Federal Judge Denies Hytera’s Motion for Summary Judgment in Motorola TDMA Patent Dispute

U.S. District Judge Franklin U. Valderrama on Thursday rejected Hytera’s argument that its i-Series and H-Series products do not infringe Motorola’s U.S. Patent No. 8,116,284, finding that Motorola’s expert witness created sufficient factual questions for a jury to decide.

The ‘284 Patent covers a method and system for temporarily selecting a time division multiple access timeslot by a radio communication device to communicate with a talkgroup of other devices through a repeater station. Motorola alleges Hytera infringes the patent both literally and under the doctrine of equivalents.

Hytera argued that its devices do not meet the “assigned default timeslot” limitation because they prioritize the most recently used timeslot over a fixed default slot. The company also contended its products do not perform the “re-selecting” limitation required claims.

Valderrama noted that while the parties agreed the Accused Products always use the last-used timeslot if available, they disputed whether the patent claims cover that process. The judge pointed to an expert report by Dr. Wicker, which described scenarios in Extended Pseudo Trunk Mode where the devices switch timeslots in a manner that could satisfy the patent’s requirements.

“The Court agrees with Motorola that a reasonable jury could find, at least in some circumstances, that the Accused Devices literally infringe the “default timeslot” limitation of the ‘284 Patent,” Valderrama wrote.

Hytera also relied on a prior ruling by the U.S. International Trade Commission finding its i-Series devices did not infringe the patent. Valderrama acknowledged the ITC ruling as persuasive but not binding, citing Federal Circuit precedent that Congress did not intend ITC decisions on patent issues to have preclusive effect.

The judge also denied Hytera’s motion regarding the doctrine of equivalents, finding that Dr. Wicker’s testimony created a dispute over whether the Accused Devices perform substantially the same function, way, and result as the patented invention.

Hytera has filed five additional motions for summary judgment on non-infringement and one motion regarding lost profit or price erosion damages, which the court will address in separate orders.

Valderrama, a George W. Bush appointee, issued the redacted memorandum opinion on May 14, 2026, following a claim construction order issued in April that adopted Motorola’s proposed constructions for disputed terms. The underlying opinion was signed on March 30, 2026.