IP Law Daily, PATENT—N.D. Ill.: Motorola’s direct infringement claims against global provider Hytera fail, indirect claims survive, (Apr 14, 2026)

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

The court found that Hytera did not complete or control the claimed system, but factual disputes remained on customer infringement and the company’s knowledge and encouragement of infringing use.

A federal district court in Illinois has granted in part and denied in part Hytera Communications Corporation Ltd.’s motion for partial summary judgment in an infringement lawsuit filed by Motorola Solutions, Inc. The court found Hytera, a global provider of critical communications technologies and solutions, did not directly infringe Motorola’s group radio communication system patent as a matter of law but allowed Motorola’s claims for induced and contributory infringement to proceed. The court found no evidence that Hytera itself completed or used the claimed system but determined that genuine disputes of material fact existed regarding whether Hytera’s customers directly infringed and whether Hytera knowingly encouraged or contributed to such infringement. The court also dismissed with prejudice Motorola’s infringement claims relating to Hytera’s H-Series products, following Motorola’s concession that those products were not accused (Motorola Solutions, Inc. v. Hytera Communications Corp., Ltd., No. 1:17-cv-01972 (N.D. Ill. Apr. 8, 2026)).

Background. Motorola Solutions, Inc., a provider of mission-critical communications systems, brought the action against Hytera Communications Corporation Ltd., a Chinese manufacturer of digital mobile radio devices and related infrastructure.

The asserted patent, U.S. Patent No. 6,591,111 (the ’111 patent), related to a group radio communication system enabling point-to-multipoint communications across interconnected radio sub-networks. The patent, filed on December 10, 1999, and issued on July 8, 2003, covered both system and method claims directed to coordinating communication between multiple radio sub-networks through a group controller and a packet-switched data network. Motorola asserted Claims 11, 13, and 15, which required, among other elements, overlapping radio coverage areas, incompatible communication protocols, and the use of packet-switched data communications networks. The patent expired on December 10, 2019.

Motorola filed suit alleging that Hytera’s Legacy, i-Series, and H-Series products infringed the ‘111 patent through direct, induced, and contributory infringement. Hytera moved for partial summary judgment, arguing that its products did not infringe as a matter of law. With respect to the H-Series products, Hytera contended that no infringement could occur because those products were introduced after the patent expired.

H-Series products. The court first addressed the H-Series products and concluded that Motorola had effectively withdrawn its infringement allegations. Relying on its prior order and Motorola’s concession, the court dismissed the H-Series-related claims with prejudice. This narrowed the dispute to the Legacy and i-Series products and eliminated any claim based on post-expiration conduct.

Direct infringement. On direct infringement under 35 U.S.C. § 271(a), the court sided with Hytera. Hytera argued that it merely sold hardware and software components, while the complete claimed system required configuration and integration by customers or dealers. Motorola countered that Hytera’s activities—including installation, testing, and training—constituted “use” of the system.

The court rejected Motorola’s position, finding that Hytera did not perform the “final act” necessary to complete the patented system. Distinguishing CenTrak, Inc. v. Sonitor Techs., Inc., 915 F.3d 1360 (Fed. Cir. 2019), the court found no evidence that Hytera assembled all claim elements. Instead, it relied on Centillion Data Systems, LLC v. Qwest Communications International, Inc., 631 F.3d 1279 (Fed. Cir. 2011), which held that direct infringement requires a party to control the system as a whole and put it into service. Because Hytera’s customers or dealers completed the system configuration and controlled its operation, Hytera itself did not “use” the claimed invention.

Accordingly, the court granted summary judgment of no direct infringement, holding that no reasonable jury could find Hytera liable under § 271(a).

Indirect infringement. Turning to indirect infringement under §§ 271(b) and (c), the court emphasized that both induced and contributory infringement require proof of an underlying act of direct infringement. Citing Linear Tech. Corp. v. Impala Linear Corp., 379 F.3d 1311 (Fed. Cir. 2004), and Limelight Networks, Inc. v. Akamai Techs., Inc., 572 U.S. 915 (2014), the court examined whether Hytera’s customers could directly infringe.

Hytera argued that its products were merely capable of infringement and could also be configured in non-infringing ways. Motorola, however, presented evidence that customers used the accused Smart Dispatch systems in configurations that satisfied the claim limitations, including in packet-switched networks and overlapping coverage areas.

The court found genuine disputes of material fact regarding Claims 11, 13, and 15, particularly on whether the accused systems necessarily used packet-switched networks and overlapping coverage. Because a reasonable jury could find that customers directly infringed, the threshold requirement for indirect infringement was satisfied.

Knowledge of the patent.Hytera next argued that Motorola failed to show that it had knowledge of the ‘111 patent. It contended that general awareness of Motorola’s patent portfolio or alleged copying of technology was insufficient.

The court acknowledged that general knowledge of a patent portfolio alone is inadequate, citing SiOnyx, LLC v. Hamamatsu Photonics K.K., 330 F. Supp. 3d 574 (D. Mass. 2018). However, it found that Motorola’s evidence went beyond mere general awareness. Motorola presented evidence that Hytera engineers had access to and allegedly copied Motorola’s source code and technical documents.

Although Hytera disputed whether this established knowledge of the specific patent, the court held that this created a factual question for the jury. Given the parties' competitive relationship and the alleged copying, a reasonable jury could infer knowledge of the patent.

Contributory infringement. On contributory infringement under § 271(c), Hytera argued that its Smart Dispatch system had non-infringing uses and therefore could not form the basis for liability.

The court rejected this argument, emphasizing that the relevant inquiry is whether the accused product has “substantial” non-infringing uses, citing Vita-Mix Corp. v. Basic Holding, Inc., 581 F.3d 1317 (Fed. Cir. 2009). The court found that Hytera failed to demonstrate that such non-infringing uses were substantial.

Moreover, Motorola presented evidence that the accused functionality, such as enabling overlapping coverage and packet-switched communication, was central to the product’s intended operation. Relying in part on Koninklijke Philips N.V. v. Zoll Medical Corp., 656 F. App’x 504 (Fed. Cir. 2016), the court held that the existence of hypothetical non-infringing uses did not preclude liability where the infringing functionality was a core feature.

Accordingly, the court denied summary judgment on contributory infringement.

Induced infringement. Finally, the court addressed induced infringement under § 271(b). Hytera argued that it did not take affirmative steps to encourage infringement and that its training and support materials were neutral. Motorola countered with evidence that Hytera’s engineers trained customers and dealers to configure systems in infringing ways, supported by instructional materials and technical assistance.

The court found that this evidence raised genuine issues of fact. Citing Barry v. Medtronic, Inc., 914 F.3d 1310 (Fed. Cir. 2019), the court held that training materials, manuals, and technical support could constitute active steps encouraging infringement. Because a reasonable jury could find that Hytera induced its customers to infringe, summary judgment was denied on this claim as well.

Conclusion. Finally, the court ultimately granted summary judgment in Hytera’s favor on direct infringement and dismissed claims relating to the H-Series products but allowed Motorola’s induced and contributory infringement claims to proceed to trial with respect to the Legacy and i-Series products.

The Case is No. 1:17-cv-01972.

Judge: Valderrama, F.

Attorneys: Argie Lagrimas Mina (Kirkland & Ellis LLP) for Motorola Solutions, Inc. Andrew Alexander (Calfee, Halter & Griswold LLP) for Hytera Communications Corp. Ltd. and Hytera America, Inc.

Companies: Motorola Solutions, Inc.; Hytera Communications Corp. Ltd.; Hytera America, Inc.

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