DCT

1:25-cv-00114

Aubes E Commerce v. RVLock & Co

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00114, D. Utah, 12/01/2025
  • Venue Allegations: Venue is based on Defendant RVLock having a regular and established place of business, including offices and employees, within the District of Utah.
  • Core Dispute: Plaintiffs seek a declaratory judgment that their RV door lock products do not infringe Defendant’s patents related to electronic touch pad lock assemblies, and further allege the patents are invalid, in response to Defendant’s patent infringement complaints submitted to Amazon.
  • Technical Context: The technology concerns electronic, keyless lock assemblies for recreational vehicle (RV) doors, a market where convenience and enhanced security are significant product differentiators.
  • Key Procedural History: The action was initiated in response to Defendant’s use of Amazon’s Patent Evaluation Express (“APEX”) process to have Plaintiffs' product listings removed. The complaint alleges these actions were improper because they leveraged the outcome of an unrelated proceeding against products that are technologically distinct from the patented invention.

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
2025-04-29 RVLock files Amazon complaint against Plaintiff AUBES
2025-07-08 RVLock files Amazon complaint against Plaintiff Qisheng
2025-12-01 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,"* issued July 21, 2015

The Invention Explained

  • Problem Addressed: The patent's background describes drawbacks in prior art RV door locks, including their reliance on manual keys, incompatibility with remote operation, potential for misalignment between the deadbolt and strike, and overly complicated construction (’919 Patent, col. 1:43-59).
  • The Patented Solution: The invention is a lock assembly that integrates an electronic touchpad and a motor with a traditional paddle handle and latch mechanism. The motor actuates the deadbolt through a system comprising a "motor crank arm" and a "first link", allowing for keyless electronic locking and unlocking while retaining manual key and interior knob operation (’919 Patent, Abstract; col. 2:6-26). Figure 9 illustrates the internal linkage connecting the motor to the deadbolt (’919 Patent, Fig. 9).
  • Technical Importance: This design provided a self-contained, keyless entry solution for the RV market, addressing consumer demand for more convenient and technologically advanced security features without requiring external wiring (’919 Patent, col. 13:11-22).

Key Claims at a Glance

  • The complaint asserts non-infringement of independent claim 1 as representative (Compl. ¶38).
  • Essential elements of Claim 1 include:
    • A housing and an external handle.
    • A latch connected to the handle.
    • A key lock mounted on the exterior.
    • A "lock cam" rotatably mounted in the housing, connected to the key lock, and having a "lock cam crank arm".
    • A "first link" operably connected with the lock cam crank arm.
    • A deadbolt lock movably mounted in the housing and operably connected with the "first link".
    • A "motor" operatively connected with the "first link".
    • An electronic touchpad to actuate the motor.
  • The complaint reserves the right to address claims that depend from claim 1 (Compl. ¶39).

U.S. Patent No. 9,940,767 - *"Touch Pad Lock Assembly,"* issued April 10, 2018

The Invention Explained

  • Problem Addressed: As a continuation-in-part, this patent addresses the same technical challenges as the ’919 Patent, namely the limitations of manual RV lock assemblies and the need for a robust, electronically actuated alternative (’767 Patent, col. 1:34-51).
  • The Patented Solution: The ’767 Patent also discloses an integrated electronic lock assembly. Its core mechanism for actuating the deadbolt is consistent with the ’919 Patent, relying on a motor that drives a linkage system, which includes a "crank arm" and a "first link", to move the deadbolt between locked and unlocked positions (’767 Patent, Abstract; col. 2:4-30).
  • Technical Importance: The invention reflects continued development in providing convenient, keyless security systems tailored for the specific requirements of the recreational vehicle market (’767 Patent, col. 1:34-38).

Key Claims at a Glance

  • The complaint asserts non-infringement of independent claim 14 as representative (Compl. ¶45).
  • Essential elements of Claim 14 are substantially similar to Claim 1 of the ’919 Patent, including:
    • A housing with exterior and interior plates.
    • A handle and an associated latch plunger.
    • A key lock mounted on the exterior plate.
    • A "lock cam" rotatably mounted in the housing and having a "crank arm".
    • A "first link" operably connected with the crank arm.
    • A deadbolt lock movably mounted and operably connected with the "first link".
    • A "motor" operatively connected with the "first link".
    • A computer input device (touchpad) to actuate the motor.
  • The complaint reserves the right to address claims that depend from claim 14 (Compl. ¶46).

III. The Accused Instrumentality

Product Identification

  • The "Accused Locks" are various RV door lock products sold on Amazon by the plaintiff entities (Compl. ¶¶ 1, 19, 21, 23, 25, 27). The complaint shows an exemplary exterior view of one such product, the Accused AUBES Lock. (Compl. ¶19, Illustration 1).

Functionality and Market Context

  • The Accused Locks are electronic RV door handles that provide keyless entry via a keypad (Compl. ¶19, Illustration 1). Crucially, the complaint alleges that the internal mechanism of the Accused Locks is "fundamentally different" from that described in the patents-in-suit. Instead of the claimed "cam-and-linkage mechanism," the Accused Locks allegedly "utilize a fundamentally different dual-gear drive configuration to move the deadbolt" (Compl. ¶30). The complaint presents a visual comparison, juxtaposing a patent figure of the claimed linkage against a photograph of the accused dual-gear mechanism to highlight this alleged structural and functional distinction (Compl. p. 11). The complaint alleges that the Plaintiffs have earned significant reputation and customer recognition for these products on the Amazon platform (Compl. ¶¶ 19, 21, 23, 25, 27).

