DCT

1:25-cv-00067

Kohree v. RVLock & Co

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: Kohree LLC, et al. v. RVLock & Co., LLC, 1:25-cv-00067, D. Utah, 08/12/2025
  • Venue Allegations: Venue is alleged to be proper in the District of Utah because Defendant RVLock has its headquarters and a regular and established place of business within the district.
  • Core Dispute: Plaintiffs seek a declaratory judgment that their RV door lock products do not infringe Defendant's patents related to electronic and mechanical lock assemblies, which Defendant has asserted against them in complaints filed with Amazon.
  • Technical Context: The technology concerns integrated lock assemblies for recreational vehicles (RVs) that combine a traditional paddle handle, a mechanical key lock, a deadbolt, and an electronic keypad for multiple modes of operation.
  • Key Procedural History: The action was initiated in response to Defendant's patent infringement complaints submitted to Amazon's Patent Evaluation Express (“APEX”) process, which resulted in the removal of Plaintiffs' product listings. The complaint alleges that Defendant has misused the APEX process and has filed counterclaims in the action alleging infringement of at least one of the patents-in-suit.

Case Timeline

Date Event
2008-12-22 Earliest Priority Date for ’919 and ’767 Patents
2015-07-21 U.S. Patent No. 9,085,919 Issues
2018-04-10 U.S. Patent No. 9,940,767 Issues
2025-04-21 Defendant files Amazon complaint against Plaintiff XPORTION-DIRECT
2025-04-22 Defendant files Amazon complaints against Plaintiffs YSSKTCTIME and KAW
2025-04-29 Defendant files Amazon complaint against Plaintiff Kohree
2025-06-11 Defendant files Amazon complaint against Plaintiff AOTWSEN
2025-06-12 Defendant files another Amazon complaint against Plaintiff AOTWSEN
2025-08-12 Plaintiffs file Amended Complaint for Declaratory Judgment

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 9,085,919 - “Touch Pad Lock Assembly”

  • Patent Identification: U.S. Patent No. 9,085,919, “Touch Pad Lock Assembly,” issued July 21, 2015 (’919 Patent).

The Invention Explained

  • Problem Addressed: The patent describes prior art paddle handle assemblies for vehicles like RVs as having drawbacks, including reliance on manual key locks, not being adapted for remote electronic operation, experiencing alignment problems between the deadbolt and strike, and having complicated constructions that are expensive and difficult to repair (’919 Patent, col. 1:47-64).
  • The Patented Solution: The invention is an integrated lock assembly that combines multiple actuation methods. It features an external handle, a latch, a key lock, a deadbolt, a motor, and an electronic touchpad. These mechanical and electronic components are operably linked, allowing the deadbolt to be locked or unlocked either mechanically with a key or electronically by entering a code on the touchpad (’919 Patent, Abstract; col. 2:1-30). Figure 9 illustrates the internal linkages connecting the lock cam (74), motor (86), and deadbolt (80) (’919 Patent, Fig. 9).
  • Technical Importance: The invention provided a unified, self-contained locking system for the RV market that offered the convenience of keyless entry while retaining traditional mechanical overrides (’919 Patent, col. 1:52-56).

Key Claims at a Glance

  • The complaint identifies independent claim 1 as representative (Compl. ¶33).
  • Essential elements of Claim 1 include:
    • a housing;
    • an external handle pivotally mounted on the housing;
    • a latch operably connected with the handle;
    • a key lock mounted on the housing;
    • a rotatable lock cam connected to the key lock and having a crank arm;
    • a first link operably connected with the lock cam crank arm;
    • a deadbolt lock movably mounted in the housing;
    • the deadbolt lock being operably connected with the first link;
    • a motor operatively connected with the first link; and
    • an electronic touchpad operatively connected with the motor to actuate it and shift the deadbolt.
  • The complaint seeks a judgment of non-infringement for all claims of the patent, which would include any dependent claims (Compl. ¶35).

U.S. Patent No. 9,940,767 - “Touch Pad Lock Assembly”

  • Patent Identification: U.S. Patent No. 9,940,767, “Touch Pad Lock Assembly,” issued April 10, 2018 (’767 Patent).

