Bulletproof Property Management LLC v. Tesla Inc

This patent infringement litigation, Bulletproof Property Management LLC v. Tesla Inc, centers on allegations that Tesla's "Auto Shift" feature infringes two U.S. patents. The plaintiff, Bulletproof Property Management LLC, is a Wyoming limited liability company whose sole owner and principal, Bennet Langlotz, is also the inventor of the asserted patents and a "prolific inventor" with a history of commercialized patents across various industries, including automotive. While Bulletproof Property Management LLC operates a property management business, its role in this litigation, asserting patents developed by its principal, strongly indicates it functions as a Patent Assertion Entity (PAE) or Non-Practicing Entity (NPE). The defendant, Tesla Inc., is a leading electric vehicle (EV) and clean-energy technology company [cite: Previous search results].

The core of the dispute involves Tesla motor vehicles equipped with the "Auto Shift" feature, which Bulletproof Property Management LLC alleges infringes its patents by utilizing the patented vehicle gear selection control process and system. The patents at issue are U.S. Patent No. 11,932,230 and U.S. Patent No. 12,221,104. U.S. Patent No. 11,932,230, titled "Vehicle gear selection control," describes a system where a vehicle's controller automatically selects a driving direction (forward or reverse) based on steering angle movements, eliminating the need for explicit operator direction input [cite: 10, Previous search results]. A specific one-line technical sketch for U.S. Patent No. 12,221,104 could not be directly located through web search, though the amended complaint identifies it as a 'Follow-On Patent' also pertaining to the "Auto Shift" feature [cite: Previous search results].

The case was filed in the U.S. District Court for the Western District of Texas, Austin Division, and is presided over by Judge Alan D. Albright, with Magistrate Judge Mark Lane also assigned [cite: 4, 5, 7, Previous search results]. The Western District of Texas, and particularly Judge Albright's court, has garnered attention as a popular venue for patent litigation due to its reputation for efficiently managing patent dockets and its patentee-friendly procedures [cite: Previous search results]. The case is notable for involving a likely NPE asserting automotive technology patents against a major innovator in the electric vehicle industry. Furthermore, Tesla has initiated inter partes review (IPR) proceedings against both asserted patents at the Patent Trial and Appeal Board (PTAB): IPR2026-00229 against U.S. Patent No. 11,932,230 and IPR2026-00219 against U.S. Patent No. 12,221,104, representing significant parallel challenges to the patents' validity [cite: 6, Previous search results]. While some search results initially indicated a "Closed" status, more comprehensive docket information, including scheduled future events such as a Claim Construction Hearing on August 24, 2026, and a Final Pretrial Conference on August 5, 2027, confirms the case remains active and ongoing [cite: Previous search results].

Patent Infringement Litigation: Bulletproof Property Management LLC v. Tesla Inc

Case Number: 1:25-cv-00665
Court: Western District of Texas
Filed: 2025-05-05
Status: Closed
Patents at issue: U.S. Patent Nos. 12221104, 11932230 (and potentially other related patents)

This case, filed by Bulletproof Property Management LLC ("Bulletproof") against Tesla Inc. ("Tesla") in the Western District of Texas, centered on allegations of patent infringement. While initially involving U.S. Patent No. 11,932,230, an amended complaint later included U.S. Patent No. 12221104, alongside other patents related to vehicle gear selection control. The case ultimately concluded as "Closed," concurrent with the initiation of multiple inter partes review (IPR) proceedings against the asserted patents at the Patent Trial and Appeal Board (PTAB).

Key Legal Developments and Outcome:

Filing & Initial Pleadings:

• 2025-05-05: Bulletproof Property Management LLC filed the initial complaint against Tesla Inc. for patent infringement.
• 2025-08-20: An amended complaint was filed by Bulletproof, expanding the scope of patents at issue to include U.S. Patent No. 12221104 as a 'Follow-On Patent' in addition to U.S. Patent No. 11,932,230. The amended complaint alleged willful infringement by Tesla.
• 2025-09-30: Tesla filed its Answer to the Amended Complaint, including a jury demand and counterclaims against Bulletproof Property Management LLC.

Pre-trial Motions of Substance:

• Tesla filed a Motion to Dismiss for Failure to State a Claim.
• 2026-03-24: Tesla's Motion to Dismiss for Failure to State a Claim was denied as moot by Judge Alan D. Albright.

Discovery Milestones:

• 2026-03-24: A Joint Motion for Entry of Scheduling Order Deadlines was filed by Bulletproof. This scheduling order set a Markman hearing for August 24, 2026, amended pleadings due by December 17, 2026, discovery due by March 25, 2027, joinder of parties due by October 8, 2026, and dispositive motions due by June 3, 2027.

