, 2025-09-08) — quoted verbatim from the Commission notice:
  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";
  4. "Samsara has satisfied the technical prong of the domestic industry requirement."
• Also: Samsara failed the economic prong of domestic industry for all three asserted patents; the Commission reviewed in part and took no position on the issues under review, declining review of the rest.
• Appeal: Reported CAFC docket 26-1630 appears on the patent's litigation record (Google Patents litigation links). ⚠️ I could not confirm from the sources retrieved whether 26-1630 is an appeal of the ITC determination, the district court, or something else — do not assume provenance.
• Defensive value: The single most important fact for a defendant is that a neutral ALJ found claims 1, 2, 4, and 5 anticipated and uninfringed, and the Commission terminated with a finding of no violation. That is powerful prior-adjudication material even though it carries no PTAB estoppel.

Samsara Inc. v. Motive Technologies, Inc. — parallel district court actions

• D. Del. 1:24-cv-00084 (complaint identified the '621 patent; exemplary claim 8 quoted in the pleading)
• N.D. Cal. 3:24-cv-06049 and 3:24-cv-00902 (Motive v. Samsara and consolidated proceedings; partial-stay briefing tied to the IPRs on Motive's patents)
• CourtListener: https://www.courtlistener.com/docket/68254259/motive-technologies-inc-v-samsara-inc/
• Defensive value: Motive's invalidity contentions on the '621 patent (initial 2024-05-30; final 2024-07-22) are public and are the ready-made prior-art map for anyone else attacked on this patent.

Reexamination flag (unconfirmed)

One docket reference mentions "reexamined patents" in the N.D. Cal. stay briefing. I could not confirm that any ex parte reexamination is on file for the '621 patent specifically, and a reexam is in any event not an AIA trial. Verify via Patent Center before relying on it.

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Strategic summary

Claim status. Because there is no PTAB FWD, no claim of US 11,611,621 has been canceled, and none has been formally sustained through an AIA trial. Every claim is "untested" in the PTAB sense. The only claim-level validity rulings on the record are the ITC's, and they are adverse to the patent owner on the asserted set: claims 1, 2, 4, and 5 held anticipated; claim 3 not shown invalid on the anticipation theory presented; claims 2–4 not shown obvious. Note the precise scope — the ITC ruling is on the asserted claims 1–5, not the whole patent, and the patent contains further claims (claim 8 is an independent method claim recited in the district-court complaint). Do not represent the ITC finding as a PTAB cancellation of claims — it is an ITC invalidity finding that has no statutory estoppel effect on the Board or on other defendants.

Estoppel landscape. There is no § 315(e)(2) estoppel, because no petitioner ever reached a final written decision on this patent. That cuts both ways: (a) the patent owner cannot claim any PTAB-hardening benefit; and (b) no prior-art ground is foreclosed to you — the entire field of art is still available to a fresh petitioner. The ITC's invalidity findings, while persuasive, do not estop anyone and were reached on the evidentiary record of that investigation.

The § 315(b) clock is the real issue. For a defendant currently served with a complaint asserting the '621 patent, the one-year statutory bar under 35 U.S.C. § 315(b) governs. In the Samsara–Motive litigation this was front-and-center (the N.D. Cal. briefing recites that "[a] patent defendant must file an IPR petition within one year of being served with the complaint"). If you are within that window, an IPR is still procedurally available; if you are outside it, this patent may be one you can no longer reach at the PTAB at all — which is precisely why it remains "untested" here.

Pattern signals. The same petitioner (Samsara) has filed multiple IPRs in this dispute, but against Motive's patents — a one-directional PTAB campaign. There is no defensive aggregator (no Unified Patents petition) in the chain; the only Unified reference is their public patent-profile page, not a filing. The patent owner (Samsara) has been the aggressor in the ITC and district court, and has pursued appellate review (reported CAFC 26-1630), but has not had to defend this patent at the PTAB.

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Recommended next steps

• Confirm the negative on the record. Pull US 11,611,621 in PTAB E2E / Patent Center (https://ptacts.uspto.gov/ptacts/) and the Patent Trial and Appeal Board's public "Patent Number" search before advising a client there is no AIA history. The ODP block and my searches agree, but a live E2E check is the defensible step.
• Do not cite the ITC FID as an FWD. It is an Initial Determination/Commission determination in Inv. No. 337-TA-1393, not a PTAB Final Written Decision. If you need the primary document, use the Commission's Federal Register notice of 2026-02-10 (https://www.federalregister.gov/documents/2026/02/10/2026-02577/) and the Commission's 2026-02-05 determination.
• Run the § 315(b) date first. Compute the date you (or your privy) were served with any complaint asserting the '621 patent. If you are inside one year, a petition is still on the table and no ground is estopped — the full art field plus the ITC's anticipation record is available. If you are outside one year, the PTAB door is likely closed and your invalidity case lives in the district court.
• Mine the public invalidity contentions. Motive's initial (2024-05-30) and final (2024-07-22) invalidity contentions for the '621 patent are in the public ITC/docket record and give you a validated starting map for § 102/§ 103 theories.
• If active PTAB proceedings do not exist, say so plainly — as done here. The absence is itself a strategic datum: this heavily asserted patent has conspicuously not attracted an IPR, which may reflect the § 315(b) bar having run against the principal accused infringer rather than any judgment that the claims are strong.

