Tesla Inc v. Granite Vehicle Ventures LLC

1. Case Identification

• Case #: IPR2025-01034
• Patent #: 12,037,004
• Petitioner(s): Tesla, Inc.
• Patent Owner(s): Granite Vehicle Ventures LLC
• Challenged Claims: 1-9, 29-39

2. Patent Overview

• Title: Fault Handling in a Self-Driving Vehicle
• Brief Description: The ’004 patent relates to a computer program product for controlling a self-driving vehicle (SDV) by managing fault handling. The system determines competence levels for both the human driver and the SDV, compares these levels to various thresholds to identify faults, and executes corrective actions from a fault-remediation table based on the identified faults.

3. Grounds for Unpatentability

Ground 1: Obviousness over Core SDV References - Claim 1 is obvious over Hampiholi, Attard, McNew, and Frazer.

• Prior Art Relied Upon: Hampiholi (Application # 2016/0267335), Attard (Patent 9,406,177), McNew (Patent 10,377,303), and Frazer (Patent 9,494,926).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the combination of Hampiholi and Attard taught a foundational SDV capable of determining competence levels for both the human driver and the vehicle itself. Hampiholi taught determining a driver's competence level (a "severity rank R") based on sensor readings (e.g., cameras monitoring distraction). Attard taught determining an SDV's competence level (a scalar value "Φ") based on its own sensor data to assess its ability to operate autonomously. The combined system would compare the driver's competence level to thresholds to determine if a first or second fault occurred, as disclosed in Hampiholi's tiered response system. McNew was added for its teaching of a steering wheel grip sensor, which Petitioner asserted would have been an obvious addition to improve the accuracy of Hampiholi's driver monitoring.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Hampiholi and Attard to create a more robust safety system that monitors both driver state and vehicle capability, which are complementary aspects of overall vehicle safety. McNew’s sensor would be added to provide more data points for this safety assessment. A POSITA would have been motivated to incorporate Frazer's fault-remediation table to organize the various faults and corrective actions taught by the primary references, improving the system's efficiency and responsiveness in a predictable way. Attard itself suggested transferring driver controls to manual, which motivated the inclusion of McNew's teachings on managing such a transition.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success because combining sensor-based monitoring systems and organizing responses in a lookup table were well-known techniques in vehicle automation.

Ground 2: Obviousness over Weighted Voting References - Claims 2-5 are obvious over Hampiholi, Attard, McNew, Frazer, DeRuyck, Gunderson, An, Kang, and Schunder.

• Prior Art Relied Upon: The combination from Ground 1, plus DeRuyck (Patent 9,714,037), Gunderson (Application # 2007/0268158), An (Patent 9,063,543), Kang (Patent 9,688,145), and Schunder (Patent 9,451,030).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the combination in Ground 1 to add the "weighted voting system" required by claim 2. Petitioner asserted that DeRuyck taught using a weighted voting system to determine a driver's competence level by analyzing various weighted data sources. This was argued to be an obvious modification to Hampiholi's competence assessment. For limitations requiring weights based on "active learning data," Gunderson was introduced for its teaching of assigning relative weights to driver risk factors based on their prevalence in a group of drivers. An was cited as an alternative to Attard for teaching a weighted system for SDV competence.
  • Motivation to Combine: A POSITA would combine DeRuyck with the base combination to enable a more nuanced and accurate determination of driver competence than a simple threshold system, improving overall safety. Gunderson would be added to refine these weights based on real-world data from a cohort of other drivers, a known technique for improving system accuracy. To meet limitations regarding weights based on road conditions, Kang (weighting based on weather type) and Schunder (receiving weather data from other vehicles on the same roadway) were added to improve the SDV's situational awareness and safety.
  • Expectation of Success: A POSITA would have expected success as integrating weighted inputs is a standard method for improving decision-making algorithms in complex systems like SDVs.

Ground 3: Obviousness of Independent Claim 29 - Claim 29 is obvious over Hampiholi, Attard, McNew, Frazer, and Hada.

• Prior Art Relied Upon: The combination from Ground 1, plus Hada (Patent 8,305,444).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground challenged independent claim 29, which recited similar fault-handling logic to claim 1 but included specific limitations for displaying sensor readings on a screen. The base combination of Hampiholi, Attard, McNew, and Frazer was asserted to teach the core elements of receiving sensor inputs (including driver-facing cameras and steering wheel sensors), determining competence levels, and using a fault table for corrective actions. Hada was added to explicitly teach the limitation of "displaying, on a display screen, one or more sensor readings," such as the position of nearby vehicles and lane markings.
  • Motivation to Combine: Petitioner argued a POSITA would be motivated to add Hada's display functionality to the base SDV system to improve vehicle safety by providing the driver with critical sensor information. Displaying such data was a known method for enhancing driver awareness, particularly in vehicles with semi-autonomous features that still required driver supervision.
  • Expectation of Success: The combination was expected to succeed because integrating a data display with an existing sensor and processing system was a straightforward task for a POSITA.

• Additional Grounds: Petitioner asserted numerous other obviousness challenges. Ground 3 added Sako for transferring to manual control when exiting a highway. Ground 4 added Coelingh for using data from other vehicles to diagnose sensor anomalies. Ground 7 added Tsimhoni-647 for graphically displaying the SDV's competence level. Other grounds involved further permutations of these references to meet the limitations of various dependent claims.

4. Relief Requested

• Petitioner requests institution of inter partes review and cancellation of claims 1-9 and 29-39 of the ’004 patent as unpatentable.