Kohree v. RVLock & Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Kohree LLC (North Carolina); Shenzhen Time Fortress Technology Co., Ltd. (China); ningboyikemosigongyinglianyouxiangongsi (China); Dongguanshixinggankejiyouxiangongsi (China); and Dongguan Zhantai Metal Products Co., Ltd. (China)
  • Defendant: RVLock & Co., LLC (Utah)
  • Plaintiff's Counsel: Ray Quinney & Nebeker P.C.; Youngzeal LLP
• Case Identification: 1:25-cv-00067, D. Utah, 09/25/2025
• Venue Allegations: Venue is alleged to be proper in the District of Utah because Defendant RVLock has a regular and established place of business in the district, including offices and employees.
• Core Dispute: Plaintiffs, sellers of recreational vehicle (RV) door locks, seek a declaratory judgment that their products do not infringe Defendant's patents and that the patents are invalid, in response to Defendant's patent infringement complaints submitted to Amazon.com.
• Technical Context: The technology concerns electronic, touchpad-enabled lock assemblies for the doors of recreational vehicles, which combine traditional mechanical paddle handles with keyless entry systems.
• Key Procedural History: This action was filed after Defendant RVLock, which acquired the patents-in-suit in 2023, allegedly submitted infringement complaints against Plaintiffs to Amazon through its Patent Evaluation Express (APEX) program, leading to the delisting of Plaintiffs' products. Plaintiffs allege these complaints are baseless due to fundamental technical differences between the patented and accused devices.

Case Timeline

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 describes drawbacks with prior art RV door locks, including their reliance on manual keys for deadbolts, difficulty integrating with remote-operation systems, and complicated, expensive construction ʼ919 Patent, col. 1:33-59
• The Patented Solution: The invention is a lock assembly that integrates a traditional paddle handle with an electronic deadbolt system ʼ919 Patent, abstract A motor, controlled by an electronic touchpad, actuates the deadbolt through a series of mechanical connections, specifically a "lock cam" with a "crank arm" and a "first link" ʼ919 Patent, col. 2:1-27 ʼ919 Patent, Fig. 10 This design allows for keyless entry while retaining manual operation.
• Technical Importance: The technology aimed to provide the RV market with a more convenient and secure locking system that combined the benefits of electronic access with the familiarity of mechanical paddle handles ʼ919 Patent, col. 1:33-36

Key Claims at a Glance

• The complaint asserts non-infringement of independent claim 1 Compl. ¶48
• Key elements of independent claim 1 include:
  • a housing;
  • an external handle pivotally mounted in the housing;
  • a latch operably connected with the external handle;
  • a key lock mounted on the housing;
  • a lock cam rotatably mounted in the housing and connected to the key lock, the lock cam having a "lock cam crank arm";
  • a "first link" operably connected with the lock cam crank arm;
  • a deadbolt lock operably connected with the first link;
  • a motor operatively connected with the first link; and
  • an electronic touchpad operatively connected with the motor to shift the deadbolt.
• The complaint reserves the right to assert non-infringement of dependent claims Compl. ¶50

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 of the application leading to the ʼ919 Patent, the ʼ767 Patent addresses the same technical problems of providing a robust, electronically-actuated lock for the RV market ʼ767 Patent, col. 1:35-61
• The Patented Solution: The solution is substantively similar to that of the '919 Patent, describing a lock assembly where a motor drives a deadbolt via a mechanical linkage ʼ767 Patent, abstract The core mechanism involves a key lock rotating a lock cam, which in turn moves a link connected to the deadbolt, with a motor also connected to the link for electronic actuation ʼ767 Patent, col. 2:1-30
• Technical Importance: This patent continues the technical approach of the '919 Patent, aiming to secure broader or alternative protection for combining electronic touchpad convenience with the mechanical structure of an RV door lock ʼ767 Patent, col. 1:1-12

Key Claims at a Glance

• The complaint asserts non-infringement of independent claim 14 Compl. ¶49
• Key elements of independent claim 14 include:
  • a housing with an exterior plate and an interior plate;
  • 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 and connected to the key lock, the lock cam having a "crank arm";
  • a "first link" operably connected with the crank arm;
  • a deadbolt lock operably connected with the first link;
  • a motor operatively connected with the first link; and
  • a computer input device (e.g., touchpad) operatively connected with the motor.
• The complaint reserves the right to assert non-infringement of dependent claims Compl. ¶50

