PTAB

IPR2026-00227

Tesla Inc v. United States Patent Trademark Office

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Vehicle Gear Selection Control
  • Brief Description: The ’230 patent relates to operational control systems for motor vehicles. The technology enables a vehicle's controller to automatically select a driving direction, such as auto-shifting from reverse to drive, in response to a detected pattern of steering angle movements without requiring a separate, explicit direction indication from the operator.

3. Grounds for Unpatentability

Ground 1A: Obviousness over Joos - Claims 1-4, 13, 15, 17 are obvious over Joos.

  • Prior Art Relied Upon: Joos (Application # 2019/0233009).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Joos, which describes a semi-autonomous vehicle "unparking" method, discloses all limitations of the challenged independent claims. Joos’s system maneuvers a vehicle along a predefined trajectory, which includes reversing out of a parking space and then automatically shifting to a forward gear upon reaching a target end position. Petitioner contended that this auto-shift is triggered in response to a specific pattern of steering angle movements—namely, steering in a first direction while reversing and then steering in the opposite direction to set the angle for forward movement. This entire sequence, culminating in an automatic gear change, was alleged to meet the core limitation of claim 1, as it occurs without a separate operator command to change direction.
    • Key Aspects: Petitioner asserted that a person of ordinary skill in the art (POSITA) would have found it obvious to condition the auto-shift on the successful completion of the steering pattern, as this represents a logical, safe, and predictable implementation of the described unparking maneuver.

Ground 1B: Obviousness over Joos in view of Kischkat - Claims 5, 9-12, and 18 are obvious over Joos in view of Kischkat.

  • Prior Art Relied Upon: Joos (Application # 2019/0233009), Kischkat (European Patent No. EP2135788B1).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground augmented the teachings of Joos with Kischkat. Kischkat discloses a park-assist system where an automated gear shift is not performed immediately but is first offered to the driver. The driver can then accept the offered shift via a simple, pre-existing input, such as pressing the brake pedal, using a voice command, or activating a steering wheel button. Petitioner argued that adding Kischkat’s "offer and accept" functionality to Joos’s system renders obvious the dependent claims that require a controller to offer an auto-shift and then enact it only in response to a user acceptance action.
    • Motivation to Combine: A POSITA would combine Joos with Kischkat to provide drivers with a valuable intermediate option between fully automatic shifting and fully manual control. This approach improves safety by preventing unexpected vehicle movement and enhances user confidence by ensuring the driver confirms the intended change in direction before it occurs.
    • Expectation of Success: Petitioner argued there would be a high expectation of success. Both references address gear shifting in the context of parking/unparking maneuvers, and Kischkat explicitly states its techniques can be “easily” implemented, making the combination a straightforward application of known technologies to achieve a predictable result.

Ground 2A: Obviousness over Joos in view of Bettger - Claims 1-4, 13, 15, and 17 are obvious over Joos in view of Bettger.

  • Prior Art Relied Upon: Joos (Application # 2019/0233009), Bettger (Application # 2019/0161086).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground proposed modifying Joos’s system with Bettger’s method for driver confirmation of an assisted maneuver. Bettger teaches initiating an assisted reverse-turning maneuver only after the driver confirms their intent by performing a specific steering action, such as turning the steering wheel beyond a certain threshold angle that corresponds to the necessary maneuver. Petitioner argued that applying this confirmation mechanism to Joos’s system would make the entire unparking process, including the final auto-shift, responsive to an initial, driver-initiated steering input pattern.
    • Motivation to Combine: A POSITA would combine these references to enhance safety by preventing the unintentional activation of an autonomous maneuver. Using a natural steering input as the confirmation signal, as taught by Bettger, is more intuitive and convenient for a driver than using separate buttons or controls, especially while focused on reversing the vehicle.
    • Expectation of Success: Petitioner asserted that success would be reasonably expected, as both Joos and Bettger describe driver-assistance systems for similar reverse-turning contexts. Integrating Bettger's confirmation step into Joos's system would be a predictable modification to improve an existing system.
  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Allexi (to add velocity limits to the maneuver), Matters (to add maximum distance limits), and Bayer (to add haptic feedback and steering guidance), but relied on similar motivations of enhancing the safety, control, and predictability of the automated system.

4. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-18 of Patent 11,932,230 as unpatentable.