PTAB

IPR2026-00219

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 ’104 patent describes an operational control system for motor vehicles that automates gear direction changes. The system proposes a change in drive direction (e.g., from reverse to drive) based on steering input during low-speed maneuvers like unparking and executes the change after receiving a simple approval indication from the driver, such as a tap on the brake pedal.

3. Grounds for Unpatentability

Ground 1: Obviousness over Joos, Bayer, and Kischkat - Claims 1, 2, 4-6, 8-12, 14-16, 18-20 are obvious over Joos in view of Bayer and Kischkat.

  • Prior Art Relied Upon: Joos (Application # 2019/0233009), Bayer (Application # 2007/0282502), and Kischkat (European Patent No. EP2135788B1).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Joos taught a semi-autonomous unparking system that maneuvers a vehicle in reverse along a trajectory and then automatically shifts to a forward gear. The combination with Bayer, which taught a driver steering assistance system using haptic feedback to guide a driver along a parking trajectory, would render obvious a system where the driver remains engaged and provides steering input during the maneuver. The further combination with Kischkat, which taught offering a gear change and waiting for driver confirmation (e.g., a brake tap or voice command), would render obvious the claimed steps of offering the drive direction change based on the steering input and then executing it upon receiving a simple driver approval indication.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Joos and Bayer to improve the safety and reliability of the semi-autonomous unparking maneuver by ensuring the driver remains actively engaged, a known issue with fully autonomous systems. A POSITA would further add Kischkat’s "offer and confirm" feature to provide a more intuitive and safer user experience than Joos's options of either a fully automatic shift or a fully manual one, thereby giving the driver final control without the burden of using a traditional gear selector.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because all three references described well-known driver-assistance technologies for the same purpose of parking or unparking. Integrating Bayer’s haptic guidance and Kischkat’s confirmation logic into Joos’s system would be a straightforward application of known techniques to achieve predictable results.

Ground 2: Obviousness over Joos, Bayer, Kischkat, and Hoop - Claims 3 and 13 are obvious over the combination of Ground 1 in view of Hoop.

  • Prior Art Relied Upon: Joos (Application # 2019/0233009), Bayer (Application # 2007/0282502), Kischkat (European Patent No. EP2135788B1), and Hoop (Application # 2021/0122387).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1 to address the limitations of claims 3 and 13, which required an accelerator pedal operable to slow the vehicle upon release (one-pedal driving) and an approval indication that involved the driver's foot shifting from the accelerator to tap the brake. Petitioner asserted that Hoop explicitly taught a one-pedal driving system where releasing the accelerator initiated regenerative braking.
    • Motivation to Combine: A POSITA would combine Hoop’s teachings with the base combination to add the known benefits of one-pedal driving, such as increased convenience, enhanced driver experience, and improved energy efficiency through regenerative braking, particularly for the electric or hybrid vehicles to which these assistance systems are commonly applied.
    • Expectation of Success: Success would be expected, as one-pedal driving was a common and well-understood feature in electric vehicles before the patent’s critical date, and its integration into a driver-assistance system would have been within the capabilities of a POSITA.

Ground 3: Obviousness over Joos, Bettger, and Kischkat - Claims 1, 2, 4-6, 8-12, 14-16, 18-20 are obvious over Joos in view of Bettger and Kischkat.

  • Prior Art Relied Upon: Joos (Application # 2019/0233009), Bettger (Application # 2019/0161086), and Kischkat (European Patent No. EP2135788B1).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground presented an alternative to Ground 1 by replacing Bayer with Bettger. Bettger taught a system where a driver initiated an assisted reverse-turning maneuver by providing a confirmatory steering input (i.e., turning the wheel beyond a certain threshold). Petitioner argued this initial steering input would satisfy the "steering input" limitation upon which the subsequent offer to change drive direction is based. The remainder of the maneuver would follow Joos’s trajectory, culminating in an offer to shift gears that is confirmed by the driver per Kischkat.
    • Motivation to Combine: A POSITA would combine Bettger with Joos and Kischkat to enhance safety by requiring explicit driver confirmation via a natural steering motion before initiating any automated maneuver, preventing unintentional activation. This method provided a more intuitive confirmation than using separate buttons or controls.
    • Expectation of Success: A POSITA would expect success in this combination because Joos and Bettger both described driver assistance systems for reverse-turning maneuvers. Implementing Bettger’s steering-based confirmation as an initiating step for Joos’s automated process was a logical and straightforward design choice.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on adding Hoop or Allexi (Patent 10,077,073) to the Joos-Bettger-Kischkat combination, and adding Allexi to the Joos-Bayer-Kischkat combination, to address limitations related to one-pedal driving, velocity thresholds, and distance traveled.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’104 patent as unpatentable under 35 U.S.C. §103.