Litigation
Untitled case
pendingIPR2026-00227
- Court
- PTAB
Patents at issue (1)
Summary
An Inter Partes Review (IPR) case, IPR2026-00227, is pending at the PTAB, as referenced in the Google Patents legal status section for patent 11932230.
Case overview & background
Plain-language overview of the case: parties, accused product, patents at issue, and why the suit matters.
This case involves an Inter Partes Review (IPR) proceeding, IPR2026-00227, currently pending at the Patent Trial and Appeal Board (PTAB), which is linked to a patent infringement lawsuit. The parties are Bulletproof Property Management LLC as the Patent Owner and Tesla, Inc. as the Petitioner. Bulletproof Property Management LLC appears to operate as a Patent Assertion Entity (PAE) or Non-Practicing Entity (NPE), holding a portfolio of patents, including those invented by Bennet Langlotz, who is also identified as a "gun patent attorney." Conversely, Tesla, Inc. is a prominent operating company known globally as an electric vehicle manufacturer.
The core of the dispute lies in an underlying patent infringement lawsuit, Bulletproof Property Management LLC v. Tesla Inc. (Case No. 1:25-cv-00665), filed in the U.S. District Court for the Western District of Texas. In this district court action, Bulletproof Property Management LLC alleges that Tesla's motor vehicles, specifically those equipped with the "Auto Shift" feature, infringe its patents. The primary patent at issue in IPR2026-00227 is U.S. Patent No. 11,932,230, titled "Vehicle gear selection control." This patent broadly claims a motor vehicle system where a controller selects a driving direction (forward or reverse) based on a pattern of steering angle movements, without direct operator input, and can automatically change between modes like reverse and drive.
The procedural posture includes the IPR at the PTAB, where Tesla is challenging the validity of patent 11,932,230. This IPR is a defensive measure in response to the ongoing infringement litigation in the Western District of Texas, presided over by Judge Alan D. Albright. The Western District of Texas has gained a reputation as a patent-owner friendly venue, often influencing where patent infringement cases are filed. This case is notable due to the targeting of a major automotive innovator, Tesla, Inc., by a suspected NPE over technology related to advanced vehicle control systems, specifically automated gear selection features. It highlights the continuing trend of NPE assertions in the high-tech and automotive sectors and the strategic use of PTAB proceedings to challenge patent validity in parallel with district court litigation.
Key legal developments & outcome
Major rulings, motions, claim construction, settlements, and the present posture or final disposition.
I'll research the litigation docket and parallel PTAB proceedings.
Key legal developments — Bulletproof Property Mgmt. LLC v. Tesla, Inc., No. 1:25-cv-00665-ADA (W.D. Tex.)
Threshold correction to the earlier sections. The prior "Plaintiff representatives" section flagged doubt about whether IPR2026-00227 corresponds to the '230 patent and speculated that IPR2026-00229 was the '230 proceeding. That is now resolved against the speculation: the Director's June 15, 2026 decision and Patent Owner's mandatory notices both expressly identify IPR2026-00227 as the petition on U.S. Patent No. 11,932,230, and IPR2026-00229 as the petition on U.S. Patent No. 12,240,458. (USPTO Director decision, IPR2026-00204 et al.; PO Mandatory Notices, IPR2026-00229)
1. Pre-suit notice and accusation (2024)
| Date | Event |
|---|---|
| 2024-03 (approx.) | Plaintiff/inventor Bennet Langlotz informs Tesla's counsel of the '230 patent; Tesla admits receipt of a letter "no later than April 5, 2024" (Answer ¶ 8, Dkt. 24). |
| 2024-04/05 | Tesla releases firmware 2024.14 containing the accused "Auto Shift" feature (Tesla admits release "in and around April 2024," Dkt. 24 at 3). |
| 2024-05 | Langlotz cease-and-desist correspondence per Plaintiff's own recitation (Dkt. 41 at 6). |
These facts drive the (now-dropped) willfulness/inducement theories and were the centerpiece of Patent Owner's "settled expectations"/delay argument at the PTAB.
2. Filing and initial pleadings (2025)
- 2025-05-05 — Complaint filed (Dkt. 1). Bulletproof Property Management LLC v. Tesla, Inc.; John Does 1–20, No. 1:25-cv-00665, W.D. Tex. (Austin Division), assigned to Judge Alan D. Albright. Asserted seven patents — the '230 patent plus six "Follow-On Patents" ('104, '184, '871, '456, '457, '458) — all covering Tesla's Auto Shift/auto gear-selection functionality in Model S/3/X/Y. (Justia docket; Complaint, Dkt. 1)
- 2025-05-06 — Summons issued; 2025-05-29 — case made subject to Judge Albright's Standing Order Governing Proceedings (OGP 4.3) – Patent Cases.
