Samsara Inc. v. Motive Technologies Inc.

I. BACKGROUND

A. The Parties Plaintiff Samsara Inc. (Plaintiff? or “Samsara”) is a Delaware corporation with its principal place of business in San Francisco, California. (D.I. 23 § 11). Samsara is a technology company that offers hardware dashboard cameras for motor vehicles along with software applications that use artificial intelligence to critique behind-the-wheel driver behavior and improve driver safety. (Ud. 7, 37). Defendant Motive is also a Delaware corporation with its principal place of business in San Francisco, California. (/d. § 12). Like Samsara, Motive competes in the market for driver safety and fleet management technology. (/d. □□ 5, 8). According to the Amended Complaint, Motive engaged in a scheme to steal Samsara’s proprietary technology over the course of nearly five years, including by copying Samsara’s product designs, marketing strategies, and other patented technical elements of its business. (/d. JJ 1, 2, 9). Motive allegedly achieved this by, among other things, directing its employees to register for and digitally access Samsara’s products using customer accounts with fictitious…