DCT

2:25-cv-04566

Dbest Products Inc v. Amazon.com

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-04566, C.D. Cal., 05/21/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Amazon has consented to venue and has regular places of business within the judicial district.
  • Core Dispute: Plaintiff alleges that certain collapsible shopping carts sold by Defendant infringe a patent related to stackable and collapsible carts with specific locking mechanisms.
  • Technical Context: The technology concerns the field of portable, collapsible carts, focusing on mechanical improvements to enhance structural rigidity when expanded for use.
  • Key Procedural History: The complaint alleges that Plaintiff previously notified Defendant of the infringement through Amazon’s "Notice of Claimed Infringement" (NOCI) procedure. It further alleges that although Amazon initially removed the accused product listings, it later reinstated them, prompting the current lawsuit.

Case Timeline

Date Event
2020-01-06 Earliest Patent Priority Date ('576 Patent)
2024-10-01 '576 Patent Issue Date
Late 2024 Plaintiff sends Notice of Claimed Infringement
2025-05-21 Complaint Filing Date

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

U.S. Patent No. 12,103,576 - “Stackable Collapsible Carts,” issued October 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" and concludes that "the need for improvements to collapsible carts still remains" (’576 Patent, col. 1:21-25).
  • The Patented Solution: The invention claims to solve this problem with a collapsible cart having multi-panel sidewalls that are locked together for rigidity when the cart is in its open, expanded condition (’576 Patent, Abstract). As detailed in the specification, a sidewall is comprised of a "first right panel rotatably coupled to a second right panel" (’576 Patent, col. 1:38-40). A "first lock assembly," which includes a "slideable member" moving along a "track" spanning both panels, is used to "selectively lock" the panels together, thereby reinforcing the structure (’576 Patent, col. 1:41-50).
  • Technical Importance: The described mechanism seeks to combine the portability of a folding cart with the structural integrity required to carry heavy items, addressing a key performance trade-off in the product category (’576 Patent, col. 1:21-25).

Key Claims at a Glance

  • The complaint asserts infringement of at least one claim, and based on the patent, a representative independent claim is Claim 1 (’576 Patent, col. 11:41).
  • Independent Claim 1 requires, among other elements:
    • A collapsible cart with a rigid frame including front, rear, right, and left sidewalls.
    • The right sidewall comprises a "first right panel rotatably coupled to a second right panel," with the second panel proportioned to fit within an opening in the first.
    • A "first track" that is "formed along the first right panel and the second right panel."
    • A "first slideable member" that is "cooperatively engaged to the first track" and is movable along it between an open and a closed position to "selectively lock the first right panel to the second right panel."
  • The complaint does not specify which dependent claims may be asserted.

III. The Accused Instrumentality

Product Identification

The "Accused Products" are identified as "numerous shopping carts sold on Amazon.com" (Compl. ¶15). The complaint lists specific Amazon Standard Identification Numbers (ASINs) for products that Amazon itself allegedly "offers for sale and sells" (Compl. ¶16).

Functionality and Market Context

The complaint alleges the Accused Products are collapsible shopping carts that infringe the ’576 Patent (Compl. ¶¶15-16, 20). It further alleges that after Plaintiff provided notice of infringement, Amazon initially removed the products but then "reinstated them shortly thereafter and continues to offer the Accused Products for sale and sell them" (Compl. ¶17).

IV. Analysis of Infringement Allegations

The complaint alleges that Amazon directly infringes the ’576 Patent by offering for sale and selling the Accused Products (Compl. ¶20). It states that a representative claim chart is attached as Exhibit H; however, this exhibit was not included with the public filing (Compl. ¶22). The complaint also provides references to screenshots from Amazon's website, attached as Exhibits C-G, which allegedly identify Amazon as the seller of the Accused Products (Compl. ¶4-5). Without the claim chart, the complaint's public-facing infringement theory is based on the general assertion that the Accused Products practice the limitations of at least one claim of the ’576 Patent.

Identified Points of Contention

Scope Questions

A central dispute may turn on the definitions of "track" and "slideable member." The infringement analysis will question whether the locking mechanisms of the Accused Products, if any, fall within the scope of these terms as defined by the patent. For example, does a simple snap-fit or rotating latch meet the "slideable member" limitation, which the patent describes as being "movable along the first track"? (’576 Patent, col. 12:56-59).

Technical Questions

The complaint does not provide technical details or images of the Accused Products' construction. A key evidentiary question will be whether the Accused Products actually contain a multi-panel sidewall and a locking mechanism that functions as recited in Claim 1, specifically a track that spans two rotatably coupled panels and a member that slides along that track to lock them.

V. Key Claim Terms for Construction

Key Term: "slideable member"

Context and Importance

This term is at the core of the claimed locking mechanism. Its construction will be critical in determining infringement, as the way the accused carts lock, if at all, will be compared to this limitation. Practitioners may focus on this term because its scope will determine whether various types of latches or locks are covered by the claim.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The patent does not appear to provide an explicit definition for "slideable member," which may support an interpretation based on its plain and ordinary meaning, potentially encompassing any component that slides to engage a lock.
  • Evidence for a Narrower Interpretation: The specification consistently describes the member as being "cooperatively engaged to the first track" and "movable along the first track" (’576 Patent, col. 12:55-59). Figures such as 42B show a specific sliding latch structure (58), which could be used to argue that the term is limited to a member that travels along a defined guideway, not one that simply slides into a final position without a track.

Key Term: "track"

Context and Importance

This term is inextricably linked to "slideable member." The claim requires the track to be "formed along the first right panel and the second right panel" (’576 Patent, col. 12:50-52). The definition of "track" will determine whether the Accused Products meet this structural requirement.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: Parties might argue "track" can refer to any path or channel that guides the "slideable member," even if it is not a single, physically continuous piece across the two panels.
  • Evidence for a Narrower Interpretation: The claim language requiring the track to extend "from a first position on the first right panel to a second position on the second right panel" suggests a specific alignment and function (’576 Patent, col. 12:52-54). A defendant might argue this requires a dedicated structural feature that serves as a guideway, as opposed to an incidental edge or surface.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement against Amazon for the actions of its third-party sellers (Compl. ¶¶27-31). The factual basis includes allegations that Amazon provides the online platform and tools for sellers to market the Accused Products, advertises the benefits of its marketplace to sellers, and benefits financially from the resulting sales (Compl. ¶29). The complaint alleges Amazon "specifically intends that its sellers directly infringe" (Compl. ¶30).

Willful Infringement

The complaint alleges willful infringement based on pre-suit knowledge (Compl. ¶22). The basis for this allegation is the notice Plaintiff provided to Amazon "in late 2024, through Amazon's Notice of Claimed Infringement ('NOCI') procedure" (Compl. ¶15). The complaint alleges that Amazon's subsequent reinstatement and continued sale of the Accused Products were "deliberate, willful, and intentional" acts performed with "full knowledge" of the ’576 Patent and the alleged infringement (Compl. ¶¶6, 17, 22).

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

  • A core issue will be one of structural correspondence: Does the locking mechanism used in the accused shopping carts incorporate the specific, multi-element structure of Claim 1, namely a "slideable member" that moves along a "track" spanning two distinct, rotatably-coupled panels? Or do the accused products achieve sidewall rigidity through a mechanically different design that falls outside the claim's literal scope?
  • A second central question will relate to scienter and liability: What was Amazon's knowledge and intent, both as a direct seller of certain accused products and as a marketplace operator for others? The court's analysis of willfulness and inducement will likely depend heavily on the facts surrounding the NOCI notice and Amazon's decision to reinstate the product listings after they were allegedly taken down.