2:24-cv-10961
Aborder Products Inc v. Dbest Products Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Aborder Products Inc (Texas)
- Defendant: Dbest Products Inc (California)
- Plaintiff’s Counsel: Newman Du Wors LLP
- Case Identification: 2:24-cv-10961, C.D. Cal., 05/06/2025
- Venue Allegations: Venue is alleged to be proper in the Central District of California because the defendant, dbest products, Inc., resides in the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its storage box products do not infringe Defendant’s patent related to stackable, collapsible carts.
- Technical Context: The technology at issue involves the mechanical design of collapsible storage containers, a mature field in consumer and commercial goods focused on durability, ease of use, and compact storage.
- Key Procedural History: The complaint alleges that this declaratory judgment action was precipitated by Defendant asserting its patent against Plaintiff’s products on the Amazon marketplace, which resulted in the temporary removal of Plaintiff’s product listings. The complaint also raises significant questions regarding the patent’s validity, alleging that its claimed priority date is improper due to the addition of new matter and that key drawings were copied from a pre-existing Chinese patent.
Case Timeline
| Date | Event |
|---|---|
| 2020-01-06 | Earliest Claimed Priority Date for ’576 Patent |
| 2021-12-03 | Chinese Patent CN214987334 Published |
| 2022-07-29 | Alleged First Public Availability of HAIXIN Products |
| 2023-12-15 | Application for ’576 Patent Filed |
| 2024-10-01 | ’576 Patent Issued |
| 2024-11-27 | Amazon Removes Plaintiff's Product Listings |
| 2025-01-03 | Amazon Reinstates Plaintiff's Product Listings |
| 2025-05-06 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,103,576 - "Stackable Collapsible Carts"
- Patent Identification: U.S. Patent No. 12103576, “Stackable Collapsible Carts,” issued October 1, 2024 (the “’576 Patent”).
The Invention Explained
- Problem Addressed: The patent’s background section notes that prior art collapsible carts may have sidewalls that are not "sufficiently sturdy to allow for transporting heavy objects" (’576 Patent, col. 1:21-23).
- The Patented Solution: The invention is a collapsible cart designed to be more robust when assembled. The specification describes sidewalls constructed from multiple panels that are rotatably coupled. A key feature is a lock assembly, which includes a "slideable member" that moves along a track spanning two adjacent panels to lock them together in an open, expanded position (’576 Patent, col. 2:41-57; Fig. 2). The design also incorporates features for stacking multiple identical carts, such as an indentation pattern on the top cover shaped to receive the wheels of another cart (’576 Patent, col. 10:60-65).
- Technical Importance: The described solution aims to improve the structural integrity of collapsible containers, a critical factor for utility and consumer confidence in products intended for transport and storage.
Key Claims at a Glance
The complaint identifies claims 1, 11, and 15 as the independent claims of the ’576 Patent (Compl. ¶17).
Independent Claim 1:
- A collapsible cart configured to transition from a closed to an open condition.
- A rigid frame including a right sidewall with a first right panel rotatably coupled to a second right panel.
- A first track formed along the first and second right panels.
- A first slideable member engaged with the track, movable between an open and closed position to selectively lock the first right panel to the second right panel.
Independent Claim 11:
- A cart with a rigid frame and a right sidewall comprising a first, second, and third right panel.
- The second and third right panels conform in shape to collectively cover an opening in the first right panel.
- The second right panel comprises a ribbed wall with a plurality of ribs.
- A first lock assembly integrated with the first and second right panels, having a first condition for locking and a second condition for unlocking the panels.
Independent Claim 15:
- A stackable collapsible cart with a rigid frame, wheel assembly, and a rigid top cover.
- The rigid top cover has an indentation pattern at least substantially aligned with the vertical axis of the wheel assembly.
- The indentation pattern is configured to receive a wheel assembly from another identical collapsible cart when stacked vertically.
III. The Accused Instrumentality
Product Identification
- Plaintiff’s “Noninfringing Storage Boxes,” which are offered for sale on Amazon.com under the “Aborder Products Inc” storefront and identified by a list of Amazon Standard Identification Numbers (ASINs) (Compl. ¶¶9, 12).
Functionality and Market Context
- The complaint does not provide sufficient detail for analysis of the specific technical functionality of the accused products. As a declaratory judgment action for non-infringement, its focus is on identifying features of the ’576 Patent that the products allegedly lack.
- The complaint alleges that the Amazon marketplace is Plaintiff’s “primary sales channel into the United States” and that the products compete in the U.S. market for storage boxes (Compl. ¶13).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The core of its argument is that the accused storage boxes are missing key elements required by the independent claims.
