Invalidity dossier

US 12227184

Vehicle gear selection control

Current assignee: Tesla, Inc.

Added 5/12/2026, 11:39:03 PM

At a glanceActive PTAB challenge2 lawsuits on fileasserted by Tesla, Inc.Automotive (A)

Active provider: Google · gemini-2.5-flash

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Patent summary

Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.

✓ Generated

Here is a concise summary of US patent 12227184:

Title: Vehicle gear selection control

Assignee: Bulletproof Property Management LLC

Inventor: Bennet Langlotz

Filing Date: 2024-10-27

Issue Date: 2025-02-18

Abstract: A motor vehicle for operation by a driver is described, featuring a frame with wheels and a motor. A steering control is connected to the wheels to establish a steering angle. A controller is operably connected to the steering control, the motor, and the wheels, enabling the vehicle to be driven in a forward (drive) or rearward (reverse) direction. The controller is capable of selecting a drive direction based on a pattern of steering angle movements, without requiring the operator to explicitly indicate the desired direction.

Plain-Language Overview of Independent Claims:

  • Independent Claim 1: This claim describes a method for a vehicle's drive system to automatically change between drive and reverse modes. The system monitors the steering control while the vehicle is moving in one direction, and then shifts to the other mode (e.g., from reverse to drive) based on the steering control's input, without the driver needing to specify the direction of the shift.
  • Independent Claim 13: This claim is similar to Claim 1 but specifies that a "controller" performs the actions. The controller monitors the steering control as the vehicle drives in a first direction and then changes the drive mode (e.g., from reverse to drive or vice-versa) based on the steering control's input.

USPTO Database and CAFC 2026 Dockets:

A review of the patent's metadata indicates that US12227184 is currently active and has associated litigation. This includes a US case filed in the Texas Western District Court (case 1:25-cv-00665) and a PTAB case (IPR2026-00204) which is pending. While general information about the USPTO search tools and CAFC scheduled cases for 2026 were found, no specific docket entry for patent 12227184 was identified within the provided CAFC 2026 dockets. Therefore, there is no authoritative information from the direct CAFC search results to report on specific 2026 CAFC dockets for this patent number at this time.

Generated 5/28/2026, 12:48:29 PM

Cases on file (2)

Group view →

Specific litigation cases in our database that name US patent 12227184. The free-form analysis below may also discuss cases beyond this list.

Litigation summary

Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.

✓ Generated

Known litigation involving US patent 12227184 includes the following:

1. District Court Litigation

  • Plaintiff(s): Bulletproof Property Management LLC
  • Defendant(s): Tesla Inc
  • Jurisdiction: Western District of Texas
  • Case Number: 1:25-cv-00665
  • Filing Date: May 5, 2025
  • Outcome or Current Status: This is an active patent infringement case. Tesla, Inc. has filed an answer to an amended complaint, including a jury demand and a counterclaim against Bulletproof Property Management LLC. Tesla, Inc. has also filed motions to dismiss for failure to state a claim. A claim construction hearing is scheduled for August 24, 2026, and a final pretrial conference is set for August 5, 2027.

2. Patent Trial and Appeal Board (PTAB) Litigation

Generated 5/28/2026, 12:48:36 PM

Proceedings on file (1)

All PTAB activity →

AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.

Current assignee: Tesla, Inc.

1 active

PTAB challenges

AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.

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Proceedings overview

There is one AIA trial proceeding on file for US patent 12227184, which is currently active and pending. This gives a defendant limited defensive posture at this stage, as no claims have been invalidated or sustained yet.

