PTAB

IPR2026-00204

Tesla Inc v. United States Patent Trademark Office

Log In
Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Vehicle Gear Selection Control
  • Brief Description: The ’184 patent describes methods for operating a motor vehicle where the drive system automatically changes between drive and reverse modes based on steering control inputs. The technology is primarily disclosed in the context of an "unparking" maneuver, where a vehicle shifts from reverse to drive after completing a series of steering movements to exit a parking space.

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 all limitations of the challenged claims. Joos describes a semi-autonomous method for unparking a vehicle from a cross-parking space. This method involves the vehicle maneuvering along a calculated trajectory, which includes reversing with specific steering inputs (e.g., steering right) to reach a final end position. Upon reaching this end position, the system automatically adjusts the steering for forward movement (e.g., steering left) and shifts the vehicle from reverse to drive. Petitioner contended that this gear change is "based on the steering control" because it is triggered by the vehicle successfully completing the steering-defined unparking trajectory.
    • Motivation to Combine (for §103 grounds): Not applicable, as this is a single-reference ground. Petitioner asserted it would have been obvious to a person of ordinary skill in the art (POSITA) to condition the automatic gear shift on the successful completion of the steering maneuvers taught by Joos to ensure safety and proper vehicle orientation before pulling forward.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success because implementing the auto-shift based on the completion of the steering pattern involved integrating capabilities already present in the Joos system.

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 built upon Joos by adding Kischkat's teachings to address claims requiring brake actuation or driver approval for a gear change. Kischkat describes a park-assist system where an automatic gear shift can be confirmed by the driver through various inputs, including actuating the brake pedal. For claims requiring a gear change "in response to actuation of the brake control" (claims 4, 16), Petitioner mapped this to Kischkat's disclosure of using the brake pedal to approve a shift. For claims requiring a shift "without driver indication of a direction other than approval" (claims 10, 22), Petitioner argued Kischkat's confirmation methods (like a simple "yes" or pedal tap) constitute approval without specifying a direction.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Joos and Kischkat to provide drivers with an intermediate option between fully automatic shifting and fully manual shifting. This combination would enhance safety and user control by allowing the driver to confirm the system's offered gear change, addressing potential user apprehension with fully autonomous actions.
    • Expectation of Success (for §103 grounds): Success was expected because both references describe driver-assistance systems for parking maneuvers, and integrating a known confirmation method (Kischkat) into an automated process (Joos) was a straightforward application of known techniques.

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 modified Joos with Bettger's teaching that a driver can confirm the initiation of an assisted reverse-turning maneuver via a specific steering input that corresponds to the required maneuver, such as turning the wheel beyond a certain threshold. In the combined system, the controller would monitor the steering control for this confirmatory input while the vehicle is in reverse. Upon detecting it, the system would initiate the automated unparking maneuver from Joos, which culminates in the auto-shift to drive. Therefore, the change in drive mode is responsive to the initial confirmatory steering control input.
    • Motivation to Combine (for §103 grounds): A POSITA would combine these references to improve safety and user experience. Bettger's steering-based confirmation provides a natural and intuitive way for a driver to initiate the assisted maneuver, preventing unintentional activation while avoiding the need for other, less convenient controls.
    • Expectation of Success (for §103 grounds): Success was reasonably expected as both references describe driver-assistance systems for reverse maneuvers, and implementing a steering-based confirmation mechanism was a predictable adaptation within the skill of a POSITA.

  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges based on combinations including Bayer (for haptic-feedback driver steering assistance), Allexi (for adding velocity limits to the unparking maneuver), and Hoop (for implementing one-pedal driving functionality). These grounds relied on similar motivations to add known, predictable features to improve the safety, convenience, and functionality of Joos's base system.

4. Relief Requested

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