DCT

1:25-cv-00114

Aubes E Commerce v. RVLock & Co

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00114, D. Utah, 08/12/2025
  • Venue Allegations: Venue is asserted based on Defendant RVLock & Co., LLC having a regular and established place of business, including offices and employees, within the District of Utah.
  • Core Dispute: Plaintiffs, sellers of recreational vehicle (RV) door locks, seek a declaratory judgment that their products do not infringe a patent owned by Defendant related to electronic and mechanical lock assemblies.
  • Technical Context: The technology concerns integrated lock assemblies for RVs that combine a traditional mechanical handle, latch, and deadbolt with an electronic keypad and motor for keyless entry.
  • Key Procedural History: This declaratory judgment action was filed in response to Defendant's use of the Amazon Patent Evaluation Express (APEX) process to lodge infringement complaints against Plaintiffs' product listings. Plaintiffs allege this conduct creates a justiciable controversy. The patent-in-suit was assigned from its original assignee, Bauer Products, Inc., to Defendant RVLock in September 2023.

Case Timeline

Date Event
2008-12-22 Earliest Priority Date ('’919 Patent)
2009-11-30 Priority Date ('919 Patent)
2011-02-09 Priority Date ('919 Patent)
2012-03-20 Application for '919 Patent Filed
2015-07-21 U.S. Patent No. 9,085,919 Issued
2023-09-12 '919 Patent assignment to Defendant executed
2025-04-29 Defendant files Amazon complaint against Plaintiff AUBES
2025-07-08 Defendant files Amazon complaint against Plaintiff Qisheng
2025-08-12 Complaint for Declaratory Judgment Filed

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.

The Invention Explained

  • Problem Addressed: The patent describes prior art RV "paddle handle assemblies" as having several drawbacks, including requiring separate manual actions for the latch and deadbolt, being difficult to adapt for remote or keyless operation, and having complex constructions that are expensive to manufacture and repair (’919 Patent, col. 1:43-59).
  • The Patented Solution: The invention is a unified lock assembly that integrates multiple modes of operation. It combines a traditional pivoting external handle for operating a latch with both a mechanical key lock and an electronic touchpad-and-motor system for actuating a deadbolt (’919 Patent, Abstract; col. 6:41-52). This design allows the deadbolt to be locked or unlocked either manually with a key or electronically by entering a code, providing enhanced security and convenience (’919 Patent, col. 2:6-26).
  • Technical Importance: The invention addresses the market demand for modernizing RV access systems by integrating keyless entry technology, previously less common in this product category, into the standard paddle handle form factor (’919 Patent, col. 1:49-54).

Key Claims at a Glance

  • The complaint seeks a declaratory judgment of non-infringement with respect to independent claim 1 and its dependent claims (Compl. ¶27).
  • Independent Claim 1 recites a lock assembly with the following essential elements:
    • a housing;
    • a pivotable external handle connected to a latch;
    • a key lock mounted on the housing's exterior;
    • a rotatable "lock cam" connected to the key lock, the lock cam having a "lock cam crank arm";
    • a "first link" connected to the "lock cam crank arm";
    • a movable deadbolt lock;
    • the deadbolt lock being connected to the "first link";
    • a motor that is also connected to the "first link"; and
    • an electronic touchpad connected to the motor to shift the deadbolt.

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are various models of RV door locks sold by the three plaintiffs on the Amazon marketplace, referred to as the "Accused Locks" (Compl. ¶1). Specific products are identified by Amazon Standard Identification Numbers (ASINs) for each plaintiff (Compl. ¶¶ 16, 18, 20).

Functionality and Market Context

  • The Accused Locks are electronic RV door lock assemblies that feature a prominent numerical keypad for keyless entry, a handle, and what appears to be a cylinder for a physical key (Compl. p. 6, Illustration 1). The complaint includes a photograph of the "RUNSAIL" branded lock sold by Plaintiff AUBES, showing its external keypad and handle configuration (Compl. ¶16, Illustration 1). Similar photographs are provided for the "KYX" branded lock sold by Plaintiff Yanshi and a lock sold by Plaintiff Qisheng (Compl. ¶18, Illustration 2; Compl. ¶20, Illustration 3).
  • Plaintiffs allege their products have earned "significant reputation and customer recognition" and that delisting from Amazon results in immediate loss of sales, market share, and product ratings (Compl. ¶¶ 16, 18, 20, 23).