IPR2026-00204 — Tesla, Inc. v. Bulletproof Property Management, LLC

  • Type: Inter Partes Review
  • Filed: 2026-01-20
  • Status: Pending. The proceeding is ongoing, and no final decision on institution or merits has been reached.
  • Judge panel: Not yet publicly available, as the institution decision is pending. (Note: Under current USPTO policy, institution decisions are centrally handled by the Director, who then refers petitions for consideration on the merits to a three-member panel if not discretionarily denied.)
  • Petition grounds: Not yet publicly available.
  • Institution decision: Pending. The deadline for an institution decision is not yet known. (Note: The USPTO Director now leads a screening of petitions, and institution rates have decreased.)
  • Final Written Decision: Not yet issued.
  • Settlement / termination: Not yet settled.
  • Appeal: Not applicable, as no Final Written Decision has been issued.
  • Defensive value: This proceeding is in its early stages. While it indicates that Tesla, Inc. believes there are grounds to challenge the patent's validity, no claims have been affected yet. A defendant facing assertion of this patent should monitor this IPR closely, as a successful challenge could significantly weaken the patent owner's position.

Strategic summary

Currently, all claims of US patent 12227184 are UNTESTED by a Final Written Decision in an AIA trial proceeding. The sole IPR, IPR2026-00204, filed by Tesla, Inc. against Bulletproof Property Management, LLC, is in a pending status, meaning there has been no institution decision or final determination on the patentability of the challenged claims.

The estoppel landscape is not yet established for US12227184. If IPR2026-00204 proceeds to a Final Written Decision, Tesla, Inc. (and its privies) would be estopped from raising any ground that was raised or reasonably could have been raised in the IPR regarding the claims addressed in the decision. For other defendants, prior-art grounds remain available, subject to the statutory limitations of IPRs (e.g., challenges based only on patents and printed publications under § 102 or § 103).

The filing of an IPR by a major entity like Tesla, Inc. indicates a potential perceived weakness in the patent's claims.

Recommended next steps

Since IPR2026-00204 is pending, a defendant facing assertion of this patent should closely monitor the proceeding for the institution decision. The PTAB generally has a one-year statutory deadline from institution to issue a Final Written Decision. The outcome of the institution decision will be critical:

  • If the IPR is instituted, the challenged claims will be undergoing examination for patentability.
  • If institution is denied, it would indicate that the PTAB (specifically the Director, under current policy) did not find a reasonable likelihood that Tesla, Inc. would prevail on at least one challenged claim, or that discretionary denial factors were at play.

Given the recent changes in USPTO policy regarding IPR institution, which have led to a decrease in institution rates, it is particularly important to observe whether the Director institutes this IPR.

Generated 5/28/2026, 12:48:33 PM

Ownership chain (1)

Asserters network →

Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.

  1. 2024-01-03 · recorded 2024-10-27 · reel 069032/0839 · Assignment

    Bennet LanglotzBULLETPROOF PROPERTY MANAGEMENT, LLC

    Original assignment from inventor to assignee

Assignment history

Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.

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Inventors

Original assignee

Bulletproof Property Management LLC. It is unclear from the patent text whether Bulletproof Property Management LLC ships a product embodying the claims, or its primary line of business. The legal status of the patent is "Active".

Assignment timeline

  • 2024-01-03 (executed) / recorded 2024-10-27 — Reel 069032/0839
    • Conveyance: Assignment
    • Assignor: Bennet Langlotz
    • Assignee: BULLETPROOF PROPERTY MANAGEMENT, LLC
    • Correspondent: Not specified in this record, but the overall patent record lists the assignee as Bulletproof Property Management LLC.
    • Context: Original assignment from inventor to assignee.

The USPTO Assignment Center search page for US12227184 (https://assignmentcenter.uspto.gov/patent/index.html?cn=[12227184](/patent/12227184)) shows only the initial assignment from the inventor to Bulletproof Property Management LLC. There are no further recorded assignments for this patent as of 2026-05-28.

Timeline diagram

timeline
    title Ownership of US 12227184
    2023 : Priority date
    2024 : Filed by Bulletproof Property Management LLC
         : Assigned to Bulletproof Property Management LLC
    2025 : Issued

NPE / troll-pattern signals

  1. Shell-entity transfernot present. The patent was assigned directly from the inventor to Bulletproof Property Management LLC. There is no transfer from an operating company to a shell entity in the provided records.

  2. Known asserter in the chainnot present. Bulletproof Property Management LLC does not appear on public NPE lists from the provided context.

  3. Repeat correspondent across the chainnot present. There is only one assignment recorded, and no specific correspondent information is provided beyond the assignee name itself.

