Obviousness

To analyze the obviousness of US patent 12221104 under 35 U.S.C. § 103, we must consider whether the claimed invention as a whole would have been obvious to a person having ordinary skill in the art at the time the invention was made, given the scope and content of the prior art, the differences between the claimed invention and the prior art, and the motivation to combine references. The Supreme Court's decision in KSR International Co. v. Teleflex Inc. emphasizes a flexible, "common sense" approach, recognizing that the motivation to combine can come from various sources, including the knowledge of those skilled in the art, the prior art itself, or the nature of the problem to be solved.

The core of US patent 12221104, as described in independent claims 1 and 11, is a vehicle system that offers a change in drive direction based on steering input patterns and then changes direction upon a non-directional approval indication from the driver.

Here, we will evaluate potential combinations of the cited prior art references that could render the claims obvious. The "Prior Art" section lists several patents and a non-patent citation.

Prior Art References:

• US5436833A: Shift-to-neutral reminder prompt system/method
• US20110080305A1: Vehicle Park Assist System and Method for Parking a Vehicle Using Such System
• US20130110342A1: Method for pulling a vehicle into or out of a parking space and corresponding assistance system and vehicle
• US20130144492A1: Parking mode selection apparatus and method
• US20130184979A1: Method and System for Detection of Motor Vehicle Movement to Avoid Collisions
• US9085321B2: Unparking control system and unparking control method using the same
• US9219887B2: Drive assist device
• US20160075329A1: Parking assist system and path determination method
• US9381922B2: Detection of parking maneuver in a motor vehicle
• US20200207334A1: System, method, infrastructure, and vehicle for automated valet parking
• US20200404192A1: Vehicle-mounted device
• US11001301B2: Method for moving a motor vehicle out of a parking space with at least semi-autonomous manoeuvring of the motor vehicle up to an end position, driver assistance system and motor vehicle
• US20210269019A1: Parking Assistance System for Automated Pulling-Out of a Longitudinal Parking Space With a Reversing Move as the Last Pulling-Out Move
• US11623636B2: Display device for vehicle and parking assist system
• US20210300349A1: Vehicle movement assist system
• US20240051558A1: Automated adjustment of vehicle direction based on environment analysis (Tesla, Inc.)
• US11932230B1: Vehicle gear selection control (Bulletproof Property Management, Llc) (This is an earlier related patent by the same assignee/inventor, claiming priority from the same date).
• US12049217B2: Parking support device
• US12084047B2: Vehicle driving assist system
• US12151677B2: Vehicle control device, vehicle control method, program, and vehicle
• CNET Cars, "Elon Musk explains Auto Shift feature in Model S," YouTube, Jun. 11, 2021.

Person Having Ordinary Skill in the Art (PHOSITA):
A PHOSITA in this field would likely be a vehicle control systems engineer or software developer with knowledge of automotive sensors, control algorithms, human-machine interfaces, and assisted/autonomous driving technologies. They would understand how steering inputs, vehicle speed, and environmental data are used to control vehicle movement and assist drivers during maneuvers like parking.

Motivation to Combine:
The general motivation to combine elements from these prior art references would stem from the desire to enhance driver convenience, improve safety during parking and unparking maneuvers, and further automate vehicle operations. The patent itself highlights the disadvantages of manual gear selection, such as distraction during screen swipes, especially in parking lot contexts. Therefore, a PHOSITA would be motivated to find ways to reduce driver interaction while maintaining safety and control.

Analysis of Obviousness:

Given the context, several combinations of prior art could render the claims of US12221104 obvious. The focus of US12221104 is:

1. Offering a change in drive direction based on steering input patterns.
2. Changing the drive direction in response to a non-directional approval indication from the driver.

Combination 1: US9085321B2 + US20240051558A1 (or CNET Cars video) + US5436833A

• US9085321B2 (Unparking control system and unparking control method using the same): This patent explicitly deals with "unparking" maneuvers, which are a primary focus of US12221104. It likely discloses systems for controlling vehicle movement and steering during unparking. While the full text isn't provided here, the title suggests it involves analyzing unparking patterns, which would inherently include steering angle movements.
• US20240051558A1 (Automated adjustment of vehicle direction based on environment analysis - Tesla, Inc.) / CNET Cars, "Elon Musk explains Auto Shift feature in Model S" (2021): These references strongly suggest the existence of systems that can automatically adjust or propose vehicle direction, possibly in response to environmental factors. The CNET Cars reference specifically mentions an "Auto Shift feature." While the exact mechanism of triggering auto-shift isn't fully detailed in the provided abstract, it clearly points to vehicles that can automate gear selection. Tesla's focus on advanced driver-assistance systems and autonomous driving would provide a clear motivation for such a feature.
• US5436833A (Shift-to-neutral reminder prompt system/method): While this patent is older and discusses a "shift-to-neutral reminder," it introduces the concept of a system prompting the driver and waiting for an input. This establishes a precedent for a vehicle system to "offer" a change and await driver confirmation, even if the confirmation is not for a full gear shift.