Confidence note: The "zero AIA trials" conclusion is high-confidence (structured source + corroborating searches). The CAFC docket 26-1630's provenance and the existence of any '621-specific reexamination are low-confidence and are flagged as unverified — I did not fabricate outcomes for either.

I'll research the assignment record and litigation context for US 11611621 before reconstructing the chain.

Let me verify the litigation context and assignment specifics.

Let me attempt to pull the specific reel/frame records and correspondent of record.

US 11611621 — Ownership & Assignment Reconstruction

Patent: US 11,611,621 B2 — "Event detection system"
Application: US 17/301,658 (filed 2021‑04‑09); continuation of Ser. No. 16/395,960 (filed 2019‑04‑26)
Granted: 2023‑03‑21 · Family: continuations US 18/169,031 → US 12,137,143 B1; 18/408,292 → US 12,438,947 B1; 18/903,655 → US 12,464,045 B1

Data-availability note (important): In this environment the USPTO Assignment Center (assignmentcenter.uspto.gov) and its assignment.uspto.gov index could not be queried directly; the run returned search-result pages only. Everything below is grounded in (a) the Google Patents legal-events record for this patent, (b) Samsara's own ITC complaint exhibit list, and (c) the 10‑K/EDGAR record. Where a reel/frame or a correspondent of record could not be confirmed, I say so rather than invent one.

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Inventors

Ten named inventors, all listed at California addresses except Delegard (Ohio), consistent with a San Francisco–HQ company filing:

Employer is Samsara Networks Inc. at the 2019 priority filing. Note the assignee name on the 2021 record is still the pre‑rename entity (see below).

Unusual patterns: None supportable. All ten inventors executed the original assignment to the applicant, and the patent was never separated from the operating company — there is no evidence here of inventors departing before a fire‑sale. Caveat: I could not confirm any inventor's later employment; that is a gap, not a clean bill of health.

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Original assignee

Samsara Networks Inc. (address of record: 1 De Haro Street, San Francisco, CA 94107) is named as applicant/assignee on the issued patent — even though the company had already renamed itself Samsara Inc. in February 2021, before the 2021‑04‑09 continuation filing. EDGAR confirms the corporate history: "Samsara was incorporated in Delaware in 2015 as Samsara Networks Inc. and changed its name to Samsara Inc. in February 2021."

• Line of business: Connected-operations / fleet telematics — IoT Vehicle Gateways, CM11/CM22/CM31/CM32 AI dashcams, and the "Connected Operations Cloud." Samsara Inc. is a publicly traded operating company (NYSE: IOT) with ~$1.9B ARR.
• Product embodying the claims: Yes. Samsara's own ITC complaint ties the asserted '621 claims (1‑5, 8‑12, 15‑19) to its video‑based safety platform, which detects harsh driving events and uploads crash/near‑miss footage — the exact subject matter of the specification.
• Status: Operating and solvent; not acquired, dissolved, or in bankruptcy.

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Assignment timeline

Two recorded assignment events are corroborated on Google Patents for this patent; a four-record cluster exists for the three patents Samsara asserted together, per Samsara's own ITC complaint exhibit list. I flag the mapping ambiguity rather than guess.

• 2021‑04‑09 (executed) / recorded 2021‑04‑09 — Reel/Frame not independently confirmable (candidate: 050612/0001, associated with the asserted-patent family per Samsara's ITC complaint exhibit list)

  • Conveyance: Assignment
  • Assignor: Saleh ElHattab; Justin Joel Delegard; Bodecker John DellaMaria; Brian Tuan; Jennifer Winnie Leung; Sylvie Lee; Jesse Michael Chen; Sean Kyungmok Bae; Angel Manalastas Lim; Timothy John Passaro
  • Assignee: Samsara Networks Inc.
  • Correspondent: Not established from available sources — flag as unknown, do not infer.
  • Context: Founder/inventor assignment to the operating applicant at the continuation filing date.

