Zhongchengguoda Shenzhen Qiyefazhanyouxiangongsi v. RVLock & Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Zhongchengguoda (Shenzhen) Qiyefazhanyouxiangongsi (People's Republic of China)
  • Defendant: RVLock & Co, LLC (Utah)
  • Plaintiff’s Counsel: FB Law; TronFuture Law PLLC
• Case Identification: 2:26-cv-00132, D. Utah, 02/13/2026
• Venue Allegations: Venue is alleged to be proper in the District of Utah because Defendant RVLock has a regular and established place of business, including offices and employees, within the district.
• Core Dispute: Plaintiff seeks a declaratory judgment that its recreational vehicle (RV) door locks do not infringe Defendant’s patents related to touch pad lock assemblies, and that the patents are invalid, in response to Defendant’s patent infringement complaints filed through Amazon’s marketplace procedures.
• Technical Context: The dispute concerns electronic, keyless entry lock assemblies for vehicles, particularly RVs, which integrate traditional mechanical locks with electronic touchpads and motors for deadbolt actuation.
• Key Procedural History: The complaint alleges that after Defendant’s own patent application for a similar technology was abandoned, it purchased the patents-in-suit from a third party, Bauer Products Inc., in 2023. The present action was precipitated by Defendant’s use of Amazon’s Patent Evaluation Express (APEX) program, which resulted in the removal of Plaintiff’s products from the platform. The complaint also notes that at least two other similar lawsuits involving the same Defendant and patents are pending in the same court.

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 seeks to remedy drawbacks in prior art paddle handle lock assemblies, which often required separate manual actuation for latches and deadbolts, were not adapted for remote or keyless operation, and could have complex and expensive constructions (’919 Patent, col. 1:44-59).
• The Patented Solution: The invention is a lock assembly that integrates a manual key lock, an electronic touchpad, and a motor into a single housing (’919 Patent, abstract). The system is designed so that entry of a code on the touchpad actuates a motor, which in turn drives a deadbolt between locked and unlocked positions via a specific mechanical linkage comprising a crank arm and links (’919 Patent, col. 8:45-67). This allows for electronic control of the deadbolt while retaining traditional manual key and handle functions (’919 Patent, abstract). The arrangement of these mechanical linkages is detailed in figures such as Figure 4 (’919 Patent, Fig. 4).
• Technical Importance: The invention provided a unified electronic and mechanical locking solution for the RV market, combining the security of a deadbolt with the convenience of keyless, touchpad-based entry in a single assembly.

Key Claims at a Glance

• The complaint asserts non-infringement of independent claim 1 Compl. ¶34
• Essential elements of claim 1 include:
  • a housing
  • an external handle
  • a latch operably connected to the handle
  • a key lock
  • a lock cam with a crank arm, connected to the key lock
  • a first link connected to the lock cam crank arm
  • a deadbolt lock
  • the deadbolt lock being connected with the first link
  • a motor operatively connected with the first link
  • an electronic touchpad connected to the motor to actuate it and shift the deadbolt
• The complaint does not explicitly reserve the right to assert dependent claims but seeks a declaration of non-infringement of "any claim" of the patent Compl. ¶42

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 same family as the ’919 Patent, the ’767 Patent addresses the same technical challenges of creating a convenient, integrated, and robust electronic lock assembly for closures like RV doors (’767 Patent, col. 1:32-35).
• The Patented Solution: The ’767 Patent describes a similar solution featuring a housing, handle, latch, key lock, and a computer input device (e.g., a touchpad) to control a motor (’767 Patent, abstract). The core mechanism again relies on the motor actuating the deadbolt through a series of linkages connected to a crank arm, enabling both electronic and manual operation (’767 Patent, col. 9:1-25; ’767 Patent, Fig. 4).
• Technical Importance: This patent builds upon the same technical foundation as the ’919 Patent, providing further protection for an integrated electronic locking system for the vehicle and RV market.