Motivation for Combination 1:
A PHOSITA, aiming to improve the unparking experience and reduce driver distraction (as explicitly mentioned in US12221104's background), would be motivated to combine the unparking control systems of US9085321B2 with the automated shifting capabilities suggested by the Tesla/CNET references. The problem of manual gear selection being a distraction during parking/unparking is recognized. US9085321B2 likely provides the sensing and control logic for understanding unparking maneuvers, including steering patterns. The Tesla/CNET references provide the concept of an "auto-shift." The missing piece for the claims of US12221104 is the non-directional approval. However, US5436833A teaches a system that prompts a driver and requires an input. A PHOSITA would find it obvious to apply a non-directional approval (like a brake tap, button click, or gesture as described in US12221104) to an auto-shift proposal, as this reduces the cognitive load on the driver compared to requiring a directional input (like a screen swipe) and aligns with the general trend of simplifying driver interaction in assisted driving systems. The "common sense" approach articulated in KSR supports that simplifying driver input for a predicted outcome would be a predictable variation.

Combination 2: US20130110342A1 + US20210300349A1 + US11932230B1

• US20130110342A1 (Method for pulling a vehicle into or out of a parking space and corresponding assistance system and vehicle): This patent directly addresses methods for moving a vehicle into or out of a parking space, implying the use of steering and potentially drive direction changes. It would likely detail patterns of vehicle movement and steering associated with such maneuvers.
• US20210300349A1 (Vehicle movement assist system): This general reference to a "vehicle movement assist system" suggests mechanisms for aiding drivers in various vehicle operations, which could include automated actions or proposals based on detected driving conditions.
• US11932230B1 (Vehicle gear selection control - same inventor/assignee): This is a related patent with the same title and priority date as US12221104, suggesting it covers similar or foundational aspects of vehicle gear selection control. It is highly likely to disclose the idea of automatically proposing a gear change and awaiting a non-directional driver confirmation, as it is a parent application to US12221104. Given that it issued on 2024-03-19 and claims priority from 2023-06-05, it would be prior art for any claims in US12221104 that are not fully supported by the earlier filing date. The fact that US11932230B1 is an earlier patent by the same inventor and assignee that addresses "Vehicle gear selection control" with the same priority date strongly indicates that it would disclose many of the core inventive concepts.

Motivation for Combination 2:
A PHOSITA would naturally combine the teachings of US20130110342A1, which describes pulling into or out of parking spaces (involving steering and direction changes), with a general vehicle movement assist system like US20210300349A1 to automate aspects of these maneuvers. The existence of US11932230B1, an earlier patent by the same entity on "Vehicle gear selection control," provides a strong motivation to apply its teachings (including offering direction changes based on steering and accepting non-directional approval) to the specific context of parking/unparking described in US20130110342A1. If US11932230B1 discloses the non-directional approval, then combining it with any prior art that teaches detecting steering input patterns during parking/unparking would make the claims of US12221104 obvious. The problem of reducing driver distraction during routine parking maneuvers is a common one in the automotive industry, providing a clear motivation to integrate and refine these functionalities.

Specific Obviousness Argument against Independent Claims 1 and 11:

Let's consider Independent Claim 1: "A motor vehicle for operation by a driver comprising: a frame having wheels; a motor connected to the frame; a steering control operable by the driver to generate a steering input; a drive system operably connected to the steering control to receive the steering input; the drive system operable selectably to drive the vehicle in a forward direction and a rear direction; the drive system operable based on the steering input to offer the driver a change in the drive direction; and after offering the driver the change in the drive direction, the drive system operable in response to an approval indication from the driver to change the drive direction."

And Independent Claim 11, which is substantially similar but uses "controller" instead of "drive system."

