Motorola, which has been losing market share to Canada's RIM for years, said most of RIM's products infringe on at least one of the patents, which cover technology for Wi-Fi, application management, user interface and power management. A representative for RIM declined comment.
The complaint stems from the rivals' failure to reach an agreement to renew a technology cross-licensing pact that allowed them to use each others' technology, according to Motorola. The previous pact expired in December 2007.
The companies have been in litigation in a Texas court since February 2008 due to their failure to reach a deal.
Asked about the timing for the complaint with the U.S. International Trade Commission, Jonathan Meyer, Motorola's senior vice president of intellectual property law, said the company had been considering the move for some time.
The parties are very far apart in discussions of a resolution, Meyer said.
It is a common practice for technology companies to engage in prolonged legal battles in the hope of gaining the upper hand in negotiations for licensing agreements.
Motorola said it asked the ITC to start an investigation into RIM's use of Motorola patents, to prohibit the Canadian company from importing the infringing products and to stop it from selling infringing products that were already imported.
Meyer said the ITC typically considers complaints for a month before deciding whether to launch an investigation, which could take 12 to 14 months to complete.
Motorola shares closed down 16 cents or 2 percent at $7.21 on the Nasdaq. RIM's U.S. shares closed down 3 percent or $1.91 at $61.68.
(Reporting by Sinead Carew; Editing by Tim Dobbyn and Matthew Lewis)