- 2025-05-30 — Tesla's agreed extension to respond (Dkt. 7).
- 2025-06-11 — appearances of Tesla counsel Krista Carter and Gina Cremona (Dkts. 8–9); 2025-05-30/06 David M. Hoffman appearance (Dkt. 6); Aamir A. Kazi (Dkt. 15, 2025-07-29).
- 2025-07-21 — Tesla's first Rule 12(b)(6) motion to dismiss (Dkt. 12) and sealed Opposed Motion to Transfer Venue to N.D. Cal. under 28 U.S.C. § 1404(a) (Dkt. 13; redacted copy Dkt. 14, 2025-07-28, with Nguyen and Rizkalla declarations).
- 2025-08-01 — Plaintiff's Notice of Venue/Jurisdictional Discovery (Dkt. 16), invoking OGP 4.3 ¶ V to open automatic venue discovery and to extend its response deadline to at least 2025-10-13.
- 2025-08-11 — Amended Complaint (Dkt. 18) — mooted the first dismissal motion.
- 2025-08-25 — Tesla's renewed 12(b)(6) motion (Dkt. 21), targeting indirect infringement and willfulness pleading.
- 2025-09-09 — Plaintiff's notice agreeing to dismiss without prejudice its indirect and willful infringement claims subject to Tesla's motion (Dkt. 22). Strategic significance: this mooted most of the Rule 12 motion and removed enhanced-damages exposure from the pleadings — a meaningful concession given the § 285/e-Discovery leverage Tesla's stipulation later created.
- 2025-09-30 — Tesla's Answer, Affirmative Defenses and Counterclaims (Dkt. 24) against Bulletproof. Tesla admits the core documentary facts (owner's-manual language, the March 12, 2025 @Tesla posts, the 2024.14 release) but denies infringement, denies any license is needed, and does not contest personal jurisdiction.
- 2025-10-01 — Text orders: Dkt. 12 denied as moot (amended complaint filed); Dkt. 7 granted.
- 2025-10-22 — Notice of agreed extension to complete venue discovery (Dkt. 25).
3. Parallel PTAB proceedings (2026) — the dominant driver
- 2026-01-23 — Tesla files seven IPR petitions, one per asserted patent: IPR2026-00204 ('184), -00205 ('457), -00219 ('104), -00222 ('871), -00227 ('230), -00228 ('456), -00229 ('458). Filing-date-accorded notices issued 2026-01-27. Tesla's IPR counsel is Fish & Richardson (W. Karl Renner
Plaintiff representatives
Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
It appears there may be a discrepancy in the provided IPR number. While the prompt references IPR2026-00227 as being associated with patent 11932230, comprehensive web searches, including PTAB case lists and detailed patent searches, did not yield direct evidence linking IPR2026-00227 to patent 11932230.
However, search results strongly indicate that U.S. Patent No. 11,932,230 is the subject of another Inter Partes Review, IPR2026-00229, where Tesla, Inc. is the Petitioner and Bulletproof Property Management, LLC is the Patent Owner. Patent 11932230, titled "Vehicle gear selection control," was granted on March 19, 2024, to inventor Bennet Langlotz. Bennet Langlotz has been identified as a "patent and trademark attorney" and is associated with claims of infringement against Tesla's "Auto Shift" feature.
Assuming the intent of the request is to identify counsel for the petitioner challenging patent 11932230, the relevant case is IPR2026-00229, with Tesla, Inc. as the petitioner (the "plaintiff" equivalent in this IPR context).
As filings for IPR2026-00229 were not available in the provided search snippets to directly identify counsel for Tesla, Inc., a general search for Tesla's patent litigation counsel, particularly for IPRs or automotive-related patents, would be required. Without access to the specific docket entries for IPR2026-00229, the counsel of record for Tesla, Inc. cannot be explicitly identified at this time. Filings for PTAB cases are typically accessible through the USPTO's Patent Trial and Appeal Board End-to-End (PTAB E2E) system or through services like DocketNavigator or PACER, which were not directly queried to reveal specific attorney names in the provided search results.
Defendant representatives
Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
I am unable to identify the counsel of record representing the Patent Owner in IPR2026-00227 through the current web search capabilities. Direct access to the PTAB's docketing system (P-TACTS) would be required to retrieve the official filings that designate counsel.
As of the current date, the general web searches, including queries for the PTAB docket and specific IPR counsel, have not yielded specific attorney names or firm information for IPR2026-00227. While patent 11932230 is attributed to inventor Bennet Langlotz, and he is noted as a patent and trademark attorney, it is not confirmed that he is representing himself or is represented by another firm in this IPR. Given that the case is a pending IPR from 2026, the relevant filings that would identify counsel may not yet be widely indexed or publicly accessible through general search engines.