• Elements 1-5 (Frame, wheels, motor, steering control, drive system for forward/rearward driving): These elements are fundamental to any motor vehicle and are universally taught by any of the prior art references, such as US20110080305A1 ("Vehicle Park Assist System and Method for Parking a Vehicle Using Such System").
• "the drive system operable based on the steering input to offer the driver a change in the drive direction": This element, in the context of parking/unparking, would be rendered obvious by combining US9085321B2 (Unparking control system) with the general knowledge of auto-shift systems (e.g., Tesla's "Auto Shift" as per CNET Cars and US20240051558A1). A system designed for unparking would necessarily monitor steering input to understand the vehicle's trajectory. Predicting a desired gear change (e.g., from reverse to drive after backing out) based on a pattern of steering (e.g., reversing with a large steering angle, then straightening or initiating a turn in the opposite direction, as described in FIG. 2 of US12221104) would be a logical step for a PHOSITA seeking to automate the unparking process. The patent itself notes that "AI systems would simply derive the rules from typical driver behavior", implying that these patterns are inherent in how drivers operate.
• "after offering the driver the change in the drive direction, the drive system operable in response to an approval indication from the driver to change the drive direction": This element, combined with the previous one, would be obvious from US11932230B1, given its similar title and priority date. If US11932230B1 discloses offering a gear change and accepting a non-directional approval, then combining it with any system that detects steering input for parking maneuvers would be obvious. Even without US11932230B1, combining the auto-shift concept (Tesla/CNET) with the idea of a simple confirmation from US5436833A (Shift-to-neutral reminder prompt system, which requires a driver input to confirm a prompt) would lead to the claimed invention. The motivation would be to enhance safety and convenience by requiring driver confirmation for an automated action, but simplifying that confirmation to a non-directional input to reduce distraction. The patent explicitly defines "driver confirmation of the direction is provided by a control input that conveys no direction information and is the same input regardless of direction proposed", and states that "the switch is a simple binary switch". This concept of a non-directional confirmation for a vehicle-proposed action is present in the prior art, even if in a different context.

Consideration of specific features in US12221104 claims:

• Claim 2/12 (Brake control for approval): This is explicitly taught as a method of approval in the background of US12221104 itself (referring to prior art): "the driver then for safety reasons indicates (such as by a tap on the brake) that the proposed direction is safe and correct." This demonstrates that brake actuation as a non-directional approval was known.
• Claim 3/13 (Foot shifting from accelerator to tap brake): This is a specific implementation detail of the brake control approval, which would be obvious to a PHOSITA given the prevalence of "one-pedal driving" and the established use of brake taps for confirmation.
• Claim 4/14 (Steering input greater than threshold): This is a logical parameter for determining when to offer a gear change during maneuvers like unparking, where significant steering is common. US9085321B2 (Unparking control system) would inherently rely on steering angle thresholds.
• Claim 5/15 (Velocity below threshold): This is also a logical parameter for offering gear changes, especially in parking scenarios. US12221104 itself states that "Parking operation normally takes place at slow speeds, so the operation and functions disclosed herein may be limited to circumstances below a selected speed".
• Claim 6/16 (Steering in first direction, then opposite): This describes a common pattern in parking and unparking maneuvers, as explicitly illustrated in FIG. 2 of US12221104 (e.g., turning wheels sharply in one direction, then reversing the angle). Detecting such a pattern to infer intent would be an obvious application of sensor data for a PHOSITA.
• Claim 7/17 (Distance traveled): This is another common parameter for analyzing vehicle movement in parking, as mentioned in US12221104's description: "Other systems may simply employ distance traveled information, offering an auto-shift any time a vehicle reverses and stops within a selected distance typical for such parking lots".

Conclusion on Obviousness:

The claims of US12221104 appear to be obvious under 35 U.S.C. § 103, particularly when considering the combinations of prior art discussed above. The general concept of automating gear changes in response to driving conditions, especially during parking and unparking, is widely recognized in the prior art (e.g., US20110080305A1, US9085321B2, and the Tesla auto-shift features). The innovation of US12221104 lies in proposing a direction change based on steering input patterns and then accepting a non-directional approval. However, the use of steering patterns to infer driver intent in parking scenarios is a logical application of sensor data, and the concept of a non-directional confirmation for a vehicle-proposed action is also suggested in the prior art (e.g., US5436833A and even the background of US12221104 itself which refers to prior art where a brake tap confirms a proposed direction). The primary motivation for combining these elements would be to improve driver convenience and safety during parking maneuvers by reducing the need for explicit directional input from the driver.

The presence of US11932230B1 (Vehicle gear selection control), an earlier patent by the same inventor and assignee with the same priority date, is particularly significant. If this earlier patent discloses the core mechanism of offering a gear change based on vehicle parameters and accepting a non-directional approval, then US12221104 might simply represent a further application or refinement of these already disclosed concepts to specific driving situations (like unparking maneuvers characterized by steering patterns). In such a scenario, the claims of US12221104 would likely be found obvious over US11932230B1 in combination with other prior art references that teach detection of steering patterns in parking situations.