DCT
2:25-cv-00471
Hangzhou ALFA Trading Co Ltd v. Dbest Products Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Hangzhou ALFA Trading Co. Ltd and Zhejiang Xinmao Plastie Industry Co., Ltd (People's Republic of China)
- Defendant: Dbest Products, Inc. (California)
- Plaintiff’s Counsel: Miller Law Associates, APC; Norris McLaughlin P.A.
- Case Identification: 2:25-cv-00471, C.D. Cal., 01/17/2025
- Venue Allegations: Venue is alleged to be proper as Defendant is a California corporation with its principal place of business in the district, is considered domiciled there, and has engaged in acts giving rise to the dispute within the district.
- Core Dispute: Plaintiffs seek a declaratory judgment that their collapsible cart products do not infringe Defendant’s patent, and further allege patent misuse and unfair competition based on Defendant’s enforcement actions on the Amazon marketplace.
- Technical Context: The technology involves stackable, collapsible rolling carts, a consumer product category focused on balancing portability and storage with structural rigidity for carrying goods.
- Key Procedural History: The complaint alleges that Defendant used U.S. Patent No. 12,103,576 to cause the delisting of Plaintiffs' products from Amazon. It further alleges that numerous prior art references were not considered by the USPTO during the patent's prosecution, and that a third party submitted a prior art reference to the USPTO during the prosecution of a related application.
Case Timeline
| Date | Event |
|---|---|
| 2020-01-06 | Earliest Priority Date for '576 Patent |
| 2024-10-01 | '576 Patent Issue Date |
| 2024-11-21 | Defendant allegedly uses '576 Patent to take down "Enhomme Products" |
| 2024-12-15 | Defendant allegedly uses '576 Patent to take down "Alfa Products" |
| 2025-01-17 | 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. 12,103,576, issued October 1, 2024.
The Invention Explained
- Problem Addressed: The patent background identifies a deficiency in prior art collapsible carts, noting that their sidewalls may not be "sufficiently sturdy to allow for transporting heavy objects" due to their collapsible nature (’576 Patent, col. 1:21-24).
- The Patented Solution: The patent describes a collapsible cart with a reinforced sidewall structure designed to enhance rigidity. The solution involves constructing the sidewalls from multiple panels (e.g., a "first right panel" rotatably coupled to a "second right panel") that can be locked together in an open, useable position via a dedicated locking mechanism, such as a "slideable member" that moves along a "track" spanning both panels (’576 Patent, Abstract; col. 2:37-57). This design aims to provide a more robust frame when the cart is expanded while still allowing the sidewalls to fold inwardly for compact storage.
- Technical Importance: This approach seeks to resolve the inherent design trade-off between the convenience of a foldable cart and the load-bearing strength of a rigid container (’576 Patent, col. 1:21-26).
Key Claims at a Glance
- The complaint identifies independent claims 1, 11, and 15 as being asserted by the Defendant (Compl. ¶36).
- Independent Claim 1 recites:
- A collapsible cart configured to transition between a closed (folded) and open (expanded) condition.
- A rigid frame with a front wall, rear wall, bottom wall, and left and right sidewalls configured to fold inwardly.
- The right sidewall comprises a first right panel rotatably coupled to a second right panel.
- The second right panel is "proportioned to fit within an opening in the first right panel."
- A "first track" is formed along both the first and second right panels.
- A "first slideable member" engages the track and is movable to selectively lock the first right panel to the second right panel.
- The complaint seeks a judgment of non-infringement for all claims of the ’576 Patent, thereby implicitly including all dependent claims (Compl. ¶21).
III. The Accused Instrumentality
Product Identification
- The "Accused Products" are folding storage carts sold under the brand names "Alfa Products," "Enhomme Products," and "Vecelo Products" (Compl. ¶7, 8, 13, 21).
Functionality and Market Context
- The Accused Products are described as "folding storage boxes" and are depicted as multi-level rolling utility carts (Compl. ¶20). Visuals provided in the complaint show a wheeled plastic cart with multiple shelves. (Compl. p. 2). The complaint states that the Amazon marketplace is the Plaintiffs' "primary sales channel into the United States" and that their product listings were removed as a result of Defendant's infringement complaints to Amazon (Compl. ¶2, 3, 5, 8).
IV. Analysis of Infringement Allegations
The complaint is for a declaratory judgment of non-infringement. The following table summarizes the Plaintiffs' core non-infringement arguments as they relate to the elements of Claim 1. The complaint does not provide a feature-by-feature denial but makes broad allegations that its products lack the claimed features.
