Tesla, Inc. v. Bulletproof Property Management, LLC

I'll research the parties, the asserted patents, and the procedural posture before drafting.

Key finding: the case has moved beyond the posture in the earlier summary. Let me verify the Director's decision, institution status, and each patent's subject matter.

Now let me check institution status, the vacated trial date, and the venue fight.

Case Overview & Background

Parties. Bulletproof Property Management LLC v. Tesla, Inc., No. 1:25-cv-00665-ADA (W.D. Tex., Austin Division), is a seven-patent assertion by a small, non-practicing patent holder against the country's largest EV manufacturer. Plaintiff Bulletproof is a Wyoming LLC based in Cheyenne, whose sole owner and principal is Bennet Langlotz, the named inventor on the entire patent family; the company does not make or sell vehicles, and its business model is enforcement and licensing (Tesla and commentators describe it as an NPE — a characterization drawn from the record, not a court finding). Am. Compl. ¶ 13; Mondaq/ip.com analysis ("They don't make cars. They don't manufacture anything."). Defendant Tesla, Inc. is a Texas corporation headquartered at 1 Tesla Road, Austin — a fact Bulletproof leveraged against transfer. Am. Compl. ¶ 14. The patents claim a single inventor's solution to "unparking" a stalkless EV: rather than swiping a touchscreen to shift from Reverse to Drive, the car infers the desired direction from steering-angle patterns. The family traces to U.S. Patent No. 11,932,230 ("Vehicle Gear Selection Control," issued Mar. 19, 2024, from App. Ser. No. 18/205,823), with a PCT/EP counterpart (EP4719850A1, published Apr. 8, 2026).

Accused technology and patents. The accused feature is Tesla's "Auto Shift" — software, delivered by over-the-air update beginning in May 2024, that shifts between Drive and Reverse "without using the touchscreen based on your surroundings," available on newer Model S, 3, X and Y. Am. Compl. ¶ 8 & n.1. Because the accused instrumentality is software pushed to an installed fleet, the complaint pleads direct infringement plus inducement of "hundreds of thousands, or even millions" of owners, and willfulness grounded in alleged March 2024 correspondence between Langlotz and Tesla's counsel predating the May 2024 rollout. Id. ¶¶ 7–10. The seven asserted patents are all titled Vehicle Gear Selection Control and share a common specification, with the six follow-ons filed Oct. 27, 2024 (serials 18/928,128, -131, -134, -135, -137, etc.) and issuing in a five-week burst in early 2025:

• 11,932,230 (Mar. 19, 2024) — parent; apparatus claims to a controller that selects drive/reverse direction "in response to a pattern of steering angle movements, without operator indication of a direction."
• 12,221,104 (Feb. 11, 2025) — claims to offering a direction change based on steering input and effecting it only upon a driver approval signal (e.g., a brake tap).
• 12,227,184 (Feb. 18, 2025) — the patent at issue in IPR2026-00204; method claims to monitoring steering control while driving in a first direction and automatically changing between drive and reverse "based on the steering control," with dependent claims adding pattern/sequence-of-movements, steering-angle and velocity thresholds, and brake-actuation confirmations (claims 1–23).
• 12,233,871 (Feb. 25, 2025) and 12,240,456 / 12,240,457 / 12,240,458 (all Mar. 4, 2025) — further continuations varying the same themes (auto-shift offers gated on time/distance/velocity/steering angle, vehicle-location conditions, and approval-based confirmation). Note: I verified claim text only for the '184 and '230; the one-line sketches for the remaining four are drawn from published application claim sets in the same family and should be confirmed against the issued claims.

Procedural posture, venue, and why it matters. Bulletproof filed on May 5, 2025 (Dkt. 1), amended on Aug. 11, 2025 to add the six follow-ons (Dkt. 15), and Tesla answered with counterclaims on Sept. 30, 2025. Tesla moved to transfer to the Northern District of California on July 21, 2025 (Dkt. 13), arguing that no accused-feature developer, document, or third party sits in Austin and that Langlotz lives ~215 miles away; briefing closed in fall 2025 (Dkt. 33) and I found no ruling on that motion — treat its status as unverified. Judge Albright entered a scheduling order on Apr. 2, 2026 (Markman Aug. 24, 2026; jury trial Aug. 23, 2027), then vacated all settings on Apr. 23, 2026 "due to the potential for future conflicts," leaving the case with no trial date; deadlines were extended by agreement on June 4, 2026, and Tesla filed an Opposed Motion to Stay on June 12, 2026 (Dkt. 40), which Bulletproof opposed. That vacatur became the pivot of the PTAB fight: in Tesla, Inc. v. Bulletproof Property Mgmt., LLC, IPR2026-00204 et al., Paper 14 (Director June 15, 2026) — the **first decision designated informative under the Office's March 11, 2026 U.S.

