DCT
2:25-cv-00350
Shantou Juhe Home Furnishings Co Ltd v. Dbest Products Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shantou Juhe Home Furnishings Co., Ltd., Shantou Mengxiang Home Furnishings Co., Ltd., and Jieyang Juxiaonian Trading Co., Ltd. (People's Republic of China)
- Defendant: dbest products, Inc. (California)
- Plaintiff’s Counsel: Glacier Law LLP
- Case Identification: 2:25-cv-00350, C.D. Cal., 01/13/2025
- Venue Allegations: Plaintiffs allege venue is proper in the Central District of California because the Defendant is incorporated, maintains its principal place of business, and allegedly conducted infringing activities within the district.
- Core Dispute: Plaintiffs seek a declaratory judgment that their "Storage Bins" do not infringe Defendant's patent related to "Stackable Collapsible Carts," and that the patent is invalid, following Defendant’s infringement complaints on the Amazon marketplace.
- Technical Context: The technology concerns the mechanical design of collapsible storage carts, a product category focused on balancing portability and structural integrity for consumer use.
- Key Procedural History: The action was precipitated by Defendant's infringement complaints to Amazon, which resulted in the removal of Plaintiffs' product listings. Plaintiffs allege these complaints are baseless and have also put the patent's validity at issue, citing specific prior art references.
Case Timeline
| Date | Event |
|---|---|
| 2002-11-21 | Publication date of "Darren" prior art reference (U.S. Pub. No. 2002/0171228) |
| 2020-01-06 | Earliest priority date claimed by ’576 Patent (U.S. Prov. App. 62/974,956) |
| 2021-06-08 | Publication date of "Song" prior art reference (CN Pub. No. 112918890A) |
| 2024-10-01 | U.S. Patent No. 12,103,576 issues |
| 2024-11-26 | Plaintiff JXN receives Amazon notice of product removal |
| 2024-12-09 | Plaintiff JH.HOME receives Amazon notice of product removal |
| 2024-12-20 | Plaintiff Meng.HOME receives Amazon notice of product removal |
| 2025-01-13 | Complaint for Declaratory Judgment filed |
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 in prior art collapsible carts, the "sidewalls may not be sufficiently sturdy to allow for transporting heavy objects" (’576 Patent, col. 1:21-23).
- The Patented Solution: The invention is a collapsible cart with a specific mechanical locking system to enhance the rigidity of its foldable sidewalls. As described in the patent's summary, the solution involves a multi-panel sidewall where the panels are locked together by "a first lock assembly comprising a first track and a first slideable member" (’576 Patent, col. 2:42-43). The slideable member moves along the track to selectively lock the panels, providing structural integrity when the cart is in its open, expanded condition (’576 Patent, col. 2:47-59).
- Technical Importance: This design aims to improve the utility of collapsible carts by making them more robust and capable of handling heavier loads, a significant limitation of earlier designs (’576 Patent, col. 1:21-25).
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement of independent claims 1, 11, and 15 (Compl. ¶24).
- Independent Claim 1 recites a collapsible cart with key elements including:
- A rigid frame with sidewalls configured to fold inwardly.
- A right sidewall comprising a "first right panel rotatably coupled to a second right panel."
- "a first track formed along the first right panel and the second right panel."
- "a first slideable member cooperatively engaged to the first track" which is movable to "selectively lock the first right panel to the second right panel." (Compl. ¶25).
- Independent Claim 11 recites a cart with key elements including:
- A rigid frame with inwardly folding sidewalls, the right sidewall comprising a first panel, a second panel, and a third panel.
- "a first lock assembly integrated with the first right panel and the second right panel," having locking and unlocking conditions (Compl. ¶26).
- Independent Claim 15 recites a "stackable collapsible cart" with key elements including:
- A rigid frame with inwardly folding sidewalls.
- "a first lock assembly integrated with the first right panel and the second right panel."
- A wheel assembly.
- A rigid top cover with an "indentation pattern" configured to receive a wheel assembly from another cart when stacked (Compl. ¶27).
- The complaint asserts that because the independent claims are not infringed, the dependent claims (2-10) are also not infringed (Compl. ¶31).