’576 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Plaintiff's Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A collapsible cart configured to transition from a closed condition where it is folded up to an open condition where it is expanded for use... | The complaint alleges the Accused Products do not meet the limitations of the claims of the '576 Patent. | ¶37 | col. 11:41-44 |
| the right sidewall comprising a first right panel rotatably coupled to a second right panel; | The complaint asserts that the Accused Products do not have the specific sidewall structure required by claims 1-10 of the '576 patent, which includes inwardly folding sidewalls comprised of a first panel rotatably coupled to a second panel. | ¶9, 37 | col. 11:50-52 |
| the second right panel proportioned to fit within an opening in the first right panel; | The complaint's general denial of infringement implies the accused products lack this specific geometric arrangement. | ¶37 | col. 11:53-55 |
| a first track formed along the first right panel and the second right panel...and a first slideable member cooperatively engaged to the first track...to selectively lock the first right panel to the second right panel... | The complaint's argument is that the Accused Products do not practice the claimed invention and that their designs are instead similar to prior art that lacks this specific locking mechanism. | ¶37, 38 | col. 11:56-68 |
Identified Points of Contention
- Technical Questions: A primary factual dispute will be whether the Accused Products' sidewalls are constructed with the specific multi-panel, track-and-slider locking system recited in the claims. The complaint does not provide detailed schematics or technical descriptions of the Accused Products to definitively show an alternative, non-infringing construction.
- Scope Questions (Ensnarement Doctrine): The complaint's central argument is that if the claims were interpreted broadly enough to cover the Accused Products, they would also be invalid over prior art (referenced in Exhibits E-L) (Compl. ¶37-39). This raises the legal question of whether the doctrine of ensnarement applies, which prevents a patentee from obtaining a scope of equivalents that would encompass the prior art. The court will have to determine the proper scope of the claims in light of both the accused designs and the cited prior art.
V. Key Claim Terms for Construction
The Term: "a first slideable member cooperatively engaged to the first track"
- Context and Importance: This phrase defines the locking mechanism that allegedly provides the cart's enhanced rigidity, a key feature of the invention. The definition of "slideable member" and its "engagement" with the "track" will be critical to determining infringement. Practitioners may focus on this term because its construction will determine whether a variety of locking mechanisms could infringe or if it is limited to the specific structure shown in the patent's figures.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language describes the member's function—being "movable along the first track" to "selectively lock" the panels—which may support a construction covering any sliding component that achieves this result (’576 Patent, col. 12:57-62).
- Evidence for a Narrower Interpretation: The specification's figures depict a specific physical embodiment of the slideable member (58) and track (46) (’576 Patent, FIG. 2, 42B, 52-53). A party could argue the term should be construed more narrowly, consistent with this disclosed structure, to exclude dissimilar locking mechanisms.
The Term: "proportioned to fit within an opening in the first right panel"
- Context and Importance: This limitation describes the physical relationship between the two panels that form the sidewall. Whether the Accused Products feature a panel that "fits within an opening" of another will be a direct point of comparison.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The language could be interpreted functionally to mean that one panel is sized to nest within the other when folded, without requiring a distinct, frame-like "opening."
- Evidence for a Narrower Interpretation: Figures such as FIG. 51 appear to show one panel (28) fitting into a distinct aperture or frame formed by the other panel (26), suggesting a more specific structural requirement (’576 Patent, col. 12:48-50; FIG. 51). An argument could be made that the claim requires this literal "panel-in-frame" configuration.
VI. Other Allegations
Indirect Infringement
- The complaint seeks a declaration of non-infringement "directly or indirectly" and "either literally or under the doctrine of equivalents," but the factual allegations focus on the design of the products themselves (direct non-infringement) (Compl. ¶21).
Willful Infringement
- Willfulness is not alleged against the Plaintiffs. Rather, the complaint alleges that Defendant engaged in "willful misuse of the '576 Patent" and "unfair competition" by knowingly enforcing an allegedly non-infringed and/or unenforceable patent against Plaintiffs' products on Amazon (Compl. ¶10, COUNT II, COUNT III).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope versus prior art: Can the claims of the ’576 Patent be construed broadly enough to cover the Plaintiffs’ accused carts without also being rendered invalid by the numerous prior art references the complaint alleges were never considered by the patent examiner?
- A key evidentiary question will be one of technical comparison: Does the evidence show that the Accused Products actually incorporate the specific multi-panel sidewall with a "track" and "slideable member" locking mechanism as claimed in the patent, or do they utilize a fundamentally different and non-infringing folding design? The outcome will likely depend on the court's construction of key claim terms.
- A third question will address improper enforcement: Did the Defendant's actions in reporting the Plaintiffs' products to Amazon constitute patent misuse or unfair competition, particularly if the court finds the products do not infringe or the patent is invalid?