PTAB

IPR2026-00204

Tesla Inc v. United States Patent Trademark Office

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: VEHICLE GEAR SELECTION CONTROL
  • Brief Description: The ’184 patent relates to a system for vehicle operational control, specifically a method to automatically change a vehicle's drive system between drive and reverse modes based on steering control inputs during low-speed maneuvers like unparking.

3. Grounds for Unpatentability

Ground 1: Claims 1-3, 6-9, 11, 13-15, and 18-23 are obvious over Joos.

  • Prior Art Relied Upon: Joos (Application # 2019/0233009).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Joos discloses a semi-autonomous method for unparking a vehicle that meets all limitations of the challenged claims. Joos’s driver assistance system monitors steering control via a steering angle sensor to guide the vehicle along a reversing trajectory to a calculated end position. Upon reaching this end position, the system automatically shifts from reverse to drive mode. Petitioner contended that this gear change is necessarily "based on the steering control" because it is conditioned on the vehicle successfully reaching the end position, which is achieved by following a path defined by steering movements. Joos also discloses setting a new, pull-forward steering angle at the end position before the auto-shift, which Petitioner argued constitutes a "pattern" or "sequence" of steering movements as required by dependent claims.
    • Motivation to Combine: Not applicable for this single-reference ground. Petitioner asserted that conditioning the auto-shift on the pull-forward steering angle being set would have been an obvious modification to enhance safety and provide a more intuitive experience, representing a simple choice among a finite number of predictable solutions.
    • Expectation of Success: A POSITA would have reasonably expected success because implementing the change would involve integrating capabilities already configured in the Joos system, such as setting a steering angle and auto-shifting gears.

Ground 2: Claims 4, 10, 12, 16, 22, and 24 are obvious over Joos in view of Kischkat.

  • Prior Art Relied Upon: Joos (Application # 2019/0233009) and Kischkat (European Patent No. EP2135788B1).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claims requiring driver input, such as brake pedal actuation, to confirm the mode change. Joos provided the foundational unparking system that automatically shifts gears. Kischkat taught a park-assist system where an automated gear shift is offered to the driver, who can then confirm it via various inputs, including tapping the brake or accelerator pedal. The combination of Joos's automatic gear change with Kischkat's driver confirmation method was alleged to render claims requiring actuation of a brake control obvious.
    • Motivation to Combine: A POSITA would combine these references to improve the user experience and safety of the Joos system. Joos presented only two options: fully automatic or fully manual shifting. Kischkat’s "offer and confirm" approach provided a desirable middle ground, giving the driver final control over the gear shift without the burden of using a traditional selector. This would provide drivers with more control and prevent surprise from an unexpected change in direction.
    • Expectation of Success: Petitioner argued for a high expectation of success, as both references describe driver assistance systems for parking maneuvers, and integrating a confirmation step is a straightforward modification of known systems to achieve the predictable result of enhanced user control.

Ground 3: Claims 1-3, 6-9, 11, 13-15, and 18-23 are obvious over Joos in view of Bettger.

  • Prior Art Relied Upon: Joos (Application # 2019/0233009) and Bettger (Application # 2019/0161086).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground argued that it would have been obvious to modify the Joos system to require a specific steering input from the driver to initiate the assisted unparking maneuver. While Joos taught the maneuver itself, Bettger taught requiring driver confirmation for a reverse-turning maneuver by "carrying out a certain steering movement" that exceeds a threshold. In the combined system, the controller would monitor the steering control for this confirmatory input before starting the maneuver, and the subsequent auto-shift at the end of the maneuver would therefore be responsive to this initial steering control input.
    • Motivation to Combine: The primary motivation was to promote safety and improve the user experience by preventing the "unintentional performance of a reverse-turning maneuver," as described in Bettger. This approach allows the driver to retain control over initiating the automated process, using a natural and convenient confirmation mechanism (steering) rather than another control.
    • Expectation of Success: A POSITA would have reasonably expected success because both Joos and Bettger describe driver assistance systems for similar reverse-turning contexts. Implementing Bettger's confirmatory logic into Joos’s existing system would be a predictable software adaptation.
  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges based on further combinations of prior art. These included adding Hoop (one-pedal driving functionality where releasing the accelerator slows the vehicle), Allexi (using a speed limiter during parking maneuvers), and Bayer (providing haptic steering torque feedback to guide the driver) to the primary Joos-based combinations to meet the limitations of other dependent claims.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-24 of the ’184 patent as unpatentable.