IV. Analysis of Infringement Allegations

'919 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a housing; The main body of the accused lock assembly. ¶¶16, 18, 20; Illustrations 1-3 col. 6:7-8
an external handle pivotally mounted in an exterior portion of the housing for rotation... The handle visible on the exterior of the Accused Locks. ¶¶16, 18, 20; Illustrations 1-3 col. 6:9-13
a latch operably connected with the external handle and configured such that when the external handle is in the retracted position, the latch is in a latched position... Plaintiffs allege this element is not present in the Accused Locks. ¶27 col. 6:14-21
a key lock mounted on the exterior portion of the housing... A keyhole is visible on the exterior of the Accused Locks. ¶¶16, 18, 20; Illustrations 1-3 col. 6:41-43
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; Plaintiffs allege this element is not present in the Accused Locks. ¶27 col. 8:12-17
a first link operably connected with the lock cam crank arm; Plaintiffs allege this element is not present in the Accused Locks. ¶27 col. 8:50-54
a deadbolt lock movably mounted in the housing... The complaint does not provide sufficient detail for analysis of this element. col. 6:41-42
the deadbolt lock being operably connected with the first link; Plaintiffs allege this element is not present in the Accused Locks. ¶27 col. 2:19-20
a motor having a locked and unlocked position operatively connected with the first link; Plaintiffs allege this element is not present in the Accused Locks. ¶27 col. 2:20-22
an electronic touchpad mounted on the exterior portion of the housing being operatively connected with the motor... The numerical keypad on the exterior of the Accused Locks. ¶¶16, 18, 20; Illustrations 1-3 col. 7:11-15

Identified Points of Contention

  • Technical Questions: The core of the non-infringement argument is that the specific internal linkage mechanism recited in claim 1 is absent from the Accused Locks (Compl. ¶27). The complaint asserts a complete break in the claimed mechanical chain connecting the key lock and motor to the deadbolt via the "lock cam", "lock cam crank arm", and "first link". A central evidentiary question will be what internal mechanism the Accused Locks actually use to translate motor and key rotation into deadbolt movement, as the complaint provides no schematics or descriptions of the products' internal workings.
  • Scope Questions: The dispute raises the question of how broadly the term "operably connected with" should be interpreted. If the Accused Locks use a different but functionally analogous linkage system, the outcome may depend on whether that alternative structure can be read on the claim language, either literally or under the doctrine of equivalents.

V. Key Claim Terms for Construction

  • The Term: "lock cam"

    • Context and Importance: This term is a linchpin of the claimed invention's mechanical linkage. Plaintiffs allege the Accused Locks lack this component entirely (Compl. ¶27). Practitioners may focus on this term because its definition—and whether it requires the specific structure shown in the patent—is central to determining if there is a literal absence of the element as Plaintiffs contend.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the "lock cam" in functional terms as a component that is "rotatably mounted in the housing and operably connected with the key lock for rotation therewith" (’919 Patent, col. 2:9-12). This functional language may support an interpretation that covers any component performing that role.
      • Evidence for a Narrower Interpretation: The patent discloses a specific embodiment of the "lock cam 74", detailing its cylindrical base, shaft, and associated crank arm (75) (’919 Patent, Fig. 11-12; col. 8:15-25). A defendant could argue these details confine the term's meaning to a structure possessing these specific features.

  • The Term: "first link"

    • Context and Importance: This is another critical component in the disputed linkage, connecting the "lock cam" and motor to the deadbolt. Its alleged absence is a foundation of Plaintiffs' non-infringement case (Compl. ¶27). The dispute will turn on whether the Accused Locks contain any component that meets the definition of this term.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim describes the component functionally as "a first link operably connected with the lock cam crank arm" (’919 Patent, cl. 1). This language does not, on its face, limit the link's shape or form.
      • Evidence for a Narrower Interpretation: The detailed description shows "first link 83" as a distinct physical part with specific pivot points connecting the motor crank arm (76) and the deadbolt (80) (’919 Patent, Fig. 4; col. 8:49-60). A party could argue that the term should be limited to this disclosed structure or its clear equivalent.

VI. Other Allegations

The complaint does not contain allegations of indirect or willful infringement made by Defendant against Plaintiffs. Instead, as a declaratory judgment action, it focuses on establishing non-infringement. However, Plaintiffs do make allegations regarding Defendant's conduct.

  • Exceptional Case: Plaintiffs request a finding that the case is exceptional under 35 U.S.C. § 285, which would entitle them to attorneys' fees (Compl., Prayer for Relief ¶C). This request appears to be based on allegations that Defendant has engaged in a "deliberate and systematic pattern of conduct by willfully misusing the Amazon Patent Evaluation Express ('APEX') process" to have Plaintiffs' products delisted without a proper basis (Compl. ¶¶ 14-15, 22).

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

  • A core issue will be one of factual proof: what is the actual internal mechanical structure of the Accused Locks? The case hinges on whether discovery reveals a mechanism that includes the specific "lock cam" and "first link" components as claimed, or an entirely different system for actuating the deadbolt.
  • A related key question will be one of claim construction: how narrowly will the court define the terms "lock cam" and "first link"? A narrow construction tied to the patent's specific illustrated embodiments would favor the Plaintiffs' non-infringement position, while a broader, more functional definition could bring a wider range of alternative mechanisms within the scope of the claims.
  • Finally, a significant procedural question will be whether Defendant's alleged "misuse" of the Amazon APEX platform rises to the level of litigation misconduct sufficient to deem the case "exceptional" under 35 U.S.C. § 285, should the Plaintiffs prevail on the merits.