DCT

2:25-cv-00471

Hangzhou Alfa Trading Co Ltd v. Dbest Products Inc

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00471, C.D. Cal., 04/18/2025
  • Venue Allegations: Venue is alleged to be proper as the Defendant is domiciled in the Central District of California.
  • Core Dispute: Plaintiffs seek a declaratory judgment that their collapsible storage products do not infringe Defendant’s patent related to stackable collapsible carts.
  • Technical Context: The technology concerns collapsible carts and storage containers, a consumer goods sector where portability, durability, and space-saving designs are significant market drivers.
  • Key Procedural History: This action follows Defendant’s submission of patent infringement complaints to Amazon, which resulted in the delisting of Plaintiffs' products. The complaint for declaratory judgment asserts non-infringement and heavily references numerous prior art patents and applications that were allegedly not considered by the U.S. Patent and Trademark Office during the prosecution of the patent-in-suit, suggesting a potential future challenge to the patent's validity.

Case Timeline

Date Event
2020-01-06 U.S. Patent No. 12,103,576 Priority Date
2024-10-01 U.S. Patent No. 12,103,576 Issue Date
2024-11-21 Defendant allegedly used patent to take down Plaintiffs' "Enhomme" product listings on Amazon
2024-12-15 Defendant allegedly used patent to take down Plaintiffs' "Alfa" product listings on Amazon
2025-04-18 Complaint for Declaratory Judgment Filed

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

U.S. Patent No. 12,103,576 - "Stackable Collapsible Carts"

  • Issued: October 1, 2024
  • Short Name: ’576 Patent

The Invention Explained

  • Problem Addressed: The patent's background section notes that prior art collapsible carts often lack sufficient sturdiness in their sidewalls for transporting heavy objects, a consequence of their collapsible design. (’576 Patent, col. 1:21-23).
  • The Patented Solution: The invention is a collapsible cart with a rigid frame that can transition between a folded state for storage and an expanded state for use. The solution to the sturdiness problem centers on a specific sidewall construction where the side walls are designed to fold inwardly. This is achieved by having sidewalls composed of multiple panels, for instance, a "first right panel rotatably coupled to a second right panel," which can be locked together in the open position to provide structural integrity. (’576 Patent, Abstract; col. 2:37-58). A slideable locking member is described that traverses a track across both panels to secure them. (’576 Patent, col. 7:4-13).
  • Technical Importance: The design aims to combine the convenience of a collapsible container with the load-bearing capacity of a rigid one, addressing a key trade-off in the design of portable storage solutions. (Compl. ¶20).

Key Claims at a Glance

  • The complaint identifies independent claims 1, 11, and 15 as the independent claims of the ’576 Patent. (Compl. ¶35).
  • Essential elements of independent claim 1 include:
    • A collapsible cart configured to transition from a closed condition to an open condition.
    • A rigid frame having a front wall, a rear wall, a right sidewall, a left sidewall, and a bottom wall.
    • The right sidewall and the left sidewall are configured to fold inwardly in the closed condition.
    • The right sidewall comprising a first right panel rotatably coupled to a second right panel.
    • The second right panel proportioned to fit within an opening in the first right panel.
    • A first track formed along the first and second right panels.
    • A first slideable member cooperatively engaged to the first track, movable between an open and closed position to selectively lock the first right panel to the second right panel.
  • The complaint does not explicitly reserve the right to assert dependent claims, as it is a declaratory judgment action for non-infringement.

III. The Accused Instrumentality

Product Identification

The "Accused Products" are identified as the "Alfa Products," "Enhomme Products," and "Vecelo Products," which are sold by the Plaintiffs on online marketplaces such as Amazon. (Compl. ¶¶ 2, 4, 6, 22).

Functionality and Market Context

The complaint describes the Accused Products as belonging to the "folding storage boxes area." (Compl. ¶21). Product images included in the complaint depict multi-tiered, wheeled plastic storage containers and stackable folding boxes with transparent doors. (Compl. p. 2, p. 3, p. 4). The "Alfa Products," for example, are shown as wheeled storage carts with multiple levels. (Compl. p. 2). The complaint alleges that the Amazon marketplace is the Plaintiffs' "primary sales channel into the United States" for these products. (Compl. ¶8).

IV. Analysis of Infringement Allegations

The complaint, as an action for a declaratory judgment of non-infringement, does not contain affirmative infringement allegations or a claim chart mapping patent claims to the accused products. Instead, it asserts that "None of the Accused Products infringe Claims 1, 11, and 15 of the ’576 Patent, either literally or under the doctrine of equivalents." (Compl. ¶36). The complaint's theory of non-infringement is primarily based on the argument that the accused designs are similar to prior art (Exhibits E-L) and that any claim construction that would read on the Accused Products would also "ensnare" this prior art. (Compl. ¶¶ 37-38). The complaint does not provide a technical breakdown of how the Accused Products differ from the claim limitations. Therefore, the complaint does not provide sufficient detail for a claim chart analysis.

Identified Points of Contention

  • Scope Questions: The central dispute appears to be whether the specific mechanical configurations of the Plaintiffs' folding storage products fall within the scope of the ’576 Patent's claims. A key question for the court will be how the claim elements, such as "a first right panel rotatably coupled to a second right panel," apply to the folding mechanisms of the Accused Products.
  • Technical Questions: The complaint raises the question of whether there is a fundamental structural and functional difference between the Accused Products and the patented invention. Plaintiffs' non-infringement position appears to rely on an assertion that their products practice the prior art, raising the question of what specific features of the Accused Products are alleged to be disclosed in the prior art references but not claimed in the ’576 Patent.

V. Key Claim Terms for Construction

  • The Term: "a first right panel rotatably coupled to a second right panel" (from Claim 1).
  • Context and Importance: This term is foundational to the patent's claimed solution for providing rigidity to a collapsible structure. The definition of how the panels are "rotatably coupled" and how the "second right panel" is "proportioned to fit within an opening in the first right panel" will be critical in determining whether the folding mechanisms of the Accused Products meet these structural limitations. Practitioners may focus on this term because it describes the core mechanical novelty asserted by the patent holder.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term "rotatably coupled" itself is broad and could arguably cover any form of hinged connection between two panels that allows for relative rotation.
    • Evidence for a Narrower Interpretation: The specification describes this coupling in the context of specific embodiments, showing a "first hinge 27" connecting the panels along a vertical axis and a "first slideable member 58" that moves along a "first track 46" to lock them. (’576 Patent, col. 6:30-34, col. 7:4-13). An argument could be made that the term should be limited to this type of configuration, where one panel essentially functions as a door that closes an opening in the other and is secured by a separate locking slide.

VI. Other Allegations

  • Indirect Infringement: This section is not applicable, as the complaint is a declaratory judgment action for non-infringement.
  • Willful Infringement: This section is not applicable, as the complaint is a declaratory judgment action for non-infringement.

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

This case will likely center on two primary questions for the court:

  • A core issue will be one of claim scope: How broadly should the court construe the structural limitations of the claims, particularly the requirement for a multi-panel sidewall where one panel is "rotatably coupled" to and "proportioned to fit within an opening" in another? The answer will determine if the specific folding mechanisms of the Plaintiffs' various storage products are encompassed by the patent.
  • A second key question will be the impact of prior art on claim construction and validity: The complaint's repeated emphasis on prior art allegedly not considered by the patent office (Compl. ¶¶ 12-19) and its "ensnarement" argument (Compl. ¶¶ 37-38) suggests that the litigation will not only address infringement but may also involve a significant challenge to the validity of the ’576 Patent itself. The relevance and teachings of these prior art references will be a central point of contention.