III. The Accused Instrumentality

Product Identification

• The "Accused Locks" are various models of RV door locks imported, marketed, and sold by the several Plaintiffs on the Amazon.com platform Compl. ¶1 Compl. ¶¶27-36 The complaint provides images of several exemplary Accused Locks from different Plaintiffs Compl. p. 7, Illustration 1

Functionality and Market Context

• The complaint alleges that the Accused Locks perform the same general function of providing keyless entry for RVs but achieve it through a "fundamentally different" internal mechanism Compl. ¶38 Specifically, Plaintiffs allege their products use a "dual-gear drive configuration" to move the deadbolt and do not employ the "cam-and-linkage" mechanism claimed in the patents-in-suit Compl. ¶38 A side-by-side diagram in the complaint contrasts the patents' claimed mechanism with the accused dual-gear drive Compl. p. 11
• The Accused Locks are sold by multiple independent businesses on Amazon, where Plaintiffs allege they have earned significant reputation and customer recognition Compl. ¶2 Compl. ¶27 Compl. ¶29 The delisting of these products from Amazon following Defendant's infringement assertions is alleged to have caused a loss of sales, market share, and goodwill Compl. ¶45

IV. Analysis of Infringement Allegations

As this is a declaratory judgment action, the analysis reflects the Plaintiffs' asserted grounds for non-infringement.

'919 Patent Infringement Allegations

'767 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: The central dispute appears to hinge on the interpretation of the claim terms describing the deadbolt actuation mechanism. A primary question for the court will be whether the scope of "a lock cam ... having a ... crank arm" and "a first link" can be construed to read on the components of the accused "dual-gear drive configuration" Compl. ¶38
• Technical Questions: What evidence does the complaint provide that the accused "dual-gear drive" is structurally and functionally different from the claimed "cam-and-linkage" mechanism? The complaint provides a comparative diagram purporting to show this difference, which presents a key factual question regarding the operation of the accused devices Compl. p. 11 The analysis may also turn on whether the accused mechanism, if not literally infringing, is an equivalent under the doctrine of equivalents.

V. Key Claim Terms for Construction

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

• Context and Importance: This term is at the core of the non-infringement argument Compl. ¶38 Compl. ¶50 Plaintiffs' position is that their gear-driven system lacks any such component. The construction of this term will be a critical factor in determining literal infringement.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the function of this component as translating rotational motion from the key lock into motion that can shift the deadbolt ʼ919 Patent, col. 8:14-44 A party could argue that any component performing this function meets the definition.
  • Evidence for a Narrower Interpretation: The patent figures depict a specific structure for the "lock cam 74" and its "crank arm 75" ʼ919 Patent, Figs. 9-12 A party could argue that the term should be limited to this disclosed embodiment or structures that are very similar, thereby excluding a system of intermeshing gears.

• The Term: "a first link operably connected with the lock cam crank arm"

• Context and Importance: This element is the connective tissue of the claimed mechanism and is also alleged to be missing from the Accused Locks Compl. ¶50 Its definition is inextricably linked to the "lock cam crank arm" term.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term "link" can be broadly defined as any rigid body that connects other moving parts. A party might argue that a gear tooth or a section of a larger gear assembly functions as a "link."
  • Evidence for a Narrower Interpretation: The specification and figures show the "first link 83" as a distinct, elongated member that pivotally connects the crank arm to the deadbolt mechanism ʼ919 Patent, Fig. 9 This could support a narrower construction that requires a separate, bar-like connecting element, which Plaintiffs allege their gear system lacks.

VI. Other Allegations

The complaint does not provide sufficient detail for analysis of Defendant's specific infringement theories.

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 "link," which describe a specific type of mechanical linkage in the patent's figures, be construed broadly enough to cover the allegedly "fundamentally different" components of the accused "dual-gear drive configuration"? This claim construction dispute will likely be determinative of literal infringement.
• A key evidentiary question will be one of technical and functional comparison: assuming no literal infringement, does the accused dual-gear mechanism perform substantially the same function (actuating the deadbolt), in substantially the same way, to achieve substantially the same result as the claimed cam-and-linkage system? The outcome of this doctrine of equivalents analysis will depend on detailed factual evidence and expert testimony regarding the operation of both systems.