PTAB

IPR2026-00222

Tesla Inc v. Bulletproof Property Management LLC

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Petition

1. Case Identification

2. Patent Overview

  • Title: Vehicle Gear Selection Control
  • Brief Description: The ’871 patent discloses operational control systems for motor vehicles. The invention centers on a system that automates gear selection, specifically changing from reverse to drive mode, in response to a detected sequence of steering and brake inputs without requiring a direct directional command from the operator, such as during an unparking maneuver.

3. Grounds for Unpatentability

Ground 1: Claims 1-6 and 8-13 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 independent claims. Joos described a vehicle controller that executes an unparking trajectory by reversing, steering in a first direction, braking to a stop at an end position, and then steering in an opposite direction to prepare for forward movement. Petitioner asserted this series of actions constitutes the claimed "sequence of detected steering and brake inputs." Joos's system then automatically engages the forward gear to complete the maneuver, meeting the limitation of changing drive mode "without operator indication of a direction." Dependent claims reciting specific steering and braking sequences were also alleged to be disclosed in the figures and description of Joos's unparking maneuver.

Ground 2: Claims 1-6 and 8-13 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 the system of Joos by incorporating the teachings of Bettger. Bettger taught using a specific driver steering input, such as turning the wheel past a certain threshold, as an explicit confirmation to initiate an assisted reverse-turning maneuver. In the combined system, the autonomous unparking sequence of Joos would not begin until the controller first detected this confirmatory steering input from the driver. The subsequent automatic shift from reverse to drive would therefore be responsive to a sequence of inputs that begins with the driver's confirmation.
    • Motivation to Combine: Petitioner contended a POSITA would combine Bettger with Joos to enhance safety and improve the user experience. Requiring a deliberate driver input to initiate the maneuver would prevent unintentional activation, giving the driver final control before ceding partial autonomy to the vehicle. This was argued to be a predictable solution to a known challenge in driver-assistance systems.
    • Expectation of Success: A POSITA would have an expectation of success because integrating a known driver confirmation method (Bettger) into a known autonomous maneuver system (Joos) involved applying established techniques in the field of vehicle control systems.

Ground 3: Claims 7 and 14 are obvious over Joos, Bettger, Kischkat, and Hoop

  • Prior Art Relied Upon: Joos (Application # 2019/0233009), Bettger (Application # 2019/0161086), Kischkat (European Patent No. EP2135788B1), and Hoop (Application # 2021/0122387).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground challenged claims 7 and 14, which specifically require "detecting releasing an accelerator pedal ... to slow the vehicle to a stop without driver application of force to the brake control." Petitioner argued for adding the teachings of Hoop to the system proposed in other grounds. Hoop disclosed "one-pedal driving" for electric or hybrid vehicles, where releasing the accelerator pedal engages regenerative braking to slow the vehicle. In the combined system, the driver would slow the vehicle to its end position during the unparking maneuver by releasing the accelerator, directly meeting the explicit limitation of these claims.
    • Motivation to Combine: A POSITA would combine Hoop's teachings to implement a well-known and desirable feature in modern electric vehicles. One-pedal driving enhances convenience, improves energy efficiency by maximizing regenerative braking, and reduces wear on conventional friction brakes. Applying this known technique to the vehicle system of Joos/Bettger/Kischkat was presented as a straightforward and beneficial modification.
    • Expectation of Success: A POSITA would reasonably expect success in this combination, as one-pedal driving and regenerative braking were common features in electric vehicles prior to the patent's critical date, and the underlying technologies were fully compatible with the assistance systems described in the other references.
  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 2B) for claims 1-6 and 8-13 based on Joos in view of Bettger and Kischkat. This combination added Kischkat's teaching of using a brake pedal tap as a driver's confirmation to accept a system-offered automated gear shift from reverse to drive.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-14 of the ’871 patent as unpatentable.