DCT
2:25-cv-04573
Dbest Products Inc v. Dongguan Xianghuo Trading Co Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Dbest Products, Inc. (California)
- Defendant: DONGGUAN XIANGHUO TRADING CO., LTD (China)
- Plaintiff’s Counsel: Orbit IP, LLP
- Case Identification: 2:25-cv-04573, C.D. Cal., 05/21/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is subject to personal jurisdiction in the district, based on allegations that Defendant has both consented to jurisdiction by previously suing Plaintiff in the district and conducts substantial business there.
- Core Dispute: Plaintiff alleges that Defendant’s collapsible cart products, sold online, infringe two patents related to locking mechanisms for improving the structural integrity of such carts.
- Technical Context: The case concerns the consumer market for portable, collapsible utility carts, where product designs seek to balance convenient, compact storage with the sturdiness required for carrying loads.
- Key Procedural History: The complaint alleges that Plaintiff has a policy of marking its products with the patent numbers-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2020-01-06 | Earliest Priority Date for '446 and '546 Patents |
| 2025-04-15 | U.S. Patent No. 12,275,446 Issues |
| 2025-05-20 | U.S. Patent No. 12,304,546 Issues |
| 2025-05-21 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,275,446
- Patent Identification: U.S. Patent No. 12,275,446, "High Load Capacity Collapsible Carts," issued April 15, 2025 (the "'446 Patent").
- The Invention Explained:
- Problem Addressed: The patent specification states that because of their collapsible nature, prior art cart designs have sidewalls that "may not be sufficiently sturdy to allow for transporting heavy objects" ('446 Patent, col. 1:13-16).
- The Patented Solution: The invention addresses this by reinforcing the hinged sidewalls. It discloses a cart where a sidewall is made of two panels that fold relative to each other. A "slideable member" moves along a track that spans both panels, and in a "closed position," this member locks the two panels together to form a rigid, planar wall ('446 Patent, Abstract; col. 5:10-39). Figure 2 illustrates the slideable member (58) designed to move along a track (46) across two panels (26, 28) of a sidewall (20) ('446 Patent, Fig. 2).
- Technical Importance: This design purports to provide the structural rigidity of a fixed cart when expanded, while retaining the ability to be collapsed into a compact form for storage ('446 Patent, col. 2:20-25).
- Key Claims at a Glance:
- The complaint asserts at least one claim without specifying which; Claim 1 is the first independent claim ('446 Patent, col. 7:13-40).
- Independent Claim 1 requires:
- A collapsible cart with a rigid frame (front, rear, right, left, and bottom walls) where the sidewalls fold inwardly.
- The right sidewall comprises a first right panel rotatably coupled to a second right panel.
- A "first track" is formed along and extends across both the first and second right panels.
- A "first slideable member" is engaged with the first track.
- The slideable member is movable between an "open position" (allowing folding) and a "closed position" that "selectively lock[s]" the first panel to the second panel.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 12,304,546
- Patent Identification: U.S. Patent No. 12,304,546, "Collapsible Carts," issued May 20, 2025 (the "'546 Patent").
- The Invention Explained:
- Problem Addressed: Similar to the '446 Patent, this patent addresses the lack of sturdiness in prior art collapsible carts, noting that sidewalls may not be sufficient for "transporting heavy objects" ('546 Patent, col. 2:25-27).
- The Patented Solution: The invention claims a collapsible cart with a specific wall configuration. It describes a cart with at least five walls, where one of the opposing walls that folds consists of two rotatably coupled panels. These panels are secured in a "common plane" by mating "latch parts" located on their respective edges, which are latched together to form a rigid wall ('546 Patent, col. 13:20-44). The specification describes an embodiment where a slideable member acts as the latching mechanism ('546 Patent, col. 7:4-23).
- Technical Importance: This approach provides a method for ensuring that foldable wall panels align and lock into a flat, stable surface, increasing the cart's load-bearing capacity when in its open, usable state ('546 Patent, col. 2:29-32).
- Key Claims at a Glance:
- The complaint asserts at least one claim without specifying which; Claim 1 is the first independent claim ('546 Patent, col. 13:20-44).
- Independent Claim 1 requires:
- A collapsible cart with a frame of at least five walls, where at least three walls rotatably fold inwardly.
- One of the opposing walls consists of a first panel and a second panel, rotatably coupled.
- A "first latch part" disposed on an edge of the first panel.
- A "second latch part" disposed on an edge of the second panel.
- The first and second latch parts are configured to "mate with one another" to hold the panels in a "common plane."
- When unlatched, the second panel is capable of rotating relative to the first.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The complaint identifies the "Accused Products" as numerous collapsible carts sold by Defendant on Amazon.com (Compl. ¶13). A schedule of specific Amazon Standard Identification Numbers (ASINs) is referenced as Exhibit C, but this exhibit was not included with the filed complaint (Compl. ¶13).
Functionality and Market Context
- The complaint alleges the Accused Products are collapsible carts that are offered for sale, sold, and distributed within the United States, including within the judicial district (Compl. ¶11, ¶15, ¶20). Based on the infringement allegations, these products are alleged to possess a frame with hinged, foldable sidewalls that include a mechanism for locking adjacent wall panels together to increase rigidity when the cart is assembled for use (Compl. ¶15, ¶20). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint alleges direct infringement but refers to representative claim charts in Exhibits D and E, which were not provided with the publicly filed document (Compl. ¶15, ¶20). The analysis below is based on the narrative allegations and the language of the primary independent claim of each patent.
