Wonderfold Corp v. Highlink Trade Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Wonderfold Corporation (California)
  • Defendant: Highlink Trade Limited (Hong Kong China); Omnifamily Inc. (California); Omnihome Inc. (New Jersey); et al.
  • Plaintiff’s Counsel: Law Offices of Niria M. Arvizu
• Case Identification: 2:24-cv-03280, C.D. Cal., 10/10/2025
• Venue Allegations: Venue is alleged to be proper based on Defendants having committed acts of infringement, transacted business, and sold products within the Central District of California. One defendant, Omnifamily Inc., is alleged to have its principal place of business in the district.
• Core Dispute: Plaintiff alleges that Defendants’ Joymor stroller infringes a utility patent for a foldable stroller mechanism and a design patent for the stroller's ornamental appearance.
• Technical Context: The technology at issue relates to foldable, wagon-style strollers designed to transport multiple children, a product category where functionality, safety, and brand-differentiating design are key market features.
• Key Procedural History: The operative pleading is a First Amended Complaint. The complaint alleges that Defendants market the accused product as an "exact dupe" of Plaintiff's product, which may be relevant to questions of intent and willfulness.

Case Timeline

Date	Event
2019-01-02	U.S. Patent No. 10,464,588 Priority Date
Early 2019	Plaintiff's Wonderfold stroller line allegedly launched
2019-04-25	U.S. Patent No. D955,301 Priority Date
2019-11-05	U.S. Patent No. 10,464,588 Issued
2022-01-01	Defendants allegedly began marketing the accused Joymor stroller
2022-06-21	U.S. Patent No. D955,301 Issued
2025-10-10	Complaint Filing Date

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

U.S. Patent No. 10,464,588 - Foldable Baby Stroller

• Patent Identification: U.S. Patent No. 10,464,588, "Foldable Baby Stroller," issued November 5, 2019 (’588 Patent).

The Invention Explained

• Problem Addressed: The patent's background section notes that many existing baby strollers cannot be "conveniently folded" and may suffer from "low structure stability" when in use, which are significant drawbacks for safety and convenience (ʼ588 Patent, col. 1:12-15, 1:47-48).
• The Patented Solution: The invention is a specific mechanical frame for a foldable stroller that aims to improve both stability and ease of folding. It comprises a front wheel assembly, a rear wheel assembly, and a central folding assembly made of two "lateral folding holders." Each holder is a network of interconnected tubes ("upper-front fence tube," "lower-back fence tube," etc.) and joints ("upper folding joint," "lower folding joint") that pivot in a prescribed manner to collapse the frame compactly ('588 Patent, Abstract; col. 4:1-29).
• Technical Importance: The claimed structure seeks to provide a robust, stable frame when unfolded while allowing for a significantly reduced size when folded for storage or transport ('588 Patent, col. 3:18-24).

Key Claims at a Glance

• The complaint asserts independent Claim 1 (Compl. ¶66).
• The essential elements of Claim 1 include:
  • A front wheel assembly with a front wheel holder.
  • A rear wheel assembly with a rear wheel holder that is "inverted U-shaped" and connected to a push rod.
  • A folding assembly with two "lateral folding holders."
  • Each lateral folding holder includes an upper-front fence tube, a lower-front fence tube, an upper-back fence tube, and a lower-back fence tube.
  • Each holder also includes a "middle holder" comprising an upper folding joint, a lower folding joint, and a support stand rod connecting them.
  • A specific arrangement of pivotal connections between the fence tubes, the wheel holders, and the folding joints.
• The complaint reserves the right to modify its infringement contentions during discovery (Compl. ¶66).

U.S. Patent No. D955,301 - Stroller

• Patent Identification: U.S. Design Patent No. D955,301, "Stroller," issued June 21, 2022 (’301 Patent).