’576 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Missing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first track formed along the first right panel and the second right panel extending from a first position on the first right panel to a second position on the second right panel | Plaintiff alleges its products lack a track that spans across two distinct side panels. | ¶31 | col. 11:51-56 |
| a first slideable member cooperatively engaged to the first track, the first slideable member is movable along the first track between an open position to a closed position to selectively lock the first right panel to the second right panel... | Plaintiff alleges its products lack a slideable member that operates on such a track to lock the panels. | ¶31 | col. 11:57-67 |
| Claim Element (from Independent Claim 11) | Alleged Missing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first lock assembly integrated with the first right panel and the second right panel, the first lock assembly having a first condition for locking the first right panel to the second right panel, and a second condition for unlocking... | Plaintiff alleges its products lack a lock assembly with the claimed characteristics of being integrated with two panels and having specific locking/unlocking conditions. | ¶32 | col. 13:3-9 |
| Claim Element (from Independent Claim 15) | Alleged Missing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| the rigid top cover has an indentation pattern being at least substantially aligned with the vertical axis of the wheel assembly, the indentation pattern configured to receive a wheel assembly from another identical collapsible cart when stacked vertically. | Plaintiff alleges its products lack a top cover with an indentation pattern specifically configured to receive and align with the wheel assembly of another cart for stacking. | ¶33 | col. 14:12-16 |
Identified Points of Contention
- Scope Questions: A central question will be how broadly terms like "track," "slideable member," and "lock assembly" are construed. The dispute may turn on whether any mechanism that slides to lock panels together meets these limitations, or if they are limited to the specific track-and-slider structure depicted in the patent’s figures. The complaint provides a side-by-side comparison of Figure 42A from the patent and Figure 5 from a Chinese patent, alleging they are nearly identical, which may be used to argue for a narrower construction to preserve validity (Compl. p. 7).
- Technical Questions: The primary technical question will be a factual one: do the accused "Aborder Products" storage boxes contain structures that meet the definitions of the disputed claim elements, either literally or under the doctrine of equivalents? The complaint's lack of detail on the accused product design means this will depend entirely on evidence produced during discovery.
V. Key Claim Terms for Construction
The Term: "first slideable member" (Claim 1)
Context and Importance: This term is central to the locking mechanism of Claim 1. The infringement analysis will depend on whether this term is construed broadly to cover any sliding latch or narrowly to require the specific type of member shown moving along a defined "track" that bridges two separate panels.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Claim 1 describes the member as being "cooperatively engaged to the first track" and "movable along the first track," which could arguably cover any component guided by a track-like structure (’576 Patent, col. 11:57-59).
- Evidence for a Narrower Interpretation: The specification consistently depicts the slideable member (58) as a distinct piece that physically slides over the junction of two panels along a raised track (46) (’576 Patent, Fig. 2; col. 7:4-10). This specific embodiment may be argued to limit the scope of the term.
The Term: "lock assembly integrated with the first right panel and the second right panel" (Claim 11)
Context and Importance: The meaning of "integrated" is critical. If it requires the lock assembly to be a single, molded piece with the panels, it would exclude designs where the lock is a separately manufactured component. This distinction could be dispositive for infringement.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "integrated" is not explicitly defined. A party could argue it simply means the components are designed to work together as a single functional unit, not that they must be of monolithic construction.
- Evidence for a Narrower Interpretation: The patent does not appear to provide a specific definition that would limit the term to a single molded piece. However, a defendant might argue that in the context of plastic molding, "integrated" implies a unitary construction to distinguish from assemblies of separate parts.
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaration of non-infringement for all forms of infringement, including contributory and induced infringement, but does not provide specific factual allegations related to these claims (Compl. ¶30).
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears poised to center on two main fronts: claim construction and patent validity. The key questions for the court will likely be:
A question of patent validity: Does the ’576 Patent have a valid claim to its 2020 priority date? The complaint’s allegations of improperly added new matter and its visual evidence suggesting that patent drawings were copied from a 2021 Chinese patent (Compl. p. 7) create a significant challenge to the patent's enforceability that may become the central issue in the case.
A question of definitional scope: How narrowly will the court construe the mechanical terms "slideable member" and "lock assembly integrated with" the side panels? The outcome of the non-infringement claim will likely hinge on whether these terms are limited to the specific embodiments shown in the patent's figures or can be read more broadly to cover other common locking mechanisms.
An evidentiary question of technical operation: Assuming the patent is valid and its claims are construed, a core factual dispute will be whether the accused storage boxes, once examined, incorporate the specific multi-panel construction and locking mechanisms as claimed in the ’576 Patent.