PTAB

IPR2026-00229

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 ’458 patent discloses operational control systems for motor vehicles. The core technology involves a drive system or controller that automatically selects a drive direction (e.g., shifting from reverse to drive) in response to steering angle movements, without requiring the operator to manually indicate a direction via a gear selector.

3. Grounds for Unpatentability

Ground 1A: Claims 1, 6, 11, and 16 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 unparking system, discloses all limitations of the independent claims. Joos teaches a vehicle reversing along a trajectory and then, at a determined end position, the system steering the wheels to a predefined angle to prepare for forward movement. The system then automatically shifts from reverse to a forward gear. Petitioner contended this sequence—steering in a first direction while reversing, followed by steering in an opposite direction at the maneuver's end point to set a pull-forward angle, which culminates in an automatic gear shift—meets the limitation of selecting a drive direction "in response to steering angle movements, without operator indication of a direction."
    • Motivation to Combine (for §103 grounds): As a single-reference ground, the motivation focused on the rationale for specific implementation choices. Petitioner argued a POSITA would find it obvious to condition the auto-shift on the completion of the steering movements to ensure safety and provide an intuitive experience, as setting the pull-forward angle before shifting to drive is a logical and predictable sequence.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success because implementing the auto-shift to occur after the steering angle is set involves applying known control system principles to capabilities already present in the Joos system.

Ground 1B: Claims 2, 4-5, 7-10, 12, 14-15, and 17-20 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 built upon Joos to address dependent claims requiring an "approval indication" from a driver to confirm the change in drive direction. Petitioner mapped Joos's base unparking system and asserted that Kischkat supplied the missing elements. Kischkat explicitly taught a park-assist system where an automated gear shift is offered to the driver, who can then confirm it by actuating the accelerator or brake pedal. This combination allegedly rendered obvious claims reciting driver approval via brake control (claims 2, 12), offering a direction change only below a velocity threshold (claims 5, 15), and changing direction without driver operation of a selector (claims 9, 19).
    • Motivation to Combine (for §103 grounds): Petitioner argued a POSITA would combine these references to provide a desirable intermediate option for drivers. While Joos presented a binary choice between fully automatic or fully manual gear shifting, Kischkat's confirmation step offered a hybrid approach that enhances safety and driver control without the burden of using the traditional gear selector. This would provide a more user-friendly and confidence-inspiring system.
    • Expectation of Success (for §103 grounds): Success was expected because both references operate in the same field of assisted parking/unparking. Kischkat stated its techniques could be "easily" implemented in vehicles with a standard data bus (e.g., CAN bus), making the integration with a system like Joos a straightforward modification for a POSITA.

Ground 2A: Claims 1, 6, 11, and 16 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 presented an alternative obviousness argument for the independent claims. Petitioner argued that while Joos provided the foundational unparking maneuver and auto-shift, Bettger taught using a driver's steering input as a confirmation to initiate an assisted reverse-turning maneuver. In the proposed combination, the entire automated sequence described in Joos (culminating in the auto-shift) would be triggered only after the driver provides a confirmation by making a steering movement that exceeds a certain threshold, as taught by Bettger.
    • Motivation to Combine (for §103 grounds): A POSITA would be motivated to combine Joos and Bettger to improve safety and the user experience. By requiring a specific steering input to initiate the maneuver, the system would prevent unintentional activation of the automated feature. This provides a natural and convenient confirmation mechanism that enhances driver control over when the assistance is engaged.
    • Expectation of Success (for §103 grounds): A POSITA would expect success because both references describe driver assistance systems for reverse-turning maneuvers. Since Joos's vehicle already included the necessary driver assistance system and steering controls, it would be well-suited to implement Bettger's confirmation technique.

  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges, primarily based on combinations of Joos with other references. These included using Hoop to add one-pedal driving functionality, Allexi to add a velocity limiter during the maneuver, and Bayer to incorporate haptic steering feedback to guide the driver. Each combination was argued to be a predictable modification to improve safety, convenience, or driver experience.

4. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-20 of the ’458 patent as unpatentable.