Motorola announced on Friday that it had filed a complaint with the U.S. International Trade Commission (ITC) alleging that Research In Motion Limited (RIM) has engaged in unfair trade practices by the importation and sale of RIM products that infringe on five of Motorola?s patents.

The five patents listed in Motorola?s complaint relate to certain early-stage innovations developed by Motorola in key technology areas, such as Wi-Fi access, application management, user interface and power management, that are now being used by RIM.

Motorola has requested that the ITC commence an investigation into RIM?s use of Motorola?s patents and, among other things, issue an Exclusion Order barring RIM?s importation of infringing products; prohibiting further sales of infringing products that have already been imported; and halting the marketing, advertising, demonstration and warehousing of inventory for distribution and use of such imported products in the United States.

Jonathan Meyer, senior vice president of intellectual property law at Motorola, said, "Through its early-stage development of the cellular industry and billions of dollars spent on research and development, Motorola has created an industry-leading intellectual property portfolio that is respected by the entire telecommunications industry. In light of RIM?s continued unlicensed use of Motorola?s patents, RIM?s use of delay tactics in our current patent litigation, and RIM?s refusal to design out Motorola?s proprietary technology, Motorola had no choice but to file a complaint with the ITC to halt RIM?s continued infringement. Motorola will continue to take all necessary steps to protect its R&D and intellectual property, which are critical to the Company?s business."

RIM declined to comment on Motorola?s filing with the ITC.