Omnitracs, LLC v. Motive Technologies, Inc.

Background

This patent-infringement case involved the ’906, ’628, ’060, and ’253 Patents owned by Omnitracs, LLC and other plaintiffs. On April 24, 2025, the jury found that Motive Technologies, Inc. did not infringe the asserted claims of any of the four patents. The jury also found that the asserted claims of the ’906 and ’628 Patents were not invalid, while finding that they involved only activities a skilled person would have considered well-understood, routine, and conventional when the patent applications were filed.

Motive renewed its motion for judgment as a matter of law—a request for the court to enter judgment despite the jury’s verdict—as to the eligibility of the asserted claims of the ’628 and ’906 Patents under 35 U.S.C. § 101. Omnitracs moved for judgment as a matter of law that Motive infringed the asserted claims of the ’628, ’060, and ’253 Patents and that the asserted claims of the ’628 and ’906 Patents were not well-understood, routine, and conventional. Omnitracs also moved for a new trial on all issues.

Motive’s Motion on Patent Eligibility

The court evaluated Motive’s motion under Rule 50(b), finding that the jury’s findings about whether the claims were well-understood, routine, and conventional were not merely advisory. Under that rule, the court was required to uphold the jury’s verdict if substantial evidence supported it.

For the ’628 Patent, the court reaffirmed its earlier conclusion that the asserted claims were directed to the abstract idea of receiving, associating, and presenting data in fleet management. The claims used generic computer components and described their functions in general terms without specifying a technical improvement. The court rejected Omnitracs’s argument that the claims’ two-device hardware arrangement and claimed benefits made them patent-eligible.

At the second step of the eligibility analysis, known as the Alice test, the court asks whether the claims contain an inventive concept. The court found substantial evidence supporting the jury’s conclusion that the two-device arrangement and the transmission of data at predetermined times were well-understood, routine, and conventional. The evidence included the Turnpike system, the ’568 Patent, Department of Transportation regulations, and trial testimony. The court therefore ruled that the asserted claims of the ’628 Patent failed the second step of the eligibility test.

The court reached the same result for the ’906 Patent. It held that the asserted claims were directed to the abstract idea of receiving, analyzing, and displaying fleet-management information. Generic servers, computers, processors, displays, and memory did not change that conclusion. The court also found that composite driver scores, the two-device configuration, transmitting data at predetermined times, and remotely updating software did not supply an inventive concept because substantial evidence showed those functions were conventional.

Omnitracs’s Motion on Infringement and Eligibility

The court denied Omnitracs’s request for judgment as a matter of law that Motive infringed the ’628 Patent. Substantial evidence supported the jury’s finding that Motive’s products did not send the required “driver summary electronic report.” The evidence supported a finding that the products sent individual data points used to create the report, while generating the report locally in the driver application and fleet dashboard.

The court also denied Omnitracs’s request concerning the ’060 Patent. The asserted claims required wireless communication using HTTP between a web server in the vehicle event recorder and a remotely located computing device. The evidence supported a finding that the vehicle gateway used HTTP as a web client, not as the required web server, and used MQTT for server functions.

The court denied Omnitracs’s request concerning the ’253 Patent. The asserted claims required values for individual video frames to decrease as the frames became farther from the relevant vehicle event. The evidence showed that Motive’s system assigned confidence values based on the likelihood that its vision model detected an object, rather than on time or distance from the vehicle event. The court found sufficient evidence that the system did not determine values on the basis required by the claims.

The court also denied Omnitracs’s motion concerning patent eligibility for the same reasons it granted Motive’s motion.

Omnitracs’s Motion for a New Trial

The court denied Omnitracs’s request for a new trial. It found that Motive’s questioning about the use of the “Frank Williams” alias and Khan’s Muslim identity was not improper or prejudicial because Omnitracs had raised the subject during its questioning and Motive had a good-faith basis for its question. The court also found that any confusion about who had provided certain testimony was corrected during questioning.

The court found that Makani violated the court’s order in limine by referring to Motive’s legal team, but concluded that the testimony was promptly struck, the jury was instructed to disregard it, and Makani was significantly sanctioned. The court also rejected Omnitracs’s objections to questioning about a letter, noting that the objection was not made during trial and was therefore waived.

The court upheld its decision to use a two-part, bifurcated verdict form because the case involved four patents, ten claims, multiple theories, willful-infringement issues, and damages calculations. It found no sufficient prejudice from the court’s explanation of the verdict form, Motive’s closing argument, or the planned jury-release time. The court also rejected Omnitracs’s other challenges to arguments and testimony, including disputes about driver information, the ’253 Patent’s preamble, Turnpike source code, source-code review, and evidence concerning theft or misappropriation.

Finally, the court held that the jury’s non-infringement verdicts for the ’628, ’060, and ’253 Patents were supported by substantial evidence and were not against the weight of the evidence. It also held that the ’906 Patent non-infringement verdict was not contrary to the clear weight of the evidence, including because the jury could reasonably treat distance driven as a factor in calculating the DRIVE score.

Disposition

The court granted Motive’s renewed motion for judgment as a matter of law on eligibility of the asserted claims of the ’628 and ’906 Patents. The court denied Omnitracs’s renewed motion for judgment as a matter of law concerning infringement, patent eligibility, and the jury’s findings about well-understood, routine, and conventional activity. The court also denied Omnitracs’s motion for a new trial.