DCT

2:25-cv-00676

Aubes E Commerce v. RVLock & Co

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00676, D. Utah, 08/12/2025
  • Venue Allegations: Venue is alleged to be proper in the District of Utah because Defendant RVLock maintains a regular and established place of business, including offices and employees, within the district.
  • Core Dispute: Plaintiffs seek a declaratory judgment that their electronic recreational vehicle (RV) door locks do not infringe Defendant’s patent, in response to infringement complaints Defendant filed against them on the Amazon marketplace.
  • Technical Context: The technology involves integrated electronic and mechanical lock assemblies for RV doors, which combine keypad entry, a motor-driven deadbolt, and a traditional key and handle mechanisms.
  • Key Procedural History: The action was precipitated by Defendant's use of the Amazon Patent Evaluation Express (APEX) process to allege infringement. Plaintiffs contend that Defendant's complaints on the platform are unsubstantiated and constitute an abuse of the APEX mechanism, creating a justiciable controversy and reasonable apprehension of a lawsuit. The patent-in-suit was assigned to Defendant RVLock from Bauer Products, Inc. in September 2023.

Case Timeline

Date Event
2008-12-22 '919 Patent Priority Date
2015-07-21 '919 Patent Issue Date
2023-09-12 '919 Patent Assignment to Defendant
2025-04-29 Defendant's Amazon complaint against Plaintiff AUBES
2025-07-08 Defendant's Amazon complaint against Plaintiff Qisheng
2025-08-12 Complaint Filing Date

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

  • 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 the need for separate manual actions to operate the latch and deadbolt, a lack of adaptability for remote electronic operation, potential alignment issues, and manufacturing complexity ('919 Patent, col. 1:44-59).
  • The Patented Solution: The invention is an integrated lock assembly that combines an external handle, a key lock, a motor-driven deadbolt, and an electronic touchpad into a single housing. Entry of a numerical code on the touchpad actuates a motor, which is connected via a specific linkage to the deadbolt, allowing for keyless locking and unlocking ('919 Patent, Abstract; col. 8:45-65). This design aims to provide a more convenient and robust locking system for closures like RV doors.
  • Technical Importance: The invention provided an integrated solution that combined the convenience of keyless electronic access with the security of a mechanical deadbolt, addressing a market need for more modern and user-friendly RV locking systems ('919 Patent, col. 1:50-54).

Key Claims at a Glance

  • The complaint seeks a declaratory judgment of non-infringement with respect to Independent Claim 1 (Compl. ¶26).
  • The essential elements of Independent Claim 1 include:
    • a housing
    • an external handle pivotally mounted on the housing
    • a latch connected to the handle that secures a closure
    • a key lock mounted on the housing
    • a rotatable lock cam connected to the key lock, the cam having a crank arm
    • a first link connected to the lock cam crank arm
    • a movable deadbolt lock
    • the deadbolt lock being operably connected with the first link
    • a motor operatively connected with the first link
    • an electronic touchpad connected to the motor to actuate the deadbolt
  • The complaint notes that the Accused Locks do not infringe claims that depend from Claim 1 (Compl. ¶27).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are several models of RV door locks sold by Plaintiffs on the Amazon marketplace, referred to collectively as the "Accused Locks" (Compl. ¶1). These include products identified by specific Amazon Standard Identification Numbers (ASINs) sold by AUBES E-COMMERCE, Shenzhen Yanshi Innovation Technology, and Guangzhou Qisheng Auto (Compl. ¶¶16, 18, 20).

Functionality and Market Context

  • The Accused Locks are electronic RV door lock assemblies that feature a numeric keypad for keyless entry (Compl. ¶¶16-21). Illustration 1 in the complaint shows an exemplary accused lock, which includes a handle, a keypad, and a lock cylinder housed in a single unit (Compl. ¶16, Illustration 1). Plaintiffs allege that these products have earned significant market reputation and customer recognition on the Amazon platform (Compl. ¶¶16, 18, 20).

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement, alleging that the Accused Locks are missing several elements of the asserted claims. The following table summarizes the disputed elements of Claim 1, framing the dispute by outlining what would need to be proven for a finding of infringement alongside the Plaintiff's basis for non-infringement as stated in the complaint.

