DCT

2:24-cv-10694

iBeauty Ltd Co v. Dbest Products Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-10694, C.D. Cal., 07/18/2025
  • Venue Allegations: Venue is asserted on the basis that the Defendant, Dbest Products, Inc., is domiciled in and resides within the Central District of California.
  • Core Dispute: Plaintiffs seek a declaratory judgment that their storage bin products do not infringe Defendant’s patents, and that the patents are invalid due to prior art and unenforceable due to inequitable conduct during prosecution.
  • Technical Context: The technology relates to the mechanical design of stackable and collapsible wheeled carts, a product category prevalent in consumer goods and retail markets.
  • Key Procedural History: This action was initiated by several sellers on the Amazon marketplace after the Defendant, Dbest Products, Inc., submitted patent infringement complaints to Amazon, leading to the removal of Plaintiffs’ product listings. Defendant has since filed counterclaims for patent infringement. A central allegation in the complaint is that the Defendant engaged in inequitable conduct before the U.S. Patent and Trademark Office by misrepresenting the lineage of the patents-in-suit to claim earlier, and allegedly improper, priority dates.

Case Timeline

Date Event
2002-08-15 Defendant's "Quik Cart" trademark first use in commerce date
2019-11-01 Alleged public display of prior art disclosing a slideable lock
2020-01-06 Earliest provisional application priority date for all patents-in-suit
2021-02-10 Alleged first availability date of a Plaintiff's prior art product (ASIN B0CGZP8NMX)
2022-08-24 Alleged first availability date of a Plaintiff's prior art product (ASIN B0B67PCFLQ)
2022-12-28 Alleged first availability date of a Plaintiff's prior art product (ASIN B0BQ3H7PT8)
2023-09-01 Alleged earliest effective filing date for the ’446 Patent
2023-12-15 Alleged earliest effective filing date for Claim 11 of the ’576 Patent
2024-10-01 U.S. Patent No. [12,103,576] issues
2024-11-27 Approximate date of first Amazon takedown notifications received by Plaintiffs
2025-01-20 Alleged earliest effective filing date for the ’546 Patent
2025-04-15 U.S. Patent No. [12,275,446] issues
2025-05-20 U.S. Patent No. [12,304,546] issues
2025-06-30 Defendant files counterclaims for patent infringement
2025-07-18 Plaintiffs file Third Amended Complaint for Declaratory Judgment

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

U.S. Patent No. 12,103,576 - "Stackable Collapsible Carts" (Issued Oct. 1, 2024)

The Invention Explained

  • Problem Addressed: The patent’s background section notes that due to the collapsible nature of prior art cart designs, their “sidewalls may not be sufficiently sturdy to allow for transporting heavy objects” (’576 Patent, col. 1:21-24).
  • The Patented Solution: The invention is a collapsible cart with sidewalls designed to fold inwardly for storage (’576 Patent, Abstract). To enhance sturdiness when open, a sidewall is constructed from a "first right panel rotatably coupled to a second right panel," which are then secured together by a "first lock assembly" comprising a "first track" and a "first slideable member" that moves along the track to lock the panels in place (’576 Patent, Abstract; col. 1:37-58). The complaint highlights that the patent’s figures appear to show two different products, with Figures 1-29 allegedly depicting a "Quik Cart Pro" and Figures 30-43 allegedly depicting a "Quik Box" (Compl. ¶51-53).
  • Technical Importance: This design attempts to solve a common trade-off in this product class by providing a specific mechanical locking solution intended to improve the structural rigidity of a collapsible frame (’576 Patent, col. 1:21-27).

Key Claims at a Glance

  • The complaint identifies independent claims 1, 11, and 15 as being at issue (Compl. ¶40).
  • Independent Claim 1 recites, in part: a collapsible cart with a right sidewall comprising a first panel rotatably coupled to a second panel, a "first track" formed along both panels, and a "first slideable member" movable along the track to selectively lock the panels together (’576 Patent, col. 11:41-67).
  • Independent Claim 11 recites, in part: a cart where the right sidewall comprises first, second, and third right panels, where the second and third panels "collectively cover the opening in the first right panel," and includes a "first lock assembly" integrated with the panels (’576 Patent, col. 12:62-13:9).
  • Independent Claim 15 recites, in part: a stackable cart with a rigid top cover having an "indentation pattern" configured to receive the wheel assembly of another identical cart when stacked vertically (’576 Patent, col. 14:12-16).