• 2023‑10‑26 (recorded) — Reel/Frame not independently confirmable (candidate: 056177/0578, per the same exhibit list)

  • Conveyance: Change of Name (recorded as "Change of Name (See Document for Details)")
  • Assignor: Samsara Networks Inc.
  • Assignee: Samsara Inc.
  • Correspondent: Not established from available sources — flag as unknown.
  • Context: Internal reorg / name‑change only — no change in beneficial ownership. Note the recorded date (2023‑10‑26) trails the actual Delaware name change (February 2021) by ~2.5 years; it is a housekeeping correction to align the patent record with the renamed entity.

Assignment records referenced by Samsara's ITC complaint for the asserted-patent group: reel/frames 050612/0001, 055665/0121, 055881/0776, 056177/0578. The complaint states "Exhibits 4‑6 are assignment records relating to the Asserted Patents" and asserts "Samsara owns all rights, title, and interest in each of the Asserted Patents, including the right to sue." I could not definitively resolve which of these four belongs to the '621 patent specifically — treat the reel/frame‑to‑patent mapping as unconfirmed.

Bottom line: there is no post‑issuance arms‑length transfer. The only non‑inventor record is a change of name. Ownership has never left the Samsara corporate family.

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Timeline diagram

timeline
    title Ownership of US 11611621
    2019 : Priority application filed by Samsara Networks Inc
    2021 : Continuation filed
         : Inventors assign to Samsara Networks Inc
         : Company renamed Samsara Inc
    2023 : Issued as US 11611621
         : Change of name recorded to Samsara Inc
    2024 : Samsara sues Motive at ITC and district court
    2026 : ITC affirms no violation against Motive

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NPE / troll-pattern signals

1. Shell‑entity transfer — not present. Chain runs inventors → Samsara Networks Inc. → Samsara Inc. No "IP/Holdings/Ventures/Licensing" entity, no registered‑agent address, no single‑purpose LLC. The 2023‑10‑26 record is a Change of Name by conveyance type, not a sale.

2. Known asserter in the chain — not present. No assignee matches the Acacia / Marathon / IV / Wi‑LAN / Conversant / Pendrell / Spangenberg lists. The asserter here is Samsara Inc. (NYSE: IOT), and the Stanford NPE Litigation Database classifies the litigation Samsara Inc. v. Motive Technologies Inc. (3:24‑cv‑06049, N.D. Cal.) with asserter category "8 – Product company," i.e., the inverse of an NPE.

3. Repeat correspondent across the chain — unclear / no finding. Only two records exist and the correspondent of record could not be pulled. A single appearance would not be a finding in any event; there is no recurrence to cite. Do not populate this from naming alone.

4. Cascading transfers (<24 months) — not present. Two records over ~2.5 years, one of which is a name change, both to the same corporate family. No chained LLCs, no shared correspondent addresses to compare.

5. Pre‑litigation transfer — not present. The nearest record (2023‑10‑26 change of name) precedes the first suit (ITC complaint filed 2024‑02‑09; district court 3:24‑cv‑06049) by ~4 months, but it is a name‑change housekeeping entry, not an assignment to a new owner, so it does not indicate a chain "arranged to enable assertion." Samsara asserted as the party that built and sells the product.

6. Bankruptcy fire‑sale — not present. No Chapter 7/11 assignor anywhere in the chain; Samsara has never been a debtor entity in these records.

7. Privateering — not present. The operating company did not hand the patent to an NPE to assert on its behalf; Samsara litigates in its own name (ITC Inv. 337‑TA‑1393; N.D. Cal. 3:24‑cv‑06049) against a direct market competitor, Motive Technologies Inc.

8. Defensive aggregator — not present. Chain terminates at Samsara Inc., an operating company asserting offensively. RPX/AST/LOT/Unified/OIN appear nowhere — note the opposite posture: Unified Patents and RPX track Samsara as an operating-company plaintiff in their patent portals.

Litigation outcome context (not an ownership signal, but material to the "assert" story): The ITC's final initial determination (2025‑09‑08) found no violation — claims 1‑5 of '621 not shown infringed, and claims 1, 2, 4, 5 held anticipated; the Commission affirmed on review and terminated the investigation in February 2026. Samsara has sought Federal Circuit review (appeal 26‑1630). A related N.D. Cal. case and a Delaware case (1:24‑cv‑00084) remain in play. None of this changes ownership.

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Verdict

Operating‑company assertion.

Ownership never left the Samsara corporate family: the only two records are the inventor→Samsara Networks Inc. assignment at the 2021‑04‑09 continuation filing and a Change of Name to Samsara Inc. recorded 2023‑10‑26 (reel/frame candidates 050612/0001 and 056177/0578 per the asserted-patent exhibit list, mapping unconfirmed). No shell‑entity transfer, no known NPE, no cascading LLC transfers, and no defensive aggregator appear in the chain. Samsara Inc. ships products embodying the claims (CM‑series AI dashcams on the Connected Operations Cloud) and asserted this patent in its own name against competitor Motive — the Stanford NPE database tags the suit "Product company" (category 8). No genuine NPE/troll signal is supported by the evidence.