'446 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged 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 collapsible cart comprising: a rigid frame forming a compartment... | The complaint alleges the Accused Products are collapsible carts that can be expanded for use and folded for storage. | ¶13, ¶15 | col. 7:13-16 |
| the right sidewall comprising a first right panel rotatably coupled to a second right panel; | The complaint alleges the Accused Products have a sidewall made of at least two panels that fold relative to each other. | ¶15 | col. 7:20-22 |
| 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; | The complaint alleges the Accused Products possess the claimed track spanning both panels of the folding sidewall. | ¶15 | col. 7:23-27 |
| 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's theory necessarily relies on the Accused Products having a locking component that functions as the claimed "slideable member" moving along the track to lock the panels. | ¶15 | col. 7:28-34 |
- Identified Points of Contention:
- Structural Questions: A primary question will be whether the Accused Products contain a "track" and a "slideable member" as those terms are understood in the patent. The defense may argue that any locking mechanism on its products is structurally and functionally different from the specific sliding latch-on-a-track configuration claimed.
- Evidentiary Questions: Without the claim charts, it is an open question what evidence Plaintiff possesses to demonstrate that the Accused Products practice each specific limitation, particularly the "slideable member" and "track" elements.
'546 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A collapsible cart configured to transition from a closed condition... the frame comprises at least five walls, with at least three of the walls configured to rotatably fold inwardly... | The complaint alleges the Accused Products are five-walled collapsible carts whose walls fold for storage. | ¶13, ¶20 | col. 13:20-28 |
| one of the two opposing walls consists of a first panel and a second panel; and the second panel rotatably coupled to the first panel; | The complaint alleges the Accused Products have an opposing wall comprised of two distinct, hinged panels. | ¶20 | col. 13:31-34 |
| a first latch part disposed on an edge of the first panel...and a second latch part disposed on an edge of the second panel... | The infringement theory requires that the Accused Products feature distinct "latch parts" on the edges of the folding panels. | ¶20 | col. 13:35-39 |
| wherein the first latch part and the second latch part are configured to mate with one another and hold the first and second panels in a common plane... | The complaint alleges the corresponding features on the Accused Products mate to lock the panels into a single, flat plane. | ¶20 | col. 13:40-42 |
- Identified Points of Contention:
- Scope Questions: A key dispute may arise over the definition of "latch part." The defense could argue this term requires a specific type of interlocking component (e.g., a hook and catch) that is distinct from other fasteners, and that its products do not use such a mechanism.
- Technical Questions: The case raises the question of whether the locking mechanism in the Accused Products involves two distinct "latch parts" that "mate," or if it operates through a different principle, such as a single bridging element or friction lock.
V. Key Claim Terms for Construction
'446 Patent: "first slideable member"
- The Term: "first slideable member"
- Context and Importance: This term is the central active component of the locking mechanism in Claim 1. The definition will determine whether infringement requires a discrete component that physically slides along a defined path, or if it can read on a wider range of locking elements that move.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "member" is general. Plaintiff may argue that any component that moves ("is slideable") to achieve the locking function meets the definition, even if it doesn't look exactly like the embodiment.
- Evidence for a Narrower Interpretation: The specification consistently depicts this element as a distinct piece (58) that is "cooperatively engaged to the first track" and is "movable along the first track" ('446 Patent, col. 5:14-17; Fig. 2). A defendant would likely argue this context limits the term to a physical slider that travels along a structural guide or track, not just any moving part.
'546 Patent: "latch part"
- The Term: "latch part"
- Context and Importance: This term defines the locking mechanism in the '546 Patent. Its construction is critical because it appears different from the "slideable member" claimed in the sister '446 Patent, yet the patents share a nearly identical specification. Practitioners may focus on this term to see if Plaintiff can use it to cover a different or broader set of accused structures than the '446 Patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim requires two "latch parts" that "mate." Plaintiff could argue this is a functional description covering any two corresponding components that join together to lock the panels, including the slideable member and track described in the specification ('546 Patent, col. 7:4-10).
- Evidence for a Narrower Interpretation: A defendant may argue that the choice of "latch part" instead of "slideable member" invokes the doctrine of claim differentiation, suggesting it must mean something different. The common meaning of a "latch" often implies a hook-and-catch or bolt mechanism, which could be argued as narrower than the slideable member shown in the patent's figures.
VI. Other Allegations
- Indirect Infringement: The complaint only alleges direct infringement under 35 U.S.C. § 271 (Compl. ¶4).
- Willful Infringement: The complaint does not contain an explicit allegation of willful infringement. It does allege that Plaintiff complies with its marking policy to provide notice to the public that its products are protected by the patents-in-suit (Compl. ¶10). This allegation may form a basis for seeking enhanced damages later in the litigation if knowledge is proven, but willfulness is not pleaded at this stage.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope and differentiation: will the court construe the '446 Patent's "slideable member" and the '546 Patent's "latch part" as describing distinct structures, or can both terms read on the same accused mechanism? The use of different terms in the claims of two related patents with a shared specification will likely be a central point of legal argument.
- A key evidentiary question will be one of proof of infringement: given the boilerplate nature of the complaint and the absence of the referenced claim chart exhibits, the case will hinge on what evidence Plaintiff can produce to show that the accused carts, sold by a foreign entity on Amazon, actually practice the specific, and potentially distinct, locking mechanisms required by the asserted claims.