  4. Cascading transfersnot present. Only one assignment is recorded.

  5. Pre-litigation transferunclear. While the Google Patents record indicates "Family has litigation" and specifies a "US case filed in Texas Western District Court" on 1:25-cv-00665 and a "PTAB case IPR2026-00204 filed (Pending)", the exact filing dates of these cases relative to the assignment date (October 27, 2024) are not precise enough to confirm a pre-litigation transfer within a 6-month window without further investigation into the complaint filing date. The Google Patents information states the PTAB case IPR2026-00204 is "filed (Pending)" and the US case in Texas Western District Court is listed as "1:25-cv-00665" which implies a 2025 filing year.

  6. Bankruptcy fire-salenot present. No indication of bankruptcy for the assignor or assignee.

  7. Privateeringnot present. No evidence of an operating company transferring to an NPE to assert on its behalf.

  8. Defensive aggregator (anti-NPE)not present. The chain does not terminate at a known defensive aggregator.

Verdict

Insufficient data. The only recorded assignment is from the inventor to Bulletproof Property Management LLC. Without information on Bulletproof Property Management LLC's business activities or further assignment records, it is not possible to confidently determine if this entity is an NPE or an operating company. While there is litigation associated with the patent family, the current assignment record does not provide sufficient information to establish an NPE pattern.

USPTO Assignment Center search for US12227184: https://assignmentcenter.uspto.gov/patent/index.html?cn=12227184

Generated 5/28/2026, 12:48:33 PM

Prior art

Earlier patents, publications, and products that may anticipate or render the claims unpatentable.

✓ Generated

To identify the most relevant prior art for US patent 12227184, I will analyze the citations listed within the patent itself. The provided text already includes a "Citations" section.

Here's an analysis of the cited prior art:

Prior Art for US Patent 12227184

The following patents are cited as prior art in US12227184B1:

  1. US5436833A

    • Full Citation: US5436833A, Eaton Corporation, "Shift-to-neutral reminder prompt system/method"
    • Publication Date: 1995-07-25
    • Priority Date: 1993-09-07
    • Brief Description: This patent describes a system and method for prompting a vehicle operator to shift a transmission to neutral. While it deals with gear selection, its focus is on safety reminders for neutral, not automatic direction changes based on steering patterns.
    • Potentially Anticipates: This patent broadly relates to gear selection control. However, it specifically focuses on shifting to neutral, not on automatically changing between drive and reverse based on steering patterns without driver direction input as claimed in US12227184. Therefore, it might be considered for background but does not appear to directly anticipate claims 1 or 13, which are focused on active gear changes based on steering patterns and without operator indication of a direction.
  2. US20110080305A1

    • Full Citation: US20110080305A1, Ford Global Technologies, Llc, "Vehicle Park Assist System and Method for Parking a Vehicle Using Such System"
    • Publication Date: 2011-04-07
    • Priority Date: 2009-10-07
    • Brief Description: This patent describes a vehicle park assist system. Such systems typically guide a driver or even autonomously steer a vehicle into a parking space, often involving shifts between forward and reverse.
    • Potentially Anticipates: This patent is relevant to parking maneuvers involving shifts between drive and reverse. It could potentially anticipate elements of claims 1 and 13 if the "park assist system" includes changing modes based on steering control movements without explicit driver direction input for the shift itself. The claims of US12227184 emphasize changing direction based on "pattern of steering angle movements, without operator indication of a direction" (Abstract), or "based on the steering control" (Claim 1, Claim 13). Existing park assist systems often involve automated steering and gear changes.
  3. US20130110342A1

    • Full Citation: US20130110342A1, Volkswagen Ag, "Method for pulling a vehicle into or out of a parking space and corresponding assistance system and vehicle"
    • Publication Date: 2013-05-02
    • Priority Date: 2010-05-12
    • Brief Description: This patent details a method and assistance system for parking and unparking, which inherently involves coordinated steering and gear changes.
    • Potentially Anticipates: Similar to US20110080305A1, this patent, by addressing methods for pulling a vehicle out of a parking space, would likely involve transitions between reverse and drive with associated steering. If these transitions are determined by the system based on steering patterns, rather than explicit directional input from the driver for each shift, it could potentially anticipate claims 1 and 13.
  4. US20130144492A1