This case involves a parallel patent infringement lawsuit in the district court and an Inter Partes Review (IPR) proceeding at the Patent Trial and Appeal Board (PTAB) challenging the validity of one of the asserted patents.

Parallel District Court Litigation

Case: Bulletproof Property Management LLC v. Tesla Inc et al., Case No. 1:25-cv-00665, filed in the U.S. District Court for the Western District of Texas.

• Filing & Initial Pleadings: Bulletproof Property Management LLC (Plaintiff) filed a patent infringement complaint against Tesla, Inc. (Defendant) on May 5, 2025. The lawsuit asserts infringement of seven patents, including U.S. Patent No. 12,227,184, which is the subject of the IPR. An Amended Complaint was filed by Bulletproof Property Management LLC on August 11, 2025. In response, Tesla, Inc. filed an Answer to the Amended Complaint, which included a Jury Demand and Counterclaims against Bulletproof Property Management LLC.
• Pre-trial Motions: Tesla, Inc. filed a Motion to Dismiss for Failure to State a Claim. An Order was issued granting Robert J. Rando permission to appear pro hac vice on behalf of Bulletproof Property Management LLC, indicating ongoing representation in the case.
• Current Posture: There is conflicting information regarding the status of the district court case. One source indicates the status as "Closed", while another states it is "OPEN". Given that filings such as an Amended Complaint and an Answer with Counterclaims occurred as late as August 2025, and no subsequent definitive dismissal or judgment has been identified, it is more likely that the case remains active or was not fully closed as of May 2026. The case is presided over by Judge Alan D. Albright.

PTAB Inter Partes Review (IPR) Proceeding

Case: Tesla, Inc. v. Bulletproof Property Management, LLC, IPR2026-00204, at the Patent Trial and Appeal Board (PTAB).

• Filing: Tesla, Inc. filed the IPR petition against Bulletproof Property Management, LLC on January 20, 2026, challenging the validity of U.S. Patent No. 12,227,184. This patent is one of the seven patents asserted by Bulletproof Property Management LLC in the parallel district court litigation against Tesla.
• Key Docket Events: A scheduling order and the Patent Owner's updated mandatory notices were filed on May 13, 2026.
• Current Posture: The IPR is currently in the pre-institution phase and is listed as "Pending". Following the filing of the petition on January 20, 2026, a decision on whether to institute the IPR proceeding is expected by the PTAB (specifically by the USPTO Director, who, as of October 2025, makes institution decisions) typically within six months of the petition filing date, or three months after the Patent Owner's preliminary response. Therefore, an institution decision for IPR2026-00204 is anticipated around July 2026.

Effect of Parallel PTAB IPR on Litigation

The IPR proceeding, if instituted, could significantly impact the district court litigation. If the PTAB finds any claims of U.S. Patent No. 12,227,184 unpatentable in a final written decision, those claims would be invalidated, potentially removing them from the district court infringement case. District courts often consider staying litigation pending the outcome of an IPR, especially when the IPR addresses central claims of the asserted patent, to promote judicial economy and benefit from the PTAB's expertise. However, no motion to stay the district court case based on the IPR has been identified as of the current date.

Here are the counsel of record representing Tesla, Inc. (Petitioner) in IPR2026-00204, based on their established roles and consistent representation of Tesla in similar Inter Partes Review (IPR) proceedings at the Patent Trial and Appeal Board (PTAB) and related appeals. While specific docket entries for IPR2026-00204 directly naming these attorneys were not publicly discoverable in the search results, their roles in recent, analogous Tesla IPRs indicate their likely involvement.

Tesla, Inc. (Plaintiff/Petitioner) Representatives:

• Jonathan R. Bowser

  • Role: Partner, Head of Patent Office Trials Practice Group (likely Lead Counsel)
  • Firm: Haynes and Boone, LLP, Washington, D.C. / Northern Virginia
  • Experience: Focuses on post-grant validity disputes including Inter Partes Reviews (IPRs) before the PTAB, having served as counsel in over 150 AIA trials and recognized as a "Top 100 Most Active Attorney" representing petitioners.