Verify at: https://assignmentcenter.uspto.gov/ (search patent 11611621) · https://patents.google.com/patent/US11611621/en (Legal Events) · https://npe.law.stanford.edu/patent/11611621 · https://portal.unifiedpatents.com/patents/patent/US-11611621-B2

Open items to close from the primary source: (1) the exact reel/frame for each of the two '621 records; (2) the correspondent of record on both records — the one field I could not source, and the field your workflow treats as the key tell. Neither gap changes the verdict, since both conveyances stay inside the same operating company.

I'll search for USPTO records and the cited prior-art references for US 11,611,621.

Prior-Art Analysis — US 11,611,621 B2 ("Event detection system")

Task note on scope. I searched for the specific identifier 11611621 and report results only for US 11,611,621 B2. I did not return or substitute results for any other number. All alphanumeric identifiers below are reproduced literally as found; where two databases render the same field differently I show both rather than correcting one to the other.

Search-budget caveat (important). I hit my tool-call limit before I could (a) pull the complete front-page "References Cited" block (16 entries per Google Patents; I retrieved 15), or (b) identify the specific reference(s) the ALJ relied on for the § 102 anticipation holding in Inv. No. 337-TA-1393. Those two gaps are flagged explicitly rather than filled by inference. Do not treat the claim mapping below as a legal opinion — the verbatim claim text of the '621 patent was not available to me (the patent text supplied to me stops before the claims).

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1. USPTO record confirmation

New, corroborated fact that refines the earlier section. An ITC notice (Inv. No. 337-TA-1393, Commission determination not to review ID Order No. 29, vote 2024-11-05) records that Samsara moved to partially terminate by withdrawing claim 17 of the '373 patent and claims 8 and 10–12 of the '621 patent. The '621 patent therefore contains at least claims 1–12, which confirms the earlier section's caution that the patent has more claims than the five that were litigated to judgment. (USITC notice PDF)

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2. The 16 "Patent Citations" appearing on/with US 11,611,621

Source: Google Patents, "Patent Citations (16)" for US11611621B2. Columns below reproduce Google Patents' own layout (priority date / publication date). I retrieved 15 of 16 — the sixteenth was not rendered in my search results.

2a. Third-party references (true prior art candidates)

2b. The applicant's own same-family filings (NOT prior art)

Do not over-read this table. A patent's "References Cited" is art that was considered, not art that was found to anticipate. Given the 2019-04-26 priority, items 6, 11, 12 and 13 were already published after the priority date, so they can only be § 102(a)(2) art (i.e., only if "effectively filed" before 2019-04-26 and naming another inventor), and items 14–15 are not art at all. That materially narrows the anticipation-eligible set.

2c. Non-patent literature

Unified Patents lists "Non-Patent Literature (3)" for this patent; I retrieved only one item, and it is corroborated as a real publication:

• Su, C.-C., et al., "Bayesian depth estimation from monocular natural images," Journal of Vision, 17(5):22 (2017), DOI 10.1167/17.5.22. (scite.ai record) This is the natural fit for the specification's "stereoscopic inference model … to construct a 3-dimensional (3D) depth model based on monocular image data" passages. Flagged: I confirmed the paper exists and its bibliographic data; I did not confirm it appears on the '621 patent's face.

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3. Which references could plausibly anticipate which claims

Methodological constraint, stated plainly. Anticipation under 35 U.S.C. § 102 requires a single reference disclosing every element of the claim "as arranged." I do not have the verbatim claim text of the '621 patent, so the mapping below is a relevance assessment keyed to the elements that the specification and abstract place in the claims — detecting an event/precursor from sensor data, indexing an object model by event type, and selectively streaming a portion of the data streams to a server per the object model's procedure. Treat each entry as "candidate, unverified."

Bottom line on the face-citations: on the record available to me, none of the 15 retrieved citations discloses the "object model that defines a procedure" limitation that the specification makes the centerpiece of the claimed invention. The most-likely anticipation target among them is the crash-detection/remote-reporting art (US 10,623,899 B2; secondarily US 2014/0012492 A1 and US 2018/0262724 A1).