    • Full Citation: US20130144492A1, Teruhisa Takano, "Parking mode selection apparatus and method"
    • Publication Date: 2013-06-06
    • Priority Date: 2010-06-09
    • Brief Description: This patent describes an apparatus and method for selecting a parking mode. This would involve logic for determining the type of parking maneuver and coordinating vehicle controls.
    • Potentially Anticipates: While focused on "parking mode selection," the underlying control for executing a parking maneuver could involve automated gear shifts based on steering. Therefore, it might anticipate claims 1 and 13 if it discloses changing drive modes based on steering control without driver direction input.
  5. US20130184979A1

    • Full Citation: US20130184979A1, International Business Machines Corporation, "Method and System for Detection of Motor Vehicle Movement to Avoid Collisions"
    • Publication Date: 2013-07-18
    • Priority Date: 2012-01-18
    • Brief Description: This patent describes a system for detecting motor vehicle movement to avoid collisions. While important for vehicle operation, its primary focus is on collision avoidance, not the primary mechanism of automatic gear selection based on steering patterns.
    • Potentially Anticipates: This patent is less directly related to the core innovation of US12227184 (automatic gear selection based on steering patterns). It's more about safety and collision avoidance during movement. It's unlikely to anticipate claims 1 or 13 directly in terms of the gear selection mechanism itself, though such a system might operate in conjunction with a gear selection system.
  6. US9085321B2

    • Full Citation: US9085321B2, Mando Corporation, "Unparking control system and unparking control method using the same"
    • Publication Date: 2015-07-21
    • Priority Date: 2013-01-17
    • Brief Description: This patent describes an unparking control system and method. Unparking inherently involves maneuvers that typically require switching between reverse and drive, and coordinated steering.
    • Potentially Anticipates: This is highly relevant as it explicitly deals with "unparking control." Unparking maneuvers, as described in US12227184, involve backing out (reverse), steering, stopping, shifting to drive, and steering in the opposite direction. If US9085321B2 describes a system that automates the gear change from reverse to drive based on observed steering patterns during the unparking process, without the driver explicitly selecting the drive direction, then it would directly anticipate claims 1 and 13.
  7. US9219887B2

    • Full Citation: US9219887B2, Aisin Seiki Kabushiki Kaisha, "Drive assist device"
    • Publication Date: 2015-12-22
    • Priority Date: 2010-09-21
    • Brief Description: This patent describes a drive assist device, which is a broad category. Details would be needed to assess its specific relevance.
    • Potentially Anticipates: The general nature of a "drive assist device" makes it difficult to definitively assess anticipation without further detail. If this device specifically includes automated gear changes based on steering patterns during low-speed maneuvers like parking/unparking, it could anticipate claims 1 and 13.
  8. US20160075329A1

    • Full Citation: US20160075329A1, Toyota Jidosha Kabushiki Kaisha, "Parking assist system and path determination method"
    • Publication Date: 2016-03-17
    • Priority Date: 2014-09-12
    • Brief Description: This patent covers a parking assist system and a method for determining the parking path. This system would involve controlling both steering and propulsion during parking maneuvers.
    • Potentially Anticipates: This is highly relevant, similar to other parking assist systems. If the system's path determination and execution involve automatic gear shifts between drive and reverse based on the steering trajectory or pattern, without explicit driver input for the direction of each shift, it could anticipate claims 1 and 13.
  9. US9381922B2

    • Full Citation: US9381922B2, Ford Global Technologies, Llc, "Detection of parking maneuver in a motor vehicle"
    • Publication Date: 2016-07-05
    • Priority Date: 2014-01-16
    • Brief Description: This patent focuses on detecting a parking maneuver. This detection is a prerequisite for any automated parking or unparking assistance.
    • Potentially Anticipates: This patent is foundational for automated parking/unparking, but by itself, "detection of parking maneuver" does not directly anticipate the method of changing gears based on steering patterns. However, if the patent further describes how this detection then triggers automated gear changes based on steering, it could become highly relevant to claims 1 and 13.
  10. US20200207334A1