U.S. Patent No. 12,275,446 - "High Load Capacity Collapsible Carts" (Issued Apr. 15, 2025)

The Invention Explained

  • Problem Addressed: The patent addresses the same technical problem as the ’576 Patent: prior art collapsible carts may lack sufficient sidewall sturdiness for heavy loads (’446 Patent, col. 1:13-17).
  • The Patented Solution: The invention is a collapsible cart with a frame composed of at least five walls, where three walls fold inwardly (’446 Patent, col. 10:22-31). The solution focuses on a "first fastener" that is "integrated with the first right panel and the second right panel" and is "operable between a first state for securing the... panel[s]... and a second state for releasing" them (’446 Patent, col. 10:7-16). The complaint alleges that the figures in the ’446 Patent are identical to Figures 1-18 of the ’576 Patent (Compl. ¶72).
  • Technical Importance: The claimed invention provides an alternative description of a mechanical means to secure the folding panels of a collapsible cart, aiming to improve its structural integrity in an open, load-bearing configuration (’446 Patent, col. 1:13-19).

Key Claims at a Glance

  • The complaint states Defendant has asserted independent claim 22 (Compl. ¶75).
  • Independent Claim 22 recites, in part: a collapsible cart with a frame of at least five walls, where a wall comprises a first and second panel. The claim requires "a first fastener configured to selectively secure the first panel and the second panel in the open condition," where the fastener is "integrated" with both panels and can operate in a "first state for securing" and a "second state for releasing" (’446 Patent, col. 10:22-42).

U.S. Patent No. 12,304,546 - "Collapsible Carts" (Issued May 20, 2025)

  • Patent Identification: U.S. Patent No. 12,304,546, "Collapsible Carts," issued May 20, 2025.
  • Technology Synopsis: This patent also seeks to improve the sturdiness of collapsible carts by focusing on the locking mechanism between wall panels (’546 Patent, col. 1:25-28). It claims a fastener with first and second "fastener member[s] integrally disposed on an edge" of the first and second panels, respectively, which are "configured to mate with one another to hold the first panel and the second panel in the substantially coplanar alignment" (’546 Patent, col. 14:15-22).
  • Asserted Claims: The complaint identifies independent claim 9 as being asserted by Defendant (Compl. ¶86).
  • Accused Features: Plaintiffs allege their products do not infringe because they lack the claimed "fasteners," the "integrally disposed on an edge" feature, and the feature where the fastener members are "configured to mate with one another" (Compl. ¶111-113).

III. The Accused Instrumentality

Product Identification

  • Plaintiffs' "storage bins" sold on Amazon.com under various storefronts, including "IBEAUTY LIMITED COMPANY," "XIANGHUO," and "LYUSDD" (Compl. ¶13, 17, 21). The complaint identifies numerous specific models and Amazon Standard Identification Numbers (ASINs) (Compl. ¶13, 17).

Functionality and Market Context

  • The complaint alleges these products are central to Plaintiffs' business in the United States, with the Amazon marketplace constituting their "primary sales channel" (Compl. ¶37). It is alleged that Defendant's infringement complaints to Amazon have resulted in the removal of Plaintiffs' product listings, causing "immediate and substantial harm" (Compl. ¶14, 37). The complaint does not provide sufficient detail for analysis of the technical functionality or operation of the accused storage bins.

IV. Analysis of Infringement Allegations

The complaint does not contain claim charts or detailed technical comparisons. Instead, it makes conclusory denials of infringement for specific claim elements. The narrative infringement theories are summarized below.

’576 Patent Infringement Allegations

  • Plaintiffs' primary theory of non-infringement is a lack of literal correspondence with key structural elements. For claim 1, Plaintiffs allege their products "lack the 'a first track' limitation" (Compl. ¶95). For claim 11, they allege a lack of "the right sidewall comprising a third right panel" and/or the "first lock assembly" (Compl. ¶96). For claim 15, they allege the products lack a "rigid top cover" with the specifically claimed "indentation pattern" for stacking (Compl. ¶97).

’446 Patent Infringement Allegations

  • Plaintiffs' non-infringement theory for claim 22 of the ’446 Patent is based on the absence of the claimed fastener mechanism. Specifically, the complaint alleges the products lack the "first fastener" limitation, the "selectively secure" limitation, and the "first state" and "second state" functionality for securing the panels along a "first plane" (Compl. ¶103-105).

