PTAB

IPR2026-00205

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 ’457 patent discloses methods and systems for operating a motor vehicle where a drive system or controller monitors a steering control during a maneuver, such as unparking. Based on the steering control inputs, the system offers the driver a change between drive and reverse modes, and executes the change only upon receiving the driver's approval.

3. Grounds for Unpatentability

Ground 1: Obviousness over Joos and Kischkat - Claims 1-4, 6-15, and 17-22 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: Petitioner argued that Joos taught the foundational elements of a semi-autonomous unparking system, including monitoring steering control while reversing along a trajectory and automatically shifting from reverse to drive mode upon reaching a calculated end position. However, Joos did not explicitly teach offering this shift to the driver for confirmation. Petitioner asserted that Kischkat supplied these missing elements by disclosing a park-assist system that explicitly offers a gear change to the driver and executes the change only after receiving a simple confirmation, such as a voice command, pedal tap, or answering "yes" to a prompt.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to create a more user-friendly and safer system. Joos presented two options: a fully automatic shift lacking driver control, or a fully manual shift requiring driver action. Petitioner contended that Kischkat provided an obvious "middle ground" solution that improved upon Joos by retaining driver control (via confirmation) without the physical burden of operating a gear selector.
    • Expectation of Success: A POSITA would have a high expectation of success, as both references operated in the same technical field of vehicle maneuvering assistance and described the integration of known electronic control systems. Combining them was presented as a straightforward application of known techniques to achieve predictable results.

Ground 2: Obviousness over Joos, Kischkat, and Bettger - Claims 1-4, 6-15, and 17-22 are obvious over Joos and Kischkat in view of Bettger.

  • Prior Art Relied Upon: Joos, Kischkat, and Bettger (Application # 2019/0161086).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Joos and Kischkat combination by adding Bettger's teaching on how to initiate an assisted maneuver. Bettger disclosed a system where a driver confirms the start of an assisted reverse-turning maneuver by performing a specific steering movement, such as turning the wheel beyond a certain threshold angle. In this modified combination, the system monitors the steering control not just to guide the vehicle, but to first detect the driver's intent to initiate the unparking procedure. The subsequent offer to shift from reverse to drive (from Joos and Kischkat) would therefore be based on this entire driver-initiated steering sequence.
    • Motivation to Combine: A POSITA would be motivated to incorporate Bettger's teachings to enhance safety by preventing the unintentional activation of the semi-autonomous unparking feature. Requiring a deliberate steering input from the driver to begin the process ensured the driver was aware and in control, improving the overall user experience and preventing surprises.
    • Expectation of Success: Integrating a known method for initiating an automated maneuver (Bettger) into a system that performs such maneuvers (Joos/Kischkat) was argued to be a predictable and logical design choice for a POSITA.

Ground 3: Obviousness over Joos, Kischkat, and Bayer - Claims 1-4, 6-15, and 17-22 are obvious over Joos and Kischkat in view of Bayer.

  • Prior Art Relied Upon: Joos, Kischkat, and Bayer (Application # 2007/0282502).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground modified the primary combination by integrating Bayer's haptic steering assistance technology. Bayer taught using torque feedback applied to the steering wheel to guide a driver along a planned trajectory during a parking maneuver. Petitioner argued that in this combination, the system's "monitoring" of the steering control would be an active process. The system would provide haptic guidance to the driver to follow the unparking path, monitor the driver's compliance, and then offer the gear shift based on the driver successfully following the guided steering inputs.
    • Motivation to Combine: A POSITA would combine Bayer to improve the reliability and precision of the unparking maneuver taught by Joos. Actively guiding the driver's steering would increase the likelihood that the vehicle correctly followed the prescribed trajectory to its end position, thereby improving the safety and consistency of the subsequent automated gear shift while ensuring the driver remained engaged in the task.
    • Expectation of Success: Applying a known driver assistance technique like haptic feedback (Bayer) to a semi-autonomous unparking system (Joos/Kischkat) was asserted to be a well-understood method for improving system performance and safety.

  • Additional Grounds: Petitioner asserted additional obviousness challenges for specific dependent claims. These grounds relied on the primary combinations above in further view of Hoop (Application # 2021/0122387) for its teachings on one-pedal driving for claims related to accelerator pedals (5, 16), and Allexi (Patent 10,077,073) for its teachings on velocity and distance limiters for claims related to vehicle speed and distance traveled (7, 8, 18, 19).

4. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-22 of Patent 12,240,457 as unpatentable.