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4. The litigation-grounded prior art — the part I could not close

The ITC's Final Initial Determination (2025-09-08) found, for the '621 patent, that claims 1, 2, 4 and 5 are invalid as anticipated under 35 U.S.C. § 102, while claim 3 was not shown invalid and claims 2–4 were not shown obvious. The Commission affirmed no violation and terminated the investigation (81 Fed. Reg., 2026-02-10; Fed. Reg. doc. 2026-02577). (Federal Register XML; ALJ FID notice PDF)

What this tells us structurally (inference, flagged): that claims 2, 4 and 5 rose and fell with claim 1 on anticipation while claim 3 survived implies claims 2–5 all depend from claim 1 (or from one another) and that claim 3 adds a limitation the anticipatory reference lacked. This is consistent with the earlier section's finding that at least claims 1–5 were asserted; it does not, by itself, tell us how many independent claims exist (the patent has at least 12 claims, per § 1 above).

What I could not do: identify the specific anticipatory reference(s) Motive proved and the ALJ credited. That identity lives in the confidential/public versions of Motive's invalidity contentions and the FID, neither of which I retrieved before exhausting my search budget. I will not guess a reference number for this. To close it, the primary sources are the ITC EDIS docket for 337-TA-1393 (https://edis.usitc.gov) and, for the appeal, CAFC No. 26-1630 (Samsara Inc. v. ITC, noticed filed 2026-04-08).

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5. Explicit uncertainties and contradictions to flag

1. Contradiction with the earlier section that should be resolved in favor of the new evidence: the earlier section listed the ITC case as "337-TA-1393" while also flagging "337-TA-3722" as a likely artifact. The Federal Register text I retrieved confirms 337-TA-1393 and does not mention 337-TA-3722. The earlier section's skepticism about 337-TA-3722 stands.
2. Complete 16th citation not retrieved. Google Patents reports 16 patent citations; I captured 15. Treat the list as complete-minus-one.
3. Titles for citations #2, #6, #8, #9 and #13 were not retrieved. I have deliberately left those blank rather than assign plausible-sounding titles.
4. Claim text still unavailable. All § 102 mapping in § 3 is element-level relevance reasoning, not claim-charting. The word "anticipates" for those rows should be read as "is a candidate that could bear on," not as a conclusion.
5. Date offsets between databases (2019-04-25/26; 2021-04-08/09; 2023-03-20/21) are preserved as retrieved and not reconciled.

Sources actually retrieved

• Google Patents, US11611621B2 — Patent Citations table
• Unified Patents portal, US-11611621-B2 — bibliographic data, article counts (Patent Art (78); Non-Patent Literature (3))
• idiyas patent badge 11611621
• ITC FID notice, Inv. No. 337-TA-1393
• USITC partial-termination notice (withdrawn claims 8, 10–12 of '621)
• Federal Register 2026-02577 (2026-02-10)
• scite.ai — Su et al. 2017, Journal of Vision

I'll gather the actual prior-art references cited against (and by) US 11,611,621 before constructing the §103 combinations.

Excellent — I now have the verbatim claim 8 text. Let me pull the actual cited prior art on the face of the patent and the references Motive used at the ITC.

Let me retrieve the specific prior-art references listed on the patent's face (the "Patent Art (78)" set).

Obviousness Analysis Under 35 U.S.C. § 103 — U.S. Patent No. 11,611,621 ("Event Detection System")

0. Source caveat (read first)

The instruction is to use "the results from the Prior Art section of this page." I have to flag a discrepancy: the authoritative patent text supplied for this analysis does not contain a Prior Art / "References Cited" section. The Google Patents rendering provided stops at the end of the written description, and the Unified Patents profile confirms only that the patent carries "Patent Art (78)" and "Non-Patent Literature (3)" — it does not expose the 81 individual citations. My targeted searches returned the abstract, specification, litigation record, and claim 8 verbatim, but not the enumerated list of 78 patent references.

Rather than fabricate reference numbers, I build the § 103 case below on what is verified:

Where I name a reference below, I mark confidence. The specific § 102 reference that anticipated claims 1, 2, 4, and 5 at the ITC was not retrievable, and I do not guess at it.

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1. Governing legal standard

The '621 patent has an effective filing date of 2019-04-26 (continuation of Ser. No. 16/395,960, filed 2019-04-26). It is squarely post-AIA, so AIA §§ 102/103 apply, KSR's expansive obviousness standard governs, and there is no pre-AIA § 102(g)/swear-behind escape hatch.

The four Graham factors (Graham v. John Deere Co., 383 U.S. 1, 17–18 (1966)) drive the analysis:

1. Scope and content of the prior art
2. Differences between the claimed invention and the prior art
3. Level of ordinary skill in the pertinent art
4. Secondary considerations (objective indicia)

Under KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 406, 418 (2007), a claim is obvious where "the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date." The Supreme Court rejected rigid application of the teaching–suggestion–motivation test and endorsed the MPEP § 2143 rationales, including: combining prior-art elements according to known methods; simple substitution of one known element for another; use of a known technique to improve a similar device; and "obvious to try" where there is a finite number of identified, predictable solutions (In re O'Farrell, 853 F.2d 894, 903 (Fed. Cir. 1988); In re Applied Materials, 692 F.3d 1289, 1295 (Fed. Cir. 2012)).

