At least with Garage Door Openers (GDOs). From the court's opinion granting Skylink's Motion for Partial Summary Judgment on Chamberlain's DMCA Claim:

Under Chamberlain's theory, any customer who loses his or her Chamberlain transmitter, but manages to operate the opener either with a non-Chamberlain transmitter or by some other means of circumventing the rolling code, has violated the DMCA. In this court's view, the statute does not require such a conclusion. GDO transmitters are similar to television remote controls in that consumers of both products may need to replace them at some point due to damage or loss, and may program them to work with other devices manufactured by different companies. In both cases, consumers have a reasonable expectation that they can replace the original product with a competing, universal product without violating federal law.

BIPlog has brought this up before. This is the case where Skylink made a third party garage door opening transmitter (you know, the little dark gray plastic thingy with a button that you keep in your car) that worked with Chamberlain's garage door opener (GDO, and it's the mechanism in your garage that actually moves the door open), after which Chamberlain asserted this violated the DMCA. Chamberlain uses a rolling code mechanism (meant to deter thieves) to make their GDO work with their own garage door-opening transmitter. Skylink makes many different transmitters that work with several manufacturers' GDOs. In this case Chamberlain said that Skylink's accessing of the rolling code was in violation of the DMCA anti-circumvention provisions.