The Invention Explained

  • Problem Addressed: The ’767 Patent addresses the same technical problems as the ’919 Patent, citing drawbacks in prior art RV paddle handle assemblies related to manual actuation, lack of remote operation capabilities, and complex, expensive designs (’767 Patent, col. 1:40-63).
  • The Patented Solution: The patent describes a similar integrated lock assembly comprising a housing, handle, latch, key lock, deadbolt, and a "computer input device" (e.g., keypad). The solution focuses on the specific arrangement of mechanical linkages, including a "first link" connecting a lock cam to a motor and the deadbolt, to enable both manual and electronic operation (’767 Patent, Abstract; col. 2:1-30). This patent appears to disclose and claim refinements to the electromechanical system of the ’919 Patent.
  • Technical Importance: This technology represents continued innovation in providing convenient, multi-modal, and secure locking systems for the RV and motor home industry (’767 Patent, col. 1:44-56).

Key Claims at a Glance

  • The complaint identifies independent claim 14 as representative (Compl. ¶34).
  • Essential elements of Claim 14 include:
    • a housing with exterior and interior plates;
    • a handle pivotally mounted on the exterior plate;
    • a latch plunger operably connected with the handle;
    • a key lock mounted on the exterior plate;
    • a lock cam rotatably mounted in the housing, connected to the key lock, and having a crank arm;
    • a first link operably connected with the crank arm;
    • a deadbolt lock movably mounted in the housing;
    • the deadbolt lock being operably connected with the first link;
    • a motor operatively connected with the first link; and
    • a computer input device operatively connected with the motor to actuate it and shift the deadbolt.
  • The complaint seeks a judgment of non-infringement for all claims of the patent, including any dependent claims (Compl. ¶35).

III. The Accused Instrumentality

Product Identification

  • The "Accused Locks" are various models of RV door locks sold by the Plaintiffs on Amazon, including those under the storefronts Kohree, YSSKTCTIME, XPORTION-DIRECT, KAW, and AOTWSEN (Compl. ¶¶18, 20, 22, 24, 26).

Functionality and Market Context

  • The complaint alleges the Accused Locks are RV door lock products imported, marketed, and sold in the United States by Plaintiffs (Compl. ¶1). Visual evidence provided in the complaint shows the Accused Locks feature an external handle, a keyhole, and a numerical keypad for entry. One image shows a lock with a key fob and a smartphone, suggesting capabilities for remote or Bluetooth operation (Compl., p. 7, Illustration 2). The complaint asserts that Plaintiffs have earned "significant reputation and customer recognition" for these products on Amazon and that Defendant's actions have caused Plaintiffs to suffer a loss of sales and market share (Compl. ¶¶18, 29). The complaint does not provide technical details on the internal mechanics of the Accused Locks.

IV. Analysis of Infringement Allegations

The complaint pleads for a declaratory judgment of non-infringement, alleging that the Accused Locks are missing several elements required by the asserted claims.

’919 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
(c) a latch operably connected with the external handle and configured such that... The complaint alleges the Accused Locks do not include this feature. ¶35 col. 2:5-15
(e) a lock cam rotatably mounted in the housing and operably connected with the key lock for rotation therewith, the lock cam having a lock cam crank arm; The complaint alleges the Accused Locks do not include this feature. ¶35 col. 2:15-18
(f) a first link operably connected with the lock cam crank arm; The complaint alleges the Accused Locks do not include this feature. ¶35 col. 2:17-18
(h) the deadbolt lock being operably connected with the first link; The complaint alleges the Accused Locks do not include this feature. ¶35 col. 2:23-24
(i) a motor having a locked and unlocked position operatively connected with the first link; The complaint alleges the Accused Locks do not include this feature. ¶35 col. 2:24-26