Two doctrines matter especially here:

• The test is what the combined teachings suggest, not bodily incorporation. In re Keller, 642 F.2d 413, 425 (CCPA 1981); In re Sneed, 710 F.2d 1544, 1550 (Fed. Cir. 1983).
• A new label for a known element adds nothing. Reciting only the function or result of a known structure does not patentably distinguish over art that inherently performs it. In re Swinehart, 439 F.2d 210, 213 (CCPA 1971). This directly attacks the "object model" terminology (below).

Level of ordinary skill (POSITA)

The PTAB, in the co-pending Samsara–Motive IPR on the related '580 patent (IPR2025-00574), adopted the patent owner's proposed POSITA:

"a bachelor's degree in engineering or computer science with one or two years training and/or experience in design of software for camera/sensor systems in the automotive industry." (PO Resp. 8–9, citing Ex. 2003 ¶ 35; adopted in the Board's decision)

That is a verified, adversarial, on-point articulation from the same NPE/assignee dispute. For the '621 patent, a POSITA would additionally have ordinary familiarity with fleet telematics event detection, accelerometer/GPS-triggered event recorders, and (by 2019) convolutional neural networks for in-cabin and forward-scene vision. The field was crowded — the ITC Staff said so in terms: "Given the crowded field of art, the Staff believes the question of obviousness may be a close call."

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2. What is actually claimed (and the "object model" labeling problem)

Claim 8 (verbatim, from the complaint):

1. A method comprising:
   [8][i] accessing a first data stream from the plurality of data streams generated by a first sensor device mounted at the vehicle;
   [8][ii] detecting a feature within the first data stream generated by the first sensor device mounted at the vehicle, the feature comprising an image feature that corresponds with an event type from among a plurality of event types, the event type comprising a set of conditions that correspond with a procedure that comprises an identification of at least a second sensor device from among a plurality of sensor devices mounted at the vehicle, the procedure associated with a traffic sign represented by the image feature;
   [8][iii] selecting the second sensor device based on the procedure that corresponds with the event type, in response to the detecting the feature that corresponds with the event type within the first data stream;
   [8][iv] accessing a second data stream generated by the second sensor device, the second data stream comprising a set of attributes;
   [8][v] identifying a client device based on the detecting the feature that corresponds with the event;
   [8][vi] presenting a notification that includes an event indicator at the client device based on the set of attributes from the second data stream.

Claim 1 (reconstructed, not verbatim — high confidence in substance, medium in wording): the "object model" claim — access sensor data; detect an event or precursor to an event corresponding to an event type/category; in response, access an object model associated with the event type that defines a procedure (data flow, processing operations, data rate/resolution, visualization and notification instructions); and stream at least a portion of the plurality of data streams to a server system based on the procedure.

The "object model" is a label, not an invention

Every clause of claim 1 that gives the "object model" substance is functional and result-oriented:

Under In re Swinehart and MPEP § 2111.01, reciting a stored configuration object and its functional effects does not distinguish over prior art that performs the same functions — the "object model" is simply a data structure keyed to an event type, which is what any event-driven system has. This is the single most important § 103 insight about the '621 patent, and it is exactly the kind of "invocation of familiar elements according to known methods" that KSR holds obvious.

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3. The prior-art landscape

3.1 Applicant's Admitted Prior Art (AAPA) — the baseline

The specification concedes the entire hardware substrate:

"EDRs may include devices with an integrated onboard camera that continuously record data that include video, as well as acceleration, deceleration, speed, steering angle, global positioning system (GPS) data, and throttle position information."

And Samsara's own complaint (¶123) repeats the concession:

"Event data records (EDRs) have included devices that record data including video, acceleration, deceleration, speed, steering angle, global positioning system (GPS) data, and throttle position information. Such systems, however, lacked the functionality to efficiently detect and monitor safety events and precursors to safety events, in real-time…"

The specification also states that the plurality of sensors "may include a front facing camera, and a cabin facing camera," an accelerometer, a gyroscope, microphones, a temperature sensor, GPS sensors, and an ECU interface — and that they may be "coupled with a network gateway." All of this is conceded art. The only asserted novelty is the software architecture layered on top: event definitions → detection → object-model lookup → selective streaming.

This AAPA is independently fatal to any attempt to read the claims on hardware alone, and it supplies elements [8][i] and [8][iv] (first/second data streams from vehicle-mounted sensors) and the baseline streaming of claim 1.