    • Full Citation: US20200207334A1, Hyundai Motor Company, "System, method, infrastructure, and vehicle for automated valet parking"
    • Publication Date: 2020-07-02
    • Priority Date: 2018-12-27
    • Brief Description: This patent describes a comprehensive system for automated valet parking. Such a system would involve extensive automation of driving, including gear selection and steering.
    • Potentially Anticipates: Automated valet parking systems inherently involve the vehicle managing its own gear shifts and steering to navigate parking spaces. If this patent's "automated valet parking" system includes changing drive modes based on patterns of steering control movements without direct driver input for the gear direction, it would very strongly anticipate claims 1 and 13.
  11. US20200404192A1

    • Full Citation: US20200404192A1, Panasonic Intellectual Property Management Co., Ltd., "Vehicle-mounted device"
    • Publication Date: 2020-12-24
    • Priority Date: 2018-03-09
    • Brief Description: This broadly titled patent would require more detail to assess its specific relevance.
    • Potentially Anticipates: Without a more specific description, it is difficult to determine if this "vehicle-mounted device" anticipates claims 1 or 13. Its relevance would depend on whether it describes an automated gear selection mechanism based on steering patterns.
  12. US11001301B2

    • Full Citation: US11001301B2, Valeo Schalter Und Sensoren Gmbh, "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"
    • Publication Date: 2021-05-11
    • Priority Date: 2016-01-21
    • Brief Description: This patent describes a method for semi-autonomous unparking. Similar to unparking control systems, this would involve automated steering and gear changes.
    • Potentially Anticipates: This patent is highly relevant as it describes a method for "moving a motor vehicle out of a parking space with at least semi-autonomous manoeuvring." If this semi-autonomous maneuvering involves the system changing between reverse and drive modes based on steering control movements (i.e., patterns of steering) without the driver explicitly indicating the direction of the gear shift, it would directly anticipate claims 1 and 13.
  13. US20210269019A1

    • Full Citation: US20210269019A1, Bayerische Motoren Werke Aktiengesellschaft, "Parking Assistance System for Automated Pulling-Out of a Longitudinal Parking Space With a Reversing Move as the Last Pulling-Out Move"
    • Publication Date: 2021-09-02
    • Priority Date: 2018-06-19
    • Brief Description: This patent describes a parking assistance system specifically for automated pulling out of a longitudinal (parallel) parking space.
    • Potentially Anticipates: This is very pertinent. Automated pulling-out from a parking space would almost certainly involve coordinated steering and gear changes (e.g., from drive to reverse and back to drive). If the system performs these gear changes based on steering inputs without requiring explicit driver directional input for each shift, it would anticipate claims 1 and 13.
  14. US20210300349A1

    • Full Citation: US20210300349A1, Honda Motor Co., Ltd., "Vehicle movement assist system"
    • Publication Date: 2021-09-30
    • Priority Date: 2020-03-31
    • Brief Description: This patent broadly covers a vehicle movement assist system.
    • Potentially Anticipates: Similar to other broad "assist system" patents, specific details are needed. If the system includes automated gear changes triggered by steering patterns during parking or unparking maneuvers, it could anticipate claims 1 and 13.
  15. US11623636B2

    • Full Citation: US11623636B2, Honda Motor Co., Ltd., "Display device for vehicle and parking assist system"
    • Publication Date: 2023-04-11
    • Priority Date: 2019-12-13
    • Brief Description: This patent focuses on a display device for a vehicle and a parking assist system. The display aspect is less directly relevant to the gear selection mechanism itself, but the parking assist system could be.
    • Potentially Anticipates: The parking assist system component could be relevant if it automates gear changes based on steering. The focus on the "display device" itself doesn't directly address the gear change mechanism of claims 1 and 13.
  16. US20240051558A1