• David O'Brien

  • Role: Partner, leads the firm's Patent Office Trials Practice Group (likely Lead Counsel)
  • Firm: Haynes and Boone, LLP, Washington, D.C. (firm's PTAB practice group lead location)
  • Experience: Possesses over 25 years of experience in software, semiconductor, and computer electronics technologies, and has served as lead counsel in over 80 contested PTAB proceedings, focusing on IPRs and other post-grant matters.

• Scott Jarratt

  • Role: Partner (likely Counsel)
  • Firm: Haynes and Boone, LLP, Dallas, TX
  • Experience: Specializes in IPRs and other post-grant proceedings before the PTAB, recognized as one of the "Best Performing Attorneys representing Petitioners" and ranked in the top 1% of PTAB attorneys in terms of statistical success.

• Hong Shi

  • Role: Counsel, Co-chair of the firm's Artificial Intelligence practice (likely Counsel)
  • Firm: Haynes and Boone, LLP, Austin, TX
  • Experience: Frequently represents clients in post-grant proceedings, including IPRs, and has expertise in a wide range of complex technologies such as artificial intelligence/deep learning, autonomous driving, and semiconductor device design.

• Ashraf Fawzy

  • Role: Managing Counsel - IP Litigation (In-house)
  • Firm: Tesla, Inc.
  • Experience: Represents Tesla in post-grant proceedings and related appeals, including arguing before the Federal Circuit.

These attorneys from Haynes and Boone, LLP, frequently represent Tesla in PTAB proceedings, as evidenced by their explicit listing as counsel for Tesla in IPR2025-00222 and IPR2025-00220, and their firm's prominent PTAB practice. Ashraf Fawzy is consistently identified as Tesla's in-house Managing Counsel for IP Litigation in various related proceedings.

analysis
The searches so far have not directly provided the counsel of record for Bulletproof Property Management, LLC in IPR2026-00204. While the initial prompt states that "the Patent Owner's updated mandatory notices were filed on May 13, 2026," I haven't found a search result that specifically links this filing for IPR2026-00204 to attorney names. The search results discussing "Patent Owner's Updated Mandatory Notices" on May 13, 2026, were in the context of other IPRs (e.g., IPR2026-00171 and PGR2025-00017). The district court case involving Bulletproof Property Management LLC and Tesla (1:2025cv00665) mentioned Michael Marron and Robert J. Rando, but this is a separate proceeding.

Since direct PTAB docket searches for IPR2026-00204 haven't yielded the specific counsel names, and the existing case summary indicates mandatory notices were filed, it is highly likely the counsel information is contained within that specific PTAB filing. Without direct access to the PTAB E2E system to pull the actual document for IPR2026-00204 docket entry for "Patent Owner's updated mandatory notices filed on May 13, 2026", I cannot definitively identify the counsel of record.

Therefore, I must state that the information cannot be found with the available search capabilities.Despite multiple web searches for IPR2026-00204, the specific counsel of record representing Bulletproof Property Management, LLC (the defendant/patent owner) in this particular PTAB Inter Partes Review case could not be definitively identified.

While the existing case summary notes that the "Patent Owner's updated mandatory notices were filed on May 13, 2026," which would typically include lead and back-up counsel, direct access to the content of this specific filing for IPR2026-00204 was not available through the conducted searches. Searches on public databases such as the USPTO Open Data Portal and Unified Patents Portal did not yield a direct listing of attorneys for Bulletproof Property Management, LLC in IPR2026-00204.

References to attorneys for Bulletproof Property Management, LLC in other related cases, such as Michael Marron and Robert J. Rando in a district court case (1:2025cv00665) against Tesla, Inc., or in a different IPR (IPR2026-00229) where Bulletproof Property Management LLC was the petitioner, are not confirmed to be the counsel of record for Bulletproof Property Management, LLC as the Patent Owner in IPR2026-00204.

Therefore, without direct access to the IPR2026-00204 docket on the PTAB-E2E system, the counsel of record for Bulletproof Property Management, LLC in this IPR cannot be explicitly named. Filings are not sealed, but the specific details of the "Patent Owner's updated mandatory notices" for this IPR are not publicly discoverable through the available search methods.