Key Claims at a Glance

• The complaint asserts non-infringement of independent claim 14 Compl. ¶35
• Essential elements of claim 14 are substantially similar to claim 1 of the ’919 Patent and include:
  • a housing with exterior and interior plates
  • a handle
  • a latch plunger
  • a key lock
  • a lock cam with a crank arm
  • a first link connected to the crank arm
  • a deadbolt lock
  • the deadbolt being 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 seeks a declaration of non-infringement of "any claim" of the patent Compl. ¶42

III. The Accused Instrumentality

Product Identification

The accused products are recreational vehicle door locks sold by Plaintiff on Amazon.com, identified in the complaint as the "Accused Locks" Compl. ¶2 Compl. ¶23 An exemplary product listing is identified by ASIN No. B0DZWQ4KM5 Compl. ¶23 An image of the product is provided in the complaint. Compl. p. 6, Illustration 1

Functionality and Market Context

The Accused Locks are alleged to perform a similar overall function as the patented invention—providing keyless entry for RV doors Compl. ¶3 However, the complaint alleges a critical technical difference in the internal mechanism used to actuate the deadbolt. Instead of the "cam-and-linkage mechanism" claimed in the patents, the Accused Locks allegedly utilize a "fundamentally different dual-gear drive configuration" Compl. ¶25 This alleged gear-based mechanism is depicted in a diagram within the complaint Compl. p. 8, Illustration 3 The complaint states that Plaintiff has earned significant reputation and customer recognition for these products on Amazon Compl. ¶23

IV. Analysis of Infringement Allegations

U.S. Patent No. 9,085,919 Infringement Allegations

U.S. Patent No. 9,940,767 Infringement Allegations

Identified Points of Contention

• Scope Questions: The primary dispute appears to center on whether the claim terms "lock cam," "crank arm," and "first link" can be interpreted to read on the "dual-gear drive configuration" allegedly used in the Accused Locks Compl. ¶25 The complaint provides a diagram of the patented cam-and-linkage mechanism to contrast with its gear-driven product Compl. p. 7, Illustration 2
• Technical Questions: A central evidentiary question will be whether the operation of the accused gear drive is technically equivalent to the function, way, and result of the claimed linkage system. The complaint’s characterization of its mechanism as "fundamentally different" suggests Plaintiff will argue against any finding of infringement under the doctrine of equivalents Compl. ¶25 Compl. ¶34 Compl. ¶35

V. Key Claim Terms for Construction

• The Term: "a lock cam ... having a lock cam crank arm" and "a first link operably connected with the lock cam crank arm"
• Context and Importance: These terms define the core mechanical linkage that translates the motor's rotational output into the linear motion of the deadbolt. The entire non-infringement case, as presented in the complaint, rests on the argument that the Accused Locks' dual-gear drive is not such a mechanism Compl. ¶25 Compl. ¶36 The construction of these terms will therefore be dispositive for literal infringement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent specification describes the function of these components in general terms, such as shifting the deadbolt between positions, which could support an argument that the claims cover any mechanism performing that function (’919 Patent, abstract; ’919 Patent, col. 8:61-67).
  • Evidence for a Narrower Interpretation: The complaint highlights specification language that describes the specific linkage as "critical" and "important" to the invention's function (’919 Patent, col. 9:25-49, cited in Compl. ¶37). This language may be used to argue that the patentee defined the invention as being limited to the specific cam-and-linkage embodiment disclosed, potentially disclaiming broader scope and excluding different mechanisms like a gear drive.

VI. Other Allegations

• Indirect Infringement: The complaint seeks a declaratory judgment that Plaintiff does not "directly or indirectly infringe" the patents-in-suit, but provides no specific facts regarding potential allegations of induced or contributory infringement Compl. ¶34 Compl. ¶35
• Tortious Interference: The complaint includes a cause of action for tortious interference with business relationships, alleging that Defendant knew its infringement complaints to Amazon were "objectively baseless" because of the significant structural and functional differences between the patented mechanism and the accused dual-gear drive Compl. ¶51 It is further alleged that Defendant circumvented Amazon's standard evaluation procedures to improperly remove Plaintiff's products from the marketplace Compl. ¶52 Compl. ¶53

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

This declaratory judgment action appears to center on a classic dispute over claim scope and technical equivalence. The key questions for the court will likely be:

• A question of claim construction: How broadly should the court construe the terms "lock cam," "crank arm," and "first link"? Will the construction be limited to the specific mechanical linkage shown and described in the patents, particularly in light of specification language calling that linkage "critical," or can the terms encompass other power transmission mechanisms like the accused dual-gear drive?
• A question of technical equivalence: If the accused products are found not to literally infringe, does their dual-gear drive perform substantially the same function, in substantially the same way, to achieve substantially the same result as the claimed linkage? The complaint’s assertion of a "fundamentally different" configuration sets the stage for a significant factual dispute on this issue.
• A question of commercial conduct: Independent of the infringement outcome, did the Defendant’s enforcement actions through the Amazon APEX program constitute tortious interference? The analysis may focus on whether Defendant had a good-faith belief in its infringement claims at the time it filed its complaints with Amazon.