    • Full Citation: US20240051558A1, Tesla, Inc., "Automated adjustment of vehicle direction based on environment analysis"
    • Publication Date: 2024-02-15
    • Priority Date: 2022-08-12
    • Brief Description: This patent, from Tesla, describes automated adjustment of vehicle direction based on environment analysis. Tesla vehicles are known for advanced driver-assist features including auto-parking and "smart summon," which involve autonomous control of direction and gear.
    • Potentially Anticipates: This is highly relevant. Tesla's known auto-shift features, as mentioned in the "Non-Patent Citations" (e.g., Elon Musk explaining Auto Shift), directly relate to automated gear changes. If this patent describes changing drive modes (e.g., drive to reverse or vice versa) based on the vehicle's environmental analysis and resulting steering adjustments, without explicit driver directional input for the gear shift, it would strongly anticipate claims 1 and 13.
  17. US11932230B1

    • Full Citation: US11932230B1, Bulletproof Property Management, Llc, "Vehicle gear selection control"
    • Publication Date: 2024-03-19
    • Priority Date: 2023-06-05
    • Brief Description: This patent is from the same assignee and has the same title as US12227184. The description within US12227184 states it is a continuation-in-part of US Patent Application Ser. No. 18/205,823 filed on Jun. 5, 2023, which issued as U.S. Pat. No. 11,932,230. This means it is a related patent from the same patent family and is therefore highly relevant.
    • Potentially Anticipates: As a direct parent or family member patent, US11932230B1 is highly likely to contain very similar or identical subject matter to US12227184. It is probable that many, if not all, of the independent and dependent claims of US12227184 could be anticipated by the disclosures in US11932230B1 under 35 U.S.C. § 102, assuming the claims of US12227184 are not sufficiently distinct or further limited. The claims are likely to be a continuation or refinement of the concepts in the earlier patent.
  18. US12049217B2

    • Full Citation: US12049217B2, Toyota Jidosha Kabushiki Kaisha, "Parking support device"
    • Publication Date: 2024-07-30
    • Priority Date: 2021-08-31
    • Brief Description: This patent describes a parking support device, implying assistance with parking maneuvers.
    • Potentially Anticipates: Similar to other parking assist/support patents, if this device automates gear changes based on steering control or patterns during parking, without explicit driver directional input for each shift, it could anticipate claims 1 and 13.
  19. US12084047B2

    • Full Citation: US12084047B2, Toyota Jidosha Kabushiki Kaisha, "Vehicle driving assist system"
    • Publication Date: 2024-09-10
    • Priority Date: 2021-10-22
    • Brief Description: This patent covers a vehicle driving assist system.
    • Potentially Anticipates: Without specific details, it's hard to assess. If the driving assist system incorporates automatic gear changes based on steering patterns in relevant driving scenarios (like parking/unparking), it could anticipate claims 1 and 13.
  20. US12151677B2

    • Full Citation: US12151677B2, Sony Group Corporation, "Vehicle control device, vehicle control method, program, and vehicle"
    • Publication Date: 2024-11-26
    • Priority Date: 2018-12-20
    • Brief Description: This patent describes a vehicle control device, method, program, and vehicle. This broad scope could encompass various aspects of vehicle control.
    • Potentially Anticipates: The general nature of a "vehicle control device" requires more detail. If it outlines a method or system for automatically changing gear modes based on steering patterns, it could anticipate claims 1 and 13.

In summary, the patents most likely to anticipate claims 1 and 13 of US12227184 are those specifically dealing with:

  • Automated or semi-automated parking/unparking systems: US20110080305A1, US20130110342A1, US9085321B2, US20160075329A1, US20200207334A1, US11001301B2, US20210269019A1, US12049217B2. These systems inherently involve coordinated steering and gear changes.
  • Systems explicitly mentioning "auto-shift" or automated direction adjustment based on environment: US20240051558A1 (Tesla).
  • Thematically related patents from the same assignee and family: US11932230B1 is a strong candidate for anticipating all claims due to its close relationship as a parent/family member.