’767 Patent Infringement Allegations

Claim Element (from Independent Claim 14) Alleged Infringing Functionality Complaint Citation Patent Citation
(c) a latch plunger operably connected with the handle, and configured such that... The complaint alleges the Accused Locks do not include this feature. ¶35 col. 4:2-10
(e) a lock cam rotatably mounted in the housing and operably connected with the key lock for rotation therewith, the lock cam having a crank arm; The complaint alleges the Accused Locks do not include this feature. ¶35 col. 4:13-16
(f) a first link operably connected with the crank arm; The complaint alleges the Accused Locks do not include this feature. ¶35 col. 4:17-18
(h) the deadbolt lock being operably connected with the first link; The complaint alleges the Accused Locks do not include this feature. ¶35 col. 4:22-23
(i) a motor operatively connected with the first link; The complaint alleges the Accused Locks do not include this feature. ¶35 col. 4:24
  • Identified Points of Contention:
    • Scope Questions: The complaint's non-infringement theory rests on the alleged absence of the entire claimed mechanical linkage system between the key lock, motor, and deadbolt, including the "lock cam," "crank arm," and "first link" (Compl. ¶35). This raises the question of whether any alternative mechanism in the Accused Locks for actuating the deadbolt could be considered structurally or functionally equivalent to the claimed linkage system.
    • Technical Questions: The complaint makes conclusory allegations that certain claim elements are missing without providing any technical details about the internal construction of the Accused Locks. A central evidentiary question will be what mechanism the Accused Locks actually use to translate motor rotation and key turns into deadbolt movement, and how that mechanism compares to the one claimed in the patents. An image of an "Exemplary Accused Kohree Locks" shows a numerical keypad and keyhole (Compl., p. 6, Illustration 1).

V. Key Claim Terms for Construction

  • The Term: "operably connected"
  • Context and Importance: This term appears repeatedly in the asserted claims to define the relationship between key mechanical components (e.g., "latch operably connected with the external handle," "deadbolt lock being operably connected with the first link") (’919 Patent, Claim 1; ’767 Patent, Claim 14). Plaintiffs' non-infringement case is built on the assertion that the Accused Locks lack these specific connections (Compl. ¶35). The scope of this term will therefore be critical; a narrow, structurally-limited definition may support non-infringement, whereas a broader, purely functional definition may favor the patentee.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patents use the term functionally to describe how one component's action affects another. For instance, the specification states that the latch plunger is configured such that movement of the handle causes the latch to move between latched and unlatched positions, defining the "operable connection" by its result (’919 Patent, col. 2:5-15).
    • Evidence for a Narrower Interpretation: The detailed description and figures disclose a very specific mechanical arrangement to achieve the claimed connections. For example, the connection between the deadbolt and the "first link" is shown as a direct pivotal connection between "first link 83" and the "inner end 82 of deadbolt 80" (’919 Patent, col. 9:34-39; Fig. 9). Parties may argue that "operably connected" should be construed in light of these specific disclosed embodiments, limiting the term to the types of direct mechanical linkages shown.

VI. Other Allegations

  • Indirect Infringement: The complaint states that Plaintiffs "do not directly or indirectly infringe" the patents-in-suit (Compl. ¶¶33-34). No facts are alleged by Plaintiffs that would support a claim for indirect infringement.

VII. Analyst’s Conclusion: Key Questions for the Case

  • A core issue will be one of technical fact-finding: What is the actual internal mechanism of the Accused Locks? The complaint’s non-infringement allegations are conclusory and lack technical support. The case will likely depend on a detailed comparison, developed through discovery, between the physical structure of the accused products and the specific mechanical linkages required by the claims.
  • A key legal question will be one of claim scope: How broadly will the term "operably connected" be construed? The dispute may turn on whether this term is limited to the specific system of cams, crank arms, and physical links disclosed in the patents' embodiments, or if it can be interpreted more functionally to cover any mechanism by which the motor and key lock cause the deadbolt to move.
  • A procedural question concerns the propriety of enforcement: Did Defendant's use of the Amazon APEX process, which prompted this lawsuit, constitute an abuse of that system or patent misuse? While separate from the infringement analysis, the complaint's allegations regarding Defendant's conduct may influence the broader dynamics of the litigation (Compl. ¶¶16-17, 28).