  • ’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 when the external handle is in the retracted position, the latch is in a latched position...and when the external handle is in the extended position, the latch is in an unlatched position... The accused lock’s external handle is mechanically linked to its latch mechanism, causing the latch to engage or disengage as the handle is operated. Plaintiff alleges this functionality is absent. ¶27 col. 2:2-9
(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 accused lock’s key cylinder is connected to a rotating cam with an attached crank arm that translates the key’s rotation into motion for the locking mechanism. Plaintiff alleges this is absent. ¶27 col. 2:9-14
(f) a first link operably connected with the lock cam crank arm; The accused lock contains a distinct "first link" component that connects the lock cam's crank arm to other parts of the deadbolt mechanism. Plaintiff alleges this link is absent. ¶27 col. 2:14-15
(h) the deadbolt lock being operably connected with the first link; The deadbolt in the accused lock is actuated via the "first link" described in the preceding elements. Plaintiff alleges this connection is absent. ¶27 col. 2:19-20
(i) a motor having a locked and unlocked position operatively connected with the first link; The accused lock's motor drives the deadbolt by acting upon the same "first link" that is connected to the key lock's cam. Plaintiff alleges this connection is absent. ¶27 col. 2:20-22
  • Identified Points of Contention:
    • Technical Questions: The primary dispute appears to be factual and technical: do the Accused Locks contain the specific mechanical linkage recited in Claim 1? The complaint's assertion that elements 1(e), 1(f), 1(h), and 1(i) are all missing suggests that Plaintiffs will argue their products employ a fundamentally different mechanism to connect the key lock and motor to the deadbolt, one that does not use the claimed "lock cam crank arm" or "first link" architecture ('919 Patent, Fig. 4; Compl. ¶27). The case may turn on evidence revealing the internal workings of the Accused Locks.
    • Scope Questions: The dispute over element 1(c), concerning the latch's connection to the handle, raises the question of whether the specific functional behavior described in the claim (e.g., how the latch operates when the handle is "retracted" versus "extended") is present in the accused products. The interpretation of these functional requirements will be critical.

V. Key Claim Terms for Construction

  • The Term: "first link"

  • Context and Importance: This term appears central to the claimed invention's mechanical linkage connecting both the manual key lock and the electronic motor to the deadbolt. Plaintiffs' non-infringement case, as outlined in the complaint, appears to rely heavily on the absence of this specific component (Compl. ¶27). Practitioners may focus on this term because its construction—whether it refers to any force-transferring component or is limited to the specific structure disclosed—could be dispositive of infringement.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The term "link" is a generic mechanical term. The claim language itself does not impose specific structural limitations beyond its operative connections, which may support an interpretation covering any component that performs the linking function.
    • Evidence for a Narrower Interpretation: The specification repeatedly refers to and illustrates a specific component as the "first link 83" (e.g., '919 Patent, Fig. 4, Fig. 9). The detailed description explains its pivotal connections with specificity, such as its "first end 84 thereof pivotally connected with an orifice 90 provided at the inner end 82 of deadbolt 80" ('919 Patent, col. 8:50-54). This detailed disclosure of a particular embodiment could be used to argue for a narrower construction limited to such a structure.

  • The Term: "operably connected"

  • Context and Importance: This term is used multiple times in Claim 1 to define the relationships between the handle, latch, key lock, cam, link, motor, and deadbolt. The required degree of directness or indirectness in these connections will be a key aspect of the infringement analysis for the entire claimed mechanism.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The term itself suggests a functional relationship rather than necessarily requiring direct physical contact, allowing for intermediate components. The summary of the invention describes the connections in broad, functional terms ('919 Patent, col. 2:1-27).
    • Evidence for a Narrower Interpretation: The patent's figures and detailed description illustrate direct, physical, and often pivotal connections between the components claimed to be "operably connected" ('919 Patent, Fig. 4, Fig. 9). An argument could be made that the term, in the context of this patent, requires the type of direct mechanical linkage shown in the preferred embodiments.

VI. Other Allegations

  • Indirect Infringement: The complaint seeks a declaratory judgment that Plaintiffs do not infringe the ’919 Patent either directly or indirectly (Compl. ¶26). It does not, however, plead specific facts relating to indirect infringement, as its purpose is to deny liability on all grounds.

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

This declaratory judgment action appears to center on a focused technical dispute regarding the internal mechanics of the accused RV locks. The outcome will likely depend on the answers to two central questions:

  1. A core issue will be one of claim scope and construction: can the term "first link," as described in the context of a specific mechanical arrangement in the '919 patent, be construed broadly enough to read on the components within the Plaintiffs' accused locks, or is its meaning confined to the specific pivotal linkage disclosed in the patent's embodiments?

  2. A key evidentiary question will be one of technical comparison: what is the actual mechanism used in the Accused Locks to translate motion from the key cylinder and motor to the deadbolt? Discovery revealing the design and operation of the accused products will be critical to determining whether they include the "lock cam crank arm" and "first link" architecture required by Claim 1 or utilize a non-infringing alternative design.