3.2 The art categories that supply the remaining limitations

I could not retrieve the enumerated references, so I identify art by category with named exemplars, marking confidence:

Critical flag: the Choe, Khan, Ali, Westmacot, Workman references that appear throughout the Samsara–Motive record are horizon-line/camera-calibration art directed to U.S. 11,875,580 — a different patent owned by Motive. They must not be cited against the '621 patent. I am calling this out because the litigation walls are dense and the temptation to cross-cite is high.

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4. Ground-by-ground § 103 analysis

Ground 0 — Claims 1, 2, 4, and 5 are a fortiori obvious (strongest ground)

The ITC has already adjudicated these claims anticipated under § 102. The FID (2025-09-08) found: "Motive has shown that claims 1, 2, 4, and 5 are invalid as anticipated." The Commission declined review of that issue and terminated with a finding of no violation (91 FR 5954).

It is black-letter law that anticipation is the epitome of obviousness: "[i]t is axiomatic that that which would literally infringe if later in time anticipates if earlier than the date of invention," and a § 102 reference necessarily renders the claim obvious under § 103. In re Fracalossi, 681 F.2d 792, 794 (CCPA 1982); In re Etter, 756 F.2d 852, 859 (Fed. Cir. 1985) (en banc).

So for claims 1, 2, 4, and 5 the § 103 conclusion follows a fortiori from a neutral ALJ's anticipation finding on an adversarial record. The only reason to re-run the analysis is to build an independent-obviousness fallback, which the anticipation reference(s) provide automatically.

Value as a ground: High. It is the rare case where a § 103 conclusion is buttressed by a prior § 102 adjudication. Caveat: the ITC finding carries no statutory estoppel on the PTAB or on a subsequent district-court defendant (as noted in the PTAB section of this file), but it is powerful persuasive evidence.

Ground A — Claim 8: TSR + conditional second-sensor activation + notification

Claim 8 is a four-reference-combination target and the most clearly obvious independent claim in the patent. Map each limitation:

Claim 8's only arguable hook is the conditional activation of a second, different sensor in response to a sign detected in the first sensor's stream. That is the "use a known technique to improve a similar device in the same way" rationale (MPEP § 2143), and it is a design choice between a finite number of identified, predictable options — activate the cabin camera, activate the ECU bus, activate GPS — all of which a POSITA would select from when a forward camera flags a sign that implies a maneuver requiring corroboration (the very "rolling stop" example the specification gives: stop sign + inertial data + GPS data). In re Applied Materials, 692 F.3d at 1295.

Motivation (explicit): The specification itself states the technical problem — the existing systems "lack functionality to efficiently detect and monitor events … in real-time." Corroborating a single-modality detection with a second modality is the standard, well-understood way to improve detection confidence in sensor fusion. That is a textbook KSR motivation.

Value as a ground: High. Claim 8 is a method claim drafted entirely from known building blocks with functional labels glued by "based on."

Ground B — Claims 2–4 and the surviving claim 3 (the hard claim)

The FID found claim 3 not shown invalid, and claims 2–4 not shown obvious. So the obviousness theories Motive actually tried failed on claim 3. That makes claim 3 (and any undifferentiated sibling) the crux for a fresh § 103 attack, and it means repeating Motive's combination will not work — a different or stronger articulation of motivation is required.

I do not know claim 3's text (unverified). What I can say with confidence is how to attack it:

1. Rebuild the motivation on the Staff's own words. The ITC Staff — a neutral party — wrote: "Given the crowded field of art, the Staff believes the question of obviousness may be a close call… The evidence is expected to show that secondary considerations do not support a finding of non-obviousness." That is a ready-made, adversarial admission that the art is dense and that objective indicia are weak. It defeats the two most common non-obviousness rebuttals.
2. Attack any "precursor" limitation as a mere degree of detection. If claim 3 depends on the "precursor to an event" concept (detecting the stop sign before confirming the event), that is just a partial or probabilistic threshold on a detection pipeline. A lower confidence threshold / earlier decision point is a predictable, result-effective variable — obvious to optimize (In re Applied Materials; Wm. Wrigley Jr. Co. v. Cadbury Adams USA LLC, 683 F.3d 1356, 1364 (Fed. Cir. 2012) (predictable results / reasonable expectation of success)).
3. Attack any additional-condition limitation as obvious to try. If claim 3 adds a further sensor, threshold, or notification condition, the combination space is small and enumerated by the specification's own event definitions (roll-over, crash, speeding, rolling stop, distracted driver). Selecting one more condition from a disclosed finite list is obvious to try.

Value as a ground: Medium. This requires the actual claim 3 text, which I do not have. I flag this as the highest-value next task (see § 7).

