IP Law Daily, PATENT—N.D. Cal.: Post-trial order confirms Motive Technologies did not infringe Omnitracs’ asserted patents, (Aug 6, 2025)

By Saurabh Kashyap, B.A., M.A., LL.B., LL.M.

Two asserted patents found invalid for claiming patent-ineligible abstract ideas under § 101; the remaining two found valid but not infringed based on substantial trial evidence.

Ruling on post-trial motions in an infringement lawsuit filed by Omnitracs, LLC, against Motive Technologies, Inc., the federal district court in San Francisco, California, granted judgment as a matter of law in favor of Motive, holding that two of Omnitracs’ asserted patents were invalid for claiming patent-ineligible subject matter under 35 U.S.C. § 101. Further, the court denied Omnitracs’ motions to overturn the jury’s non-infringement verdict on all four asserted patents and rejected its request for a new trial, finding that the jury’s determinations were supported by substantial evidence and that the invalidated claims recited only well-understood, routine, and conventional activities that failed the Alice eligibility framework (Omnitracs, LLC v. Motive Technologies, Inc., No. 3:23-cv-05261-RFL (N.D. Cal. Aug. 5, 2025)).

Background. The plaintiff, Omnitracs, LLC, is a prominent provider of fleet management and vehicle telematics solutions. The defendant, Motive Technologies, Inc., is a fast-growing company offering electronic logging devices (ELDs), AI-enabled dashcams, and cloud-based fleet data systems. The two entities compete in the commercial vehicle software space, particularly concerning systems for driver behavior scoring and vehicle data transmission.

In this lawsuit, Omnitracs asserted U.S. Patent Nos. 9,014,906 (’906 patent), 9,390,628 (’628 patent), 9,402,060 (’060 patent), and 9,911,253 (’253 patent). These patents claim methods and systems for generating driver safety reports, transmitting data from vehicles to remote servers, and processing video data in connection with fleet safety events. Specifically, the ’906 and ’628 patents relate to driver summary reporting and wireless communication between in-vehicle and portable devices; the ’060 patent addresses server communication protocols; and the ’253 patent focuses on event-based video frame weighting.

Omnitracs filed this lawsuit alleging that Motive’s fleet management products infringed the asserted patents. Motive denied infringement and challenged the asserted claims’ validity. After a full jury trial in April 2025, the jury returned a verdict in favor of Motive, finding no infringement of any asserted claims and concluding that the ’906 and ’628 patents involved only conventional technology. Post-trial, Motive filed a Rule 50(b) motion seeking judgment that the ’906 and ’628 patents were invalid under § 101, while Omnitracs moved for judgment as a matter of law on infringement and validity, and alternatively sought a new trial.

Section 101 eligibility—’628 patent. Applying the Alice Corp. Pty. Ltd. v. CLS Bank Int’l, 573 U.S. 208 (2014) two-step framework, the court found that the asserted claims of the ’628 patent were directed to an abstract idea under step one. The court held that the claims merely involved “receiving, associating, and presenting data” and failed to recite any technical improvements. Omnitracs argued that the use of a two-device system—combining a data acquisition device and a portable wireless device—was novel. The court rejected this argument, citing In re TLI Commc’ns LLC Patent Litig., 823 F.3d 607 (Fed. Cir. 2016), which held that generic hardware does not render abstract claims patent-eligible.

Under Alice step two, the court held that the claimed combination lacked an inventive concept, relying on the jury’s finding that the claim elements were routine and conventional. Motive’s expert and documentary evidence established that similar two-device systems predated the patent, including the Turnpike system and U.S. Patent No. 7,860,568. The court further cited Miller Mendel, Inc. v. City of Anna, Texas, 107 F.4th 1345 (Fed. Cir. 2024), emphasizing that functional results without technical implementation do not meet the standard for inventiveness.

Section 101 eligibility—’906 patent. The court reached the same conclusion with respect to the ’906 patent. The asserted claims, which involved receiving and processing driver data to generate composite scores, were directed to abstract concepts under Cave Consulting Grp., Inc. v. Truven Health Analytics Inc., No. 15-cv-02177-SI, 2017 WL 6405621 (N.D. Cal. Dec. 15, 2017), aff’d, 756 F. App’x 997 (Fed. Cir. 2019). Although Omnitracs pointed to composite scoring as a technical advancement, the court held that scoring based on enumerated factors was not a technological innovation. Omnitracs also invoked dependent claim 15, which involved remote updates, but the court held that remote updating was conventional in 2012, as supported by expert testimony and Turnpike’s prior use.

Non-infringement—’628 patent. On the issue of infringement, the court found that substantial evidence supported the jury’s finding that Motive’s products did not infringe the ’628 patent. The claims required sending a “driver summary electronic report” to a remote device. Motive presented uncontroverted testimony that only raw data—not the assembled report—was transmitted. The jury was entitled to find that the data did not meet the ordinary meaning of a “report,” and the court declined to override that finding.

Non-infringement—’060 patent. The ’060 patent required a web server in the vehicle gateway using HTTP to communicate with a remote device. The court held that substantial evidence showed Motive’s system used the MQTT protocol instead. Expert testimony confirmed that the vehicle gateway functioned as a client, not a server, for HTTP purposes. The court found that a reasonable jury could conclude that the system did not satisfy the claim limitations.

Non-infringement—’253 patent. The asserted claims of the ’253 patent required a method of assigning frame values that decreased with increasing time away from a vehicle event. The jury found that Motive’s system, which used AI-based confidence scoring, did not determine frame values based on temporal distance. Motive demonstrated that confidence values fluctuated based on object visibility and other factors. The court concluded that this evidence supported the non-infringement verdict.

Omnitracs’ motion for new trial. The court rejected Omnitracs’ arguments for a new trial, finding no prejudicial error. First, references to the use of an alias by a Motive executive were invited by Omnitracs’ own direct examination and were appropriately addressed in cross-examination. Second, any violations of in limine orders regarding legal review of patent notices were promptly cured with jury instructions. Third, the bifurcation of the verdict form and the "choose-your-own-adventure" analogy did not mislead the jury. The court emphasized that jurors were repeatedly instructed to decide the case based on evidence and not on procedural shortcuts, and there was no indication that they failed to do so.

The Case is No. 3:23-cv-05261-RFL.

Judge: Lin, R.

Attorneys: Akshay Sunil Deoras (Kirkland & Ellis LLP) for Omnitracs, LLC. Brent P. Ray (Arnold & Porter Kaye Scholer LLP) for Motive Technologies, Inc. f/k/a KeepTruckin, Inc.

Companies: Omnitracs, LLC; Motive Technologies, Inc. f/k/a KeepTruckin, Inc.

Cases: Patent CaliforniaNews