The core novelty of US12227184, as stated in the independent claims, is changing drive mode "based on the steering control" or "in response to a pattern of steering angle movements, without operator indication of a direction." Any prior art that explicitly discloses this mechanism in the context of shifting between drive and reverse modes would be highly anticipatory. The details of the "pattern of steering angle movements" and the "without operator indication of a direction" aspects would be critical in a full anticipation analysis.

Generated 5/28/2026, 12:48:56 PM

Obviousness

Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.

✓ Generated

Obviousness Analysis under 35 U.S.C. § 103

To determine obviousness under 35 U.S.C. § 103, the analysis considers whether the differences between the claimed invention and the prior art would have been obvious to a person having ordinary skill in the art (PHOSITA) at the time of the invention. This requires identifying a motivation to combine prior art references and a reasonable expectation of success.

The core of US patent 12227184 lies in a vehicle's drive system or controller automatically changing between drive and reverse modes based on steering control input, without explicit driver direction indication, particularly during parking/unparking maneuvers.

Combinations of Prior Art and Rationale for Obviousness:

Combination 1: US20110080305A1 (Ford Global Technologies) + US9085321B2 (Mando Corporation) + US20240051558A1 (Tesla, Inc.) / Tesla's "Auto Shift" feature as described by Elon Musk.

  • US20110080305A1 (Ford Global Technologies - "Vehicle Park Assist System and Method for Parking a Vehicle Using Such System"): This patent application describes a park assist system that identifies parking spaces, calculates a trajectory, and takes over steering to maneuver the vehicle into the space. It explicitly states that "During operation, the driver still shifts the transmission and operates the gas and brake pedals." This reference establishes a system for automated steering during parking maneuvers.

  • US9085321B2 (Mando Corporation - "Unparking control system and unparking control method using the same"): This patent focuses on an unparking control system that can safely, conveniently, and quickly unpark a vehicle. It describes a system that determines an initial unparking direction and whether to perform steering control, generating a steering control signal to reach an unparking target value after a gear change is made.

  • US20240051558A1 (Tesla, Inc. - "Automated adjustment of vehicle direction based on environment analysis") / Tesla's "Auto Shift" feature: Tesla's "Auto Shift" feature, as described by Elon Musk, uses sensors to automatically select a driving gear (Drive, Park, Neutral, or Reverse) based on surroundings, context, and navigation data, eliminating the need for a gear shifter stalk. The system can detect obstacles, such as a garage wall in front, and automatically shift to reverse once the driver presses the brake pedal. This feature also learns driver patterns and can be geocoded to specific locations, adapting to user needs over time. While drivers can override the selected gear via the touchscreen, the core idea is automated gear selection without explicit directional input from the driver.

  • Motivation to Combine: A PHOSITA would be motivated to combine these references to enhance the user experience and convenience of existing parking and unparking assist systems.

    • US20110080305A1 and US9085321B2 demonstrate the prior art's capability to automate steering during parking and unparking, respectively. However, both still require driver input for gear selection.
    • Tesla's "Auto Shift" feature directly addresses the issue of manual gear selection by automatically determining the intended drive mode based on sensor input and environmental context.
    • The motivation would be to integrate the automated gear selection (from Tesla's "Auto Shift") into existing parking/unparking assist systems (like those from Ford and Mando) to create a more seamless and less distracting user experience, especially during maneuvers that frequently require shifting between drive and reverse, such as parallel parking or backing out of a spot. Elon Musk himself articulated a general principle that "all input is error" and that the car should handle tasks it can do, indicating a clear desire in the art to minimize driver input for convenience and safety.
  • Reasoning for Obviousness: It would have been obvious for a PHOSITA to combine the automated steering capabilities of US20110080305A1 and US9085321B2 with the automatic gear selection mechanism of Tesla's "Auto Shift" feature. The explicit need for a driver to "shift the transmission" in older park assist systems highlights an area ripe for automation. The Tesla system's ability to "automatically select a driving gear when you are ready to drive" based on "inputs from various sensors" and "what obstacles it sees, context & nav map" directly provides the missing element for fully automating parking and unparking gear changes. The concept of using steering patterns as a cue for gear changes, as claimed in US12227184, is a logical extension or a specific implementation of "inputs from various sensors" and "context" used by Tesla's system to determine the intended drive mode. For instance, the detailed description of US12227184 explains that "reversing the steering angle when slowing or after stopping is the final signal preferably to verify the appropriateness of an auto-shift offer." This specific pattern of steering input, combined with vehicle speed, could be readily inferred by an AI system trained on driver behavior, as described in US12227184, and would align with the "network-learned behavior patterns" and "confident commonalities of circumstances" that Tesla's AI would learn for its auto-shift function.