Ground C — The data-rate / selective-streaming limitations

The spec's baseline-vs-elevated data-rate scheme ("under normal operating conditions … the event detection system may be configured to cause the sensor devices to generate sensor data at a reduced resolution, and to cause the gateway to stream segments of sensor data … at predefined intervals") is a classic bandwidth/storage optimization. Motivation is supplied by the specification itself (voluminous fleet data, bandwidth constraints) and by the universal design incentive to conserve cellular bandwidth and device storage. Changing sample rate/resolution as a function of detected event state is "use of a known technique to improve a similar device" and an "obvious design choice." MPEP § 2144.04; KSR, 550 U.S. at 417.

Ground D — Presentation / notification limitations (FIGS. 8–10)

Synchronized multi-stream playback, scrub-bar-linked sensor graphs, event logs, and map overlays are conventional GUI design. If any of these are claimed, they are obvious over fleet-telematics dashboards and general video-editing/telemetry-visualization practice; the motivation is the admitted need for "interfaces to enable users to manage and view recorded data" (spec, Background). I could not verify whether these features are claimed independently (flag).

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5. Articulated motivations to combine (the part the FID shows Motive got wrong)

The Federal Circuit requires an "articulated reasoning with some rational underpinning." In re Kahn, 441 F.3d 977, 988 (Fed. Cir. 2006). The following are the strongest available for the '621 patent:

1. The Applicant's own statement of the problem. The Background concedes that existing EDRs "lack functionality to efficiently detect and monitor events … in real-time." Where the specification frames the invention as solving a known deficiency of the conceded art, the motivation to combine is supplied by the applicant. This is why the AAPA is so powerful here.
2. A crowded, convergent field. The Staff's "crowded field of art" statement, plus the verified presence of Mobileye/autonomous-driving art in the same dispute's record, establishes that practitioners were actively combining camera vision with telematics event logic at the relevant time. KSR, 550 U.S. at 421 ("if a technique has been used to improve one device, and a person of ordinary skill in the art would recognize that it would improve similar devices in the same way, using the technique is obvious").
3. Sensor corroboration to reduce false positives. A single-modality detection is unreliable; adding a second, different sensor to confirm is the standard engineering fix. This is the motivation for claim 8's "select the second sensor device."
4. Bandwidth/storage constraints. Cellular data and onboard storage are finite; escalating capture only when a safety event is indicated is an obvious, result-effective optimization.
5. Design incentives for standardization and reuse. Mapping event types to configuration procedures ("object models") is the ordinary software-engineering practice of externalizing policy from code — a design choice, not an invention. Under In re Swinehart, calling it an "object model" adds nothing.

Note that the motivation need not be the applicant's or the inventor's, and need not appear in the references themselves. Belden Inc. v. Berk-Tek LLC, 805 F.3d 1064, 1073 (Fed. Cir. 2015).

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6. Anticipated counterarguments and rebuttals

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7. Bottom line and confidence

Conclusion. U.S. 11,611,621 is materially vulnerable under § 103. The claims are a software-architecture wrapper over conceded EDR hardware and many-times-conventional vision, telematics, and event-rule techniques. The two strongest grounds are:

1. Ground 0 (highest confidence): Claims 1, 2, 4, 5 are a fortiori obvious, because a neutral ALJ already held them anticipated — and anticipation is the epitome of obviousness (In re Fracalossi).
2. Ground A (high confidence): Claim 8 is obvious over (i) the conceded EDR AAPA + (ii) traffic-sign-recognition art + (iii) telematics event-definition/rule-lookup art + (iv) fleet alerting art, with the articulated motivation of sensor corroboration and real-time detection.

Claim 3 is the crux and remains unresolved. The ITC found it not invalid on the record Motive presented; I cannot analyze it properly without its text.

Explicit uncertainties:

• The enumerated "Patent Art (78)" / NPL (3) references were not retrievable; my reference identities are category-level and flagged. Any specific number not verified here should be pulled from the primary source before filing.
• Claim 1 is reconstructed, not verbatim; claim 8 is verbatim (from the D. Del. complaint).
• Claim 3's and claims 6–7/10–14's text is unknown.
• I did not reuse the Choe/Khan/Ali/Westmacot/Workman references — they belong to the '580 patent (Motive's), not the '621.

Recommended next steps:

1. Pull the verbatim claims from Google Patents US11611621B2 or Patent Center (app. 17/301,658) — specifically claims 3, 6, 7, and 10–19 — so the claim-3 and dependent-claim grounds can be completed.
2. Pull the face-of-patent "References Cited" list and the "Patent Art (78)" list (Unified Patents profile).
3. Obtain Motive's final invalidity contentions (2024-07-22) for the '621 patent from the stayed N.D. Cal. docket (3:24-cv-06049) — the ready-made, validated § 102/§ 103 map.
4. Obtain the ITC FID's claim-3 analysis to identify exactly why the obviousness theory failed, then remediate that gap rather than repeat it.