The Invention Explained

• Problem Addressed: Design patents protect ornamental appearance rather than functional solutions. The implicit goal is to create a novel, non-obvious, and non-functional visual design that distinguishes a product in the marketplace.
• The Patented Solution: The patent claims the specific ornamental design for a stroller as depicted in its eight figures (’301 Patent, Figs. 1-8). The protected design consists of the visual characteristics shown in solid lines, including the product's overall wagon-like configuration, the high-walled rectangular carriage, the arrangement of the wheels, the shape and placement of the handle, and the fabric canopy structure.
• Technical Importance: A unique product design can create strong brand association and consumer recognition, which the complaint alleges has occurred for the Wonderfold stroller (Compl. ¶¶25-26).

Key Claims at a Glance

• The patent contains a single claim for "The ornamental design for a stroller, as shown and described" (’301 Patent, Claim).
• The complaint alleges infringement of this claim (Compl. ¶¶72-75).

III. The Accused Instrumentality

Product Identification

• The accused products are identified as the "Joymor stroller" line (Compl. ¶2).

Functionality and Market Context

• The Joymor stroller is a foldable, wagon-style stroller for children, placing it in direct competition with the Plaintiff's products (Compl. ¶39).
• The complaint alleges that Defendants explicitly market the Joymor stroller as "the wonderfold exact dupe" at a lower price point and advertise that it "fits all the accessories from the wonderfold" (Compl. ¶39). A screenshot from an Instagram post allegedly shows this "exact dupe" marketing language (Compl. p. 19).
• The complaint further alleges that the Joymor stroller "copies exactly all of the patented and distinctive designs of the stroller of Wonderfold" (Compl. ¶39).

IV. Analysis of Infringement Allegations

’588 Patent Infringement Allegations

The complaint provides a detailed, element-by-element breakdown of its infringement theory for Claim 1, supported by annotated photographs from the accused product's user manual (Compl. ¶66).

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a front wheel assembly, comprising a front wheel holder, a front-left wheel and a front-right wheel disposed at the bottom of the front wheel holder	The Joymor stroller includes a front wheel assembly with a holder and two wheels at the bottom. The complaint provides a labeled photograph of this assembly. (Compl. p. 34).	¶66(1a)	col. 5:46-51
a rear wheel assembly, comprising a rear wheel holder,...wherein the rear wheel holder is inverted U-shaped, connected to a push rod...	The Joymor stroller includes a rear wheel assembly with an allegedly inverted U-shaped holder connected to a push rod. A labeled photograph depicts this structure. (Compl. p. 35).	¶66(1b)	col. 5:52-59
a folding assembly, comprising two lateral folding holders...wherein each lateral folding holder comprises an upper-front fence tube, a lower-front fence tube, an upper-back fence tube, a lower-back fence tube and a middle holder	The stroller's folding frame allegedly includes two lateral folding holders with the recited fence tubes and middle holder. An annotated photograph illustrates these components. (Compl. p. 36).	¶66(1c)	col. 5:60-67
the middle holder comprises an upper folding joint, a lower folding joint and a support stand rod disposed therebetween and connecting the upper folding joint to the lower folding joint	The Joymor stroller's middle holder is alleged to contain an upper folding joint, a lower folding joint, and a connecting support stand rod, as shown in a labeled photograph. (Compl. p. 38).	¶66(1e)	col. 6:2-5
front ends of the upper-front fence tube and the lower-front fence tube are pivotally connected to the front wheel holder respectively, rear ends of the upper-front fence tube and the lower-front fence tube are pivotally connected to front ends of the upper folding joint and the lower folding joint...	The complaint alleges that the various tubes and joints of the Joymor stroller are pivotally connected in the specific manner required by the claim, providing a comprehensive labeled diagram. (Compl. p. 40).	¶66(1g)	col. 6:19-28

• Identified Points of Contention:
  • Scope Questions: The dispute may center on the precise meaning of structural terms. For example, "Does the accused rear wheel holder possess the specific geometry of an 'inverted U-shaped' structure as understood in the context of the patent, or does it have a functionally similar but structurally distinct shape?"
  • Technical Questions: The analysis will question whether the components of the accused stroller are connected and operate in the exact manner recited. For instance, "What evidence demonstrates that the various 'fence tubes' of the Joymor stroller are 'pivotally connected' to the 'folding joints' and 'wheel holders' in the specific arrangement required by subsection (g) of Claim 1?"

