[February 15, 2024]

Motive Files Lawsuit Against Samsara to Protect Innovation and Fair Competition

Motive Technologies, Inc. ("Motive"), the only AI-powered Integrated Operations Platform for the physical economy, today filed a lawsuit against Samsara Inc. ("Samsara") (NYSE: IOT) to protect innovation and fair competition for the benefit and safety of customers.

Today's lawsuit filed in the United States District Court for the Northern District of California alleges that for years, Samsara has engaged in unlawful, anticompetitive business practices to copy Motive's products and technology and to steal its intellectual property. Despite its efforts, Samsara has failed to develop competitive AI technology and has been losing customers, particularly large Enterprise accounts, to Motive. Rather than develop better products, Samsara has resorted to waging a meritless legal battle and associated marketing campaign against Motive in an underhanded attempt to limit competition and stifle innovation.

With today's filing, Motive seeks to set the record straight and put an end to Samsara's unlawful and anticompetitive behavior. Motive's allegations against Samsara include patent infringement, theft of intellectual property and trade secrets, fraud, false and deceptive advertising, defamation, and intentional interference with prospective economic relations.

Motive Pioneered Products and Technology that Power Fleet Operations - Samsara Followed

• Motive pioneered the first iPhone- and Android-based fleet management and electronic logging platform in 2013 and manufactured its first Vehicle Gateway (LBB-1) in August 2015. Samsara was founded in July 2015 and released its copycat Vehicle Gateway (VG32) in April of the following year.
• Motive certified its Electronic Logging Device (ELD) with the U.S. Department of Transportation's Federal Motor Carrier Safety Administration (FMCSA) in July 2016, a full year before Samsara certified its own ELD with the FMCSA, with a Driver App that was a copy of Motive's.
• In 2019, Motive spent considerable time and resources developing its AI Dashcam with an Ambarella chip in collaboration with QSMC, a leading electronics manufacturer. Motive's filing claims that starting in late 2019, Samsara poached Motive's Vice President of Hardware Engineering and other engineering leaders to steal trade secrets and IP related to Motive's AI Dashcam. Samsara is in the process of launching its next-generation AI DashCam, manufactured by QSMC, using an Ambarella chip - seeming to directly copy Motive's hardware design and supplier relationship.

Motive alleges that beginning in 2016, Samsara's leadership, including Chief Product Officer Kiren Sekar and senior product and design executives, used Motive's product to copy specific features and AI capabilities that Motive spent years and millions of dollars developing. The complaint highlights that many of the Samsara employees who deceptively accessed Motive's platform were subsequently named as inventors on Samsara patents. It further alleges these users opened over 30 fake customer accounts, in at least one instance using an official identification number issued by the Department of Transportation for legitimate commercial carriers, an act that violates federal fraud and identity theft statutes.

Furthermore, Samsara poached key engineering leaders from Motive in a targeted effort to steal trade secrets and intellectual property, as well as senior sales executives in order to steal customers and other confidential information according to Motive's complaint.

Motive Alleges That Samsara Falsely Advertises its AI Capabilities, Harming Customers and Making Roads Less Safe

Samsara introduced its AI Dash Cam in February 2019, claiming it used AI to detect tailgating, cell phone use, and driver distraction to "prevent accidents before they happen." For the benefit and safety of Motive's customers and the industries it serves, Motive commissioned independent third-party benchmarking studies by the Virginia Technology Transportation Institute and Strategy Analytics, both of which prove that Samsara's AI does not work as advertised. This is the same AI Dash Cam Samsara sells today; nonetheless, Motive alleges Samsara sales representatives continue to use false and deceptive advertising to unjustly win new customers. Motive released its AI Dashcam in 2021 only once its AI models could accurately detect unsafe driving behavior, as confirmed by the third-party studies.

It is clear that Samsara would prefer to compete in court rather than in the marketplace. With today's lawsuit, Motive is seeking damages for patent infringement, the return of profits gained as a result of Samsara's false advertising claims about the Samsara AI Dash Cam, as well as injunctive relief to protect its legitimate business interests, including its confidential, proprietary, and trade secret information. Motive demands a jury trial for all claims mentioned in its lawsuit as triable by law.

For more information and updates, please visit www.truthandsafety.com.

About Motive

Motive empowers the people who run physical operations with tools to make their work safer, more productive, and more profitable. For the first time ever, safety, operations and finance teams can manage their drivers, vehicles, equipment, and fleet related spend in a single system. Motive serves more than 120,000 customers - from Fortune 500 enterprises to small businesses - across a wide range of industries, including transportation and logistics, construction, energy, field service, manufacturing, agriculture, food and beverage, retail, and the public sector. Visit gomotive.com to learn more.

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