III. The Accused Instrumentality
Product Identification
- Plaintiffs’ "Storage Bins," sold on Amazon.com under various ASINs (Compl. ¶¶8, 13-16).
Functionality and Market Context
- The accused products are storage bins sold through Amazon, which the complaint identifies as the Plaintiffs' "primary sales channel into the United States" (Compl. ¶18). The complaint alleges that the key functionality for securing the side doors of the Storage Bin is "entirely based on magnetic attraction" (Compl. ¶29). It states that each side door panel is equipped with a "magnetic object" and the corresponding frame has a "matching magnet," which pair together to secure the doors (Compl. ¶29).
IV. Analysis of Infringement Allegations
The complaint’s non-infringement theory centers on the argument that the accused products use a magnetic closure, which is fundamentally different from the mechanical sliding lock required by the asserted claims. Chart 1 in the complaint presents a side-by-side visual comparison to support this contention (Compl. p. 11). This chart juxtaposes patent figures depicting a sliding lock assembly against photographs of the accused product's magnetic closure (Compl. ¶28, p. 11).
’576 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first track formed along the first right panel and the second right panel... | The complaint alleges the accused Storage Bin does not have a track, instead using magnets on the door and frame for closure. | ¶29 | col. 7:6-7 |
| 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... | The complaint alleges the accused Storage Bin "lacks, and does not require, the sliding locking mechanism," and instead relies on magnetic attraction between a "magnetic object" and a "matching magnet" to secure the side doors. | ¶¶28-29 | col. 7:4-14 |
- Identified Points of Contention:
- Scope Questions: The core of the dispute appears to be claim construction. A central question for the court will be whether the claim term "a first slideable member cooperatively engaged to the first track" can be interpreted to read on the accused product's magnetic closure system. Plaintiffs argue for a narrow, structural interpretation that their product does not meet (Compl. ¶30).
- Technical Questions: A key factual question is whether the accused magnetic system operates in a manner equivalent to the claimed invention. The complaint argues that the "locking mechanisms (ways) are completely different" and the difference is "substantial," preemptively arguing against the doctrine of equivalents (Compl. ¶30). The evidence will focus on comparing the structure and function of the two distinct closure mechanisms.
V. Key Claim Terms for Construction
- The Term: "a first slideable member cooperatively engaged to the first track"
- Context and Importance: This limitation is the heart of the inventive locking mechanism and the central point of the non-infringement dispute. Plaintiffs allege their product lacks this entire structure, using magnets instead (Compl. ¶¶28-29). The construction of "slideable member" and "track" will likely determine the outcome of the literal infringement analysis.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party arguing for a broader reading might assert that the "plain and ordinary meaning" of the terms should apply, potentially defining "track" as any guide for movement and "slideable member" as any part that moves to lock. The patent does not appear to offer an explicit definition that would preclude such an argument.
- Evidence for a Narrower Interpretation: The patent specification and figures provide significant support for a more structural, narrower definition. The detailed description refers to a specific "first slideable member 58" and "second slideable member 60" that move along "respective tracks 46 and 48" (’576 Patent, col. 8:5-14). Figures such as FIG. 42B depict a distinct physical structure for the track (46) and the member (58) that slides along it, which a party could argue limits the claim scope to this type of mechanical arrangement.
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaration of non-infringement for both direct and indirect infringement (Compl. ¶34). However, as a declaratory judgment action filed by the accused infringer, it does not set forth the patentee's specific factual allegations that would support a claim for indirect infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to hinge on a classic patent dispute involving the scope of claim language versus the specific operation of an accused product. The central questions for the court will likely be:
A core issue will be one of definitional scope: Can the claim terms "track" and "slideable member," which are described in the patent's embodiments as components of a mechanical sliding lock, be construed broadly enough to encompass the magnetic attraction-based closure system used in the accused Storage Bins?
A key question on the doctrine of equivalents will be one of functional difference: Does the accused product's magnetic closure perform substantially the same function, in substantially the same way, to achieve substantially the same result as the claimed invention? Or, as the Plaintiffs contend, is the difference in the way the lock operates—magnetic force versus a mechanical slide—a "substantial" one that precludes a finding of equivalence?