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The analysis below summarizes Plaintiffs' primary non-infringement arguments.

'919 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality (as contended by Plaintiffs) Complaint Citation Patent Citation
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 Accused Locks allegedly do not include a lock cam with a crank arm, instead using a dual-gear drive configuration (Compl. ¶30). ¶39 col. 7:13-17
a first link operably connected with the lock cam crank arm The Accused Locks allegedly do not include a "first link" connected to a crank arm as part of their drive mechanism (Compl. ¶30). ¶39 col. 7:49-53
the deadbolt lock being operably connected with the first link The deadbolt in the Accused Locks is allegedly moved by a gear drive, not by connection to a "first link" (Compl. ¶30). ¶39 col. 7:49-53
a motor having a locked and unlocked position operatively connected with the first link The motor in the Accused Locks allegedly operates a gear system and is not operatively connected with a "first link" (Compl. ¶30). ¶39 col. 7:53-67
  • Identified Points of Contention:
    • Scope Question: A central dispute will be whether the accused "dual-gear drive configuration" falls within the legal scope of the claim terms "lock cam," "lock cam crank arm," and "first link."
    • Technical Question: What evidence does the complaint provide to support the assertion that the dual-gear system is "fundamentally different" from the patented cam-and-linkage system, and does not function as a structural equivalent? The photographic evidence of the gears is Plaintiffs' primary basis for this contention (Compl. p. 11).

'767 Patent Infringement Allegations

Claim Element (from Independent Claim 14) Alleged Infringing Functionality (as contended by Plaintiffs) Complaint Citation Patent Citation
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 Accused Locks allegedly do not include a lock cam with a crank arm, instead utilizing a dual-gear drive system (Compl. ¶30). ¶46 col. 7:15-19
a first link operably connected with the crank arm The Accused Locks allegedly do not contain a "first link" element as described (Compl. ¶30). ¶46 col. 7:51-54
the deadbolt lock being operably connected with the first link The deadbolt is allegedly actuated directly by the gear mechanism, not via a "first link" (Compl. ¶30). ¶46 col. 7:51-54
a motor operatively connected with the first link The motor allegedly drives the gear system and is not connected to a "first link" (Compl. ¶30). ¶46 col. 7:55-60
  • Identified Points of Contention: The points of contention for the ’767 Patent are identical to those for the ’919 Patent, as both turn on the same core technological dispute regarding the difference between a cam-and-linkage mechanism and a dual-gear drive.

V. Key Claim Terms for Construction

  • The Term: "lock cam ... having a ... crank arm"

  • Context and Importance: This terminology is central to the non-infringement case. Plaintiffs allege their dual-gear drive is not a "lock cam" with a "crank arm." The construction of these terms may be dispositive of literal infringement.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes the function of these components as converting rotational motion from the key or motor into linear motion to shift the deadbolt (’919 Patent, col. 8:40-51). Defendant may argue that any structure performing this specific function within the assembly meets the definition.
    • Evidence for a Narrower Interpretation: The patent provides detailed figures showing a specific, non-gear-based structure for the "lock cam" (74) and its associated "crank arm" (75) (’919 Patent, Figs. 11-12). Plaintiffs may argue the claim term is limited to this disclosed embodiment and its structural equivalents, which they contend a gear system is not.

  • The Term: "first link"

  • Context and Importance: This term is also at the heart of the dispute, as Plaintiffs contend their products lack this element entirely (Compl. ¶¶ 30, 39). The definition of what constitutes a "link" in the context of the patent will be critical.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes the "first link" (83) as the component that operably connects the motive force (from the motor crank arm) to the deadbolt (’919 Patent, col. 7:49-53). A defendant could argue that any intermediate connecting element, even a gear tooth or rack, performs this function.
    • Evidence for a Narrower Interpretation: The patent figures depict the "first link" as a distinct, elongated member with two pivot points connecting separate components (’919 Patent, Figs. 9-10). Plaintiffs may argue that a direct gear-to-gear or gear-to-rack engagement does not constitute a "link" in the manner claimed.

VI. Other Allegations

The complaint is for declaratory judgment of non-infringement and invalidity. It does not contain allegations of indirect or willful infringement against the defendant in the traditional patent sense. Instead, it includes counts for tortious interference with business relationships and patent misuse, based on allegations that Defendant knowingly submitted "objectively baseless" complaints to Amazon for an "anti-competitive purpose" (Compl. ¶¶ 65, 69-70).

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

  • A core issue will be one of definitional scope: can the claim terms "lock cam," "crank arm," and "first link," which are described in the patent as a specific type of mechanical linkage, be construed broadly enough to read on the "dual-gear drive configuration" allegedly used in the accused products?
  • A key evidentiary question will be one of technical distinction: what evidence will be required to establish whether the accused dual-gear drive operates in a "fundamentally different" way from the patented linkage system, or if it is merely an equivalent mechanism performing the same function in substantially the same way to achieve the same result?
  • A significant secondary question concerns enforcement conduct: did the defendant’s complaints to Amazon, based on patents for a cam-and-linkage system against products allegedly using a different gear-based mechanism, constitute improper enforcement conduct sufficient to support claims for tortious interference or a finding that the case is exceptional?