’301 Patent Infringement Allegations

• The complaint alleges that the design of the Joymor stroller is "the same or substantially the same" as the ornamental design claimed in the ’301 Patent, such that it would deceive an ordinary observer (Compl. ¶¶54, 57). To support this, the complaint provides a side-by-side visual comparison showing Figure 1 of the patent next to images of the Plaintiff's Wonderfold stroller and the accused Joymor stroller (Compl. p. 32). This comparison is presented as evidence that the overall visual impressions are nearly identical.
• Identified Points of Contention:
  • Scope Questions: The core legal question, under the "ordinary observer" test, will be whether the overall visual appearance of the accused Joymor stroller is substantially the same as the patented design.
  • Technical Questions: The factual dispute will likely focus on alleged differences between the products. "Will Defendants be able to identify sufficient visual differences in shape, proportion, or surface ornamentation between the Joymor stroller and the patented design to argue that an ordinary observer would not be confused?"

V. Key Claim Terms for Construction

For the ’588 Patent:

• The Term: "inverted U-shaped"
• Context and Importance: This term defines the required geometry of the rear wheel holder. Its construction is critical because if the accused product's corresponding part has a different shape (e.g., V-shaped, rectangular), it may not literally infringe this limitation. Practitioners may focus on this term as a potential non-infringement defense.
  • Evidence for a Broader Interpretation: The specification does not provide a textual definition, which may support applying the term's plain and ordinary meaning, potentially covering a range of curved, downward-opening structures.
  • Evidence for a Narrower Interpretation: The patent figures depict a specific, rounded arch shape for the rear wheel holder (e.g., ’588 Patent, FIG. 2, item 21). A party could argue the term should be construed as being limited to the embodiment shown in the drawings.
• The Term: "middle holder"
• Context and Importance: This term refers to the central hub of the folding mechanism, which itself must comprise an "upper folding joint," a "lower folding joint," and a "support stand rod." The infringement analysis depends on whether the accused device contains a single, identifiable "middle holder" that incorporates all three of these sub-components in the claimed configuration.
  • Evidence for a Broader Interpretation: The term could be functionally defined as the collection of components that serve as the central pivot point for the frame, as described in the specification ('588 Patent, col. 4:6-12).
  • Evidence for a Narrower Interpretation: The claim language requires a specific combination of three distinct sub-elements within the "middle holder." An argument could be made that if an accused device achieves a similar folding function using a different combination or number of parts, it does not meet this limitation as claimed.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendants induce infringement by selling the Joymor stroller to retail partners and end users with knowledge that their actions will cause infringement of the ’588 Patent (Compl. ¶69).
• Willful Infringement: The complaint alleges willful infringement of both the ’588 and ’301 patents (Compl. ¶¶55, 79). The basis for willfulness appears to include post-suit knowledge from the filing of the complaint (Compl. ¶68), as well as pre-suit knowledge inferred from allegations that Defendants intentionally copied the Plaintiff's product and marketed it as an "exact dupe" (Compl. ¶39).

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

• A core issue will be one of visual identity: For the design patent claim, is the accused Joymor stroller's overall ornamental design "substantially the same" as the claimed design in the eyes of an ordinary observer, particularly given Defendants' alleged marketing of the product as an "exact dupe"?
• A key evidentiary question will be one of structural correspondence: For the utility patent claim, does the accused stroller's folding mechanism contain every specific component recited in Claim 1—including an "inverted U-shaped" holder and a "middle holder" with all its required sub-parts—arranged and connected in the precise manner claimed?
• A central question for damages will be one of intent: Can the plaintiff prove that the defendants' alleged copying, "exact dupe" marketing, and use of plaintiff's trademarks in social media hashtags constitutes willful infringement, which could lead to an award of enhanced damages?