Claim Construction (Markman) Outcomes:

• A Markman hearing was scheduled for 2026-08-24. However, given the case's "Closed" status, it is unlikely this hearing proceeded as scheduled in the district court. There is no public record of a Markman order.

Parallel PTAB IPR Proceedings:

• 2026-01-20: Tesla Inc. initiated an inter partes review (IPR) proceeding against U.S. Patent No. 12221104, identified as IPR2026-00219. This IPR is currently in the pre-institution phase.
• 2026-01-23: Tesla Inc. filed an IPR petition against U.S. Patent No. 11,932,230, identified as IPR2026-00227.
• 2026-01-23: Tesla Inc. filed another IPR petition against U.S. Patent No. 11,932,230, identified as IPR2026-00228.
• Tesla also filed an IPR against U.S. Patent No. 12,240,458, identified as IPR2026-00229.
• 2026-02-03: Bulletproof Property Management LLC filed a "NOTICE of IPR Filings" with the district court, acknowledging the parallel PTAB proceedings.

Final Disposition:

• The district court case is marked as "Closed." While the specific order or reason for closure is not explicitly detailed in the provided search results, the closure of the district court case concurrent with multiple IPR filings by Tesla against the asserted patents suggests a likely settlement between the parties, leading to a voluntary dismissal of the litigation in the district court. This is a common strategy in patent litigation where IPRs are instituted. The lack of a reported judgment or trial event further supports this inference.

Here is the counsel of record representing Bulletproof Property Management LLC in Bulletproof Property Management LLC v. Tesla Inc, Case No. 1:25-cv-00665:

• Robert J. Rando

  • Role: Lead Counsel (appeared pro hac vice)
  • Firm: Likely Buether Joe & Counselors, LLC (based on the firm signing the Amended Complaint, and Rando's pro hac vice motion being filed by Christopher Joe of that firm)
  • Office Location: Not explicitly stated in the provided snippets, but typically pro hac vice attorneys are from out-of-state firms.
  • Relevant Experience: The provided search results do not detail Robert J. Rando's specific patent litigation experience or notable past cases, other than his appearance in this patent infringement suit.

• Christopher J. Joe

  • Role: Counsel (appears to be local counsel or co-counsel, as his firm signed the Amended Complaint and he filed Rando's pro hac vice motion)
  • Firm: Buether Joe & Counselors, LLC
  • Office Location: Not explicitly stated in the provided snippets.
  • Relevant Experience: The provided search results do not detail Christopher J. Joe's specific patent litigation experience or notable past cases. His firm, Buether Joe & Counselors, LLC, is identified as representing the plaintiff in this patent infringement case.

It is also worth noting that while Michael W. Smith is listed as counsel for Bulletproof Property Management, LLC in a related Inter Partes Review (IPR) proceeding (IPR2026-00229), the provided docket snippets for the district court case do not explicitly show his appearance there. The Amended Complaint in the district court case was signed by "undersigned attorneys, Buether Joe & Counselors, LLC".

Here is the identified counsel of record representing Tesla Inc. in Bulletproof Property Management LLC v. Tesla Inc:

In-house Counsel (Tesla Inc.)

• Terry W. Ahearn (Role: In-house Counsel)
  • Firm: Tesla, Inc.
  • Office Location: (Information not specified in search results, but Tesla's legal department is known to have a presence in Texas and California.)
  • Note: Appears on behalf of Tesla Inc..
• Gina Cremona (Role: In-house Counsel)
  • Firm: Tesla, Inc.
  • Office Location: (Information not specified in search results.)
  • Note: Appears on behalf of Tesla Inc..
• Krista Carter (Role: In-house Counsel - Withdrawn)
  • Firm: Tesla, Inc.
  • Office Location: (Information not specified in search results.)
  • Note: An "Unopposed MOTION to Withdraw as Attorney for Krista Carter by Tesla, Inc." was filed on January 6, 2025.

Outside Counsel (Fish & Richardson P.C.)

• Aamir A. Kazi (Role: Lead Counsel / Outside Counsel)
  • Firm: Fish & Richardson P.C.
  • Office Location: (Specific office location for Aamir A. Kazi within Fish & Richardson P.C. not immediately available from search results, but the firm has multiple offices across the US, including Texas, California, and Washington D.C.)
  • Note: Has entered an appearance on behalf of Tesla Inc.. Fish & Richardson is a prominent firm in patent litigation, representing clients in district courts, the U.S. Court of Appeals for the Federal Circuit, the International Trade Commission (ITC), and the Patent Trial and Appeal Board (PTAB).
• David M. Hoffman (Role: Outside Counsel)
  • Firm: Fish & Richardson P.C.
  • Office Location: (Specific office location for David M. Hoffman within Fish & Richardson P.C. not immediately available from search results.)
  • Note: Has entered an appearance on behalf of Tesla Inc..