PTAB

IPR2026-00228

Tesla Inc v. United States Patent Trademark Office

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petition

1. Case Identification

2. Patent Overview

  • Title: VEHICLE GEAR SELECTION CONTROL
  • Brief Description: The ’456 patent describes an operational control system for motor vehicles. The system is operable to automatically select a drive direction (e.g., forward or reverse) in response to detecting a specific pattern of steering angle movements, thereby eliminating the need for the driver to provide a manual indication of direction via a traditional gear selector.

3. Grounds for Unpatentability

Ground 1: Claims 1 and 6 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 discloses a semi-autonomous unparking system, renders claims 1 and 6 obvious under 35 U.S.C. §103. Joos describes a vehicle that maneuvers in reverse along a calculated trajectory to an end position, at which point the system automatically shifts from reverse to a forward gear. Petitioner contended that this unparking maneuver inherently constitutes a "pattern of steering angle movements" as required by claim 1. Specifically, the vehicle first steers in one direction while reversing out of the parking space and then steers in the opposite direction at the end position to align for forward travel. The drive system in Joos selects the forward direction by auto-shifting only after this pattern is completed, without any separate direction indication from the operator.
    • Motivation to Combine: Not applicable for this single-reference ground.
    • Expectation of Success: Not applicable for this single-reference ground.

Ground 2: Claims 2, 4-5, and 7-10 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 builds on Joos by adding Kischkat's teachings for dependent claims requiring a driver "approval indication." While Joos teaches a fully automatic gear shift, Kischkat discloses a driver assistance system that offers an automated gear shift and allows the driver to confirm it using an input other than a gear selector, such as tapping the brake or accelerator pedal (as required by claims 2 and 10). Kischkat's system provides an intermediate solution between Joos's fully automatic and fully manual shifting options. The combination also allegedly discloses offering a direction change based on thresholds for steering angle (claim 4), vehicle velocity (claim 5), and distance traveled (claim 7).
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine Joos and Kischkat to enhance safety and improve the user experience. The combination provides a desirable middle-ground option where the system automates the gear selection but waits for a simple, intuitive confirmation from the driver. This gives the driver final control and prevents unexpected vehicle movements, addressing potential safety concerns with fully automated systems.
    • Expectation of Success: A POSITA would have a high expectation of success because both references relate to parking assistance systems and Kischkat states its methods can be "easily implemented" on a vehicle's standard CAN bus.

Ground 3: Claims 1 and 6 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 presents an alternative basis for finding the independent claims obvious. Joos again provides the foundational semi-autonomous unparking system. Bettger teaches a system for an "assisted performance of a reverse-turning maneuver" where the driver confirms initiation of the maneuver by making a specific steering movement that exceeds a certain threshold angle. In the proposed combination, the automated unparking sequence of Joos would be initiated only after the driver provides the confirmatory steering input taught by Bettger. The subsequent auto-shift from reverse to drive would therefore occur "in response to a pattern of steering angle movements," which includes the initial confirmatory steering input.
    • Motivation to Combine: A POSITA would combine these references to create a more natural and convenient confirmation mechanism. Using the initial steering action itself as the trigger for the automated sequence, as taught by Bettger, avoids burdening the driver with separate controls and prevents unintentional activation of the feature. This improves both safety and the overall user experience.
    • Expectation of Success: Success would be reasonably expected, as both references describe driver assistance systems for similar reverse-turning maneuvers. Integrating Bettger's confirmation logic into Joos's system would be a predictable software adaptation for a POSITA.
  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges against various claims by adding the teachings of Hoop (disclosing one-pedal driving systems), Allexi (disclosing velocity limiters for parking maneuvers), and Bayer (disclosing haptic steering feedback and driver monitoring) to the core combinations of Joos, Kischkat, and Bettger.

4. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-10 of the ’456 patent as unpatentable.