Combination 2: US20130110342A1 (Volkswagen AG) + US20210300349A1 (Honda Motor Co., Ltd.)

  • US20130110342A1 (Volkswagen AG - "Method for pulling a vehicle into or out of a parking space and corresponding assistance system and vehicle"): This patent describes methods and systems for assisting a vehicle into or out of a parking space. Volkswagen's Park Assist system uses ultrasonic sensors and automated steering to guide a vehicle into parallel and perpendicular spaces, with the driver controlling the accelerator, brake, and gear selection. The system prompts the driver to shift into the recommended gear, typically reverse, and then the vehicle handles the steering automatically.

  • US20210300349A1 (Honda Motor Co., Ltd. - "Vehicle movement assist system"): While this patent is not fully detailed in the provided snippets, Honda's broader "Honda Sensing" suite includes advanced driver assistance systems that utilize sensors (like cameras and radar) to improve situational awareness and, in certain circumstances, intervene to avoid collisions. More generally, vehicle movement assist systems often interpret driver intent through various inputs. Honda's Motion Management System, for instance, uses driver steering input and vehicle speed data to control braking and assist with steering.

  • Motivation to Combine: A PHOSITA would be motivated to combine the advanced parking assistance of Volkswagen with existing driver assist systems that infer driver intent or intervene based on vehicle dynamics. The Volkswagen system explicitly requires the driver to make gear selections. The general trend in automotive technology, as evidenced by features like Tesla's Auto Shift, is to reduce explicit driver input for common maneuvers. Therefore, a motivation exists to automate the gear shifting step in Volkswagen's parking assist system.

  • Reasoning for Obviousness: It would have been obvious to integrate an automated gear selection based on sensed vehicle parameters, such as steering input and speed, into Volkswagen's parking assist system. Given that parking assist systems already automate steering based on environmental sensing, extending this automation to gear selection based on the pattern of steering and speed (which are already monitored by such systems, as indicated in US12227184's description of "unparking" sequences in FIG. 2) would be a natural progression. For example, if the vehicle is performing a steering maneuver characteristic of backing out of a parking space (as described in FIG. 2 of US12227184, involving initial straight reverse, then sharp steering, then stopping and changing steering direction), and the speed is low or zero, a PHOSITA would recognize that an automated shift from reverse to drive would be highly desirable and predictable. The "vehicle movement assist system" of Honda, even if not specifically detailing gear shifts, reflects the industry's focus on comprehensive driver assistance and intervention based on vehicle and environmental data.

General Obviousness Considerations:

  • Predictable Result: Automating gear shifts during parking/unparking based on steering patterns provides a predictable result: reduced driver distraction and increased convenience, which are common goals in automotive advancements.
  • Design Choice/Routine Optimization: The specific "pattern of steering angle movements" mentioned in the claims could be seen as a design choice or routine optimization for inferring driver intent in the context of parking maneuvers, building on existing sensor data (steering angle, speed, position) already used by parking assist systems.
  • PHOSITA: A person having ordinary skill in the art in this field would likely be an automotive engineer with experience in vehicle control systems, sensor integration, and driver assistance technologies, and would be aware of the desire to reduce driver workload during routine maneuvers. Such a person would recognize the synergy of combining automated steering with automated gear selection.
  • Secondary Considerations: While US12227184 notes the patent is active and subject to litigation, no specific information regarding secondary considerations (e.g., commercial success, long-felt need, failure of others, unexpected results) has been provided in the prompt to support non-obviousness.

Generated 5/28/2026, 12:49:08 PM

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