Identified Points of Contention

  • Scope Questions: The dispute may center on whether the mechanisms used in Plaintiffs' products, if any, for joining or securing wall panels fall within the scope of claim terms like "track," "lock assembly," and "fastener" as used in the patents-in-suit.
  • Technical Questions: A fundamental evidentiary question will be the actual mechanical structure and operation of Plaintiffs' accused storage bins. The complaint provides no information on this point, leaving open the question of whether there is a functional or structural correspondence to the claimed inventions. The allegation that the ’576 Patent’s specification appears to disclose two distinct products, the "Quik Cart Pro" and "Quik Box," raises a question of whether the claims are adequately supported across these different embodiments and how that might affect claim scope (Compl. ¶51-53).

V. Key Claim Terms for Construction

For the ’576 Patent: "a first track"

  • The Term: "a first track" (from Claim 1).
  • Context and Importance: Plaintiffs' non-infringement argument for claim 1 hinges entirely on the assertion that their products lack this element (Compl. ¶95). The construction of this term is therefore critical to the infringement analysis for this claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim requires the track to be "formed along the first right panel and the second right panel" and for a "slideable member" to be movable "along" it (’576 Patent, col. 11:52-58). A party might argue this language covers any guide, groove, or channel that directs the movement of another component.
    • Evidence for a Narrower Interpretation: The specification describes the track (46) and shows it in figures as a distinct, C-shaped channel into which the slideable member (58) is "cooperatively engaged" (’576 Patent, col. 7:5-7; Fig. 8). A party may argue that "track" should be limited to such a structure or its structural equivalent, rather than any general guiding surface.

For the ’446 Patent: "a first fastener"

  • The Term: "a first fastener" (from Claim 22).
  • Context and Importance: Plaintiffs base their non-infringement argument for claim 22 on the absence of this element (Compl. ¶103). Practitioners may focus on this term because its definition will likely determine the outcome of infringement for the ’446 patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim defines the "fastener" functionally: it must be "configured to selectively secure" two panels and be "operable between a first state for securing... and a second state for releasing" them (’446 Patent, col. 10:7-16). A party could argue this encompasses a wide range of mechanical components that perform this function, not just a specific structure.
    • Evidence for a Narrower Interpretation: The claim further requires the fastener to be "integrated with the first right panel and the second right panel in both the closed condition and in the open condition" (’446 Patent, col. 10:17-21). The shared specification between the ’446 and ’576 patents describes a slideable member and track system to perform this function. A party may argue that "fastener" should be construed in light of these specific disclosures, limiting its scope.

VI. Other Allegations

Indirect Infringement

  • The complaint seeks a declaratory judgment of non-infringement "directly or indirectly" but does not provide specific facts for analysis of inducement or contributory infringement (Compl. ¶94, 102, 110).

Inequitable Conduct

  • Plaintiffs allege that Defendant engaged in inequitable conduct during the prosecution of all three patents-in-suit. The core of the allegation is that Defendant misrepresented its patent applications to the USPTO as "continuations" of earlier applications when they should have been designated as "continuations-in-part" because they allegedly contained "new matter" not present in the parent applications (e.g., a "third right panel" in the ’576 Patent) (Compl. ¶46-47, 153).
  • It is alleged that this misrepresentation was material and made with deceptive intent, as it allowed Defendant to claim an earlier priority date (e.g., January 6, 2020) than it was entitled to, thereby avoiding intervening prior art that would have allegedly rendered the claims unpatentable (Compl. ¶48-49, 154-157). Similar allegations are made for the ’446 and ’546 patents (Compl. ¶162, 171).

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

  • A core issue will be one of prosecution history and priority: Did the Defendant improperly claim the benefit of earlier filing dates by mischaracterizing applications containing new matter as simple continuations? The answer will determine the critical date for assessing prior art and is central to both the Plaintiffs' invalidity and inequitable conduct claims.
  • A second key issue will be one of claim construction and evidence: Can the claim terms "track" and "fastener" be construed broadly enough to read on the features of Plaintiffs' accused products? The resolution will depend on the court’s interpretation of the patent language and on the yet-to-be-presented evidence detailing the actual design and operation of the accused storage bins.
  • A third question will be one of validity in view of prior art: Assuming the correct priority dates are established, do prior art references—including Defendant's own earlier "Quik Cart" product and various products sold by Plaintiffs and third parties—disclose every element of the asserted claims, thereby rendering them invalid as anticipated or obvious?