Dbest Products Inc v. iBeauty Ltd Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dbest Products, Inc. (California)
  • Defendant: IBEAUTY LIMITED COMPANY (Colorado)
  • Plaintiff’s Counsel: Orbit IP, LLP
• Case Identification: 2:25-cv-04583, C.D. Cal., 05/21/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business in the district and has committed the alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s collapsible cart products infringe two patents related to collapsible cart structures that enhance load capacity and stability.
• Technical Context: The patents relate to mechanical improvements in collapsible utility carts, a consumer product category where features like durability, load capacity, and ease of folding are key market differentiators.
• Key Procedural History: The complaint alleges that Plaintiff has a policy and practice of marking its patented products to provide notice to the public, which may be relevant to a determination of damages.

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, "High Load Capacity Collapsible Carts", issued April 15, 2025 ('446 Patent)

The Invention Explained

• Problem Addressed: The patent addresses the problem that prior art collapsible carts, due to their folding nature, may not be "sufficiently sturdy to allow for transporting heavy objects" ('446 Patent, col. 1:13-17).
• The Patented Solution: The invention is a collapsible cart with sidewalls composed of two separate panels connected by a hinge. To provide rigidity when the cart is open, a "slideable member" moves along a track that spans both panels, locking them together into a single, sturdy wall. This allows the cart to support heavy loads while still being able to fold for storage once the member is slid back to its unlocked position ('446 Patent, Abstract; col. 5:8-30).
• Technical Importance: This design attempts to combine the structural integrity of a fixed-wall cart with the storage convenience of a collapsible one by introducing a specific panel-locking mechanism.

Key Claims at a Glance

• The complaint asserts at least one claim of the '446 Patent (Compl. ¶15). Independent claim 1 is representative and includes the following essential elements:
  • A collapsible cart configured to transition from a closed condition to an open condition.
  • A rigid frame forming a compartment, including a front wall, a rear wall, a right sidewall, a left sidewall, and a bottom wall.
  • The right sidewall comprising a first right panel rotatably coupled to a second right panel.
  • A first track formed along the first and second right panels.
  • A first slideable member engaged with the first track, which is movable between an open position (allowing folding) and a closed position to "selectively lock" the first right panel to the second right panel.

U.S. Patent No. 12,304,546, "Collapsible Carts", issued May 20, 2025 ('546 Patent)

The Invention Explained

• Problem Addressed: The patent identifies the same technical problem as the '446 Patent: the need for improvements in collapsible carts to address the structural instability that prevents them from effectively transporting heavy objects ('546 Patent, col. 2:23-28).
• The Patented Solution: This invention discloses a collapsible cart with a frame of at least five walls. At least one of the opposing walls consists of a first panel rotatably coupled to a second panel. The solution for providing stability involves a "first latch part" on the edge of the first panel and a "second latch part" on the edge of the second panel. These parts are "configured to mate with one another" to hold the two panels "in a common plane," thereby locking the wall in its open, useable state ('546 Patent, col. 13:39-49).
• Technical Importance: This patent provides an alternative locking mechanism, using mating latch components rather than a sliding member on a track, to achieve the goal of a sturdy yet collapsible cart.

Key Claims at a Glance

• The complaint asserts at least one claim of the '546 Patent (Compl. ¶20). Independent claim 1 is representative and includes the following essential elements:
  • A collapsible cart with a frame of at least five walls, where at least three walls are configured to fold inwardly.
  • One of the opposing walls consists of a first panel and a second panel that is rotatably coupled to the first.
  • 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 latched.

III. The Accused Instrumentality

• Product Identification: The complaint identifies the accused instrumentalities as "numerous products" sold by Defendant on Amazon.com, collectively referred to as the "Accused Products" (Compl. ¶13). A specific list of products by Amazon Standard Identification Number (ASIN) is referenced as Exhibit C, which was not provided with the complaint document (Compl. ¶¶1-2).
• Functionality and Market Context: The complaint alleges that the Accused Products are collapsible carts that infringe the asserted patents (Compl. ¶13). It states that representative claim charts demonstrating the infringing functionality are attached as exhibits (Compl. ¶¶10, 20). However, as these exhibits were not provided, the complaint itself does not contain sufficient detail for a technical analysis of the Accused Products' specific operational features.

IV. Analysis of Infringement Allegations

The complaint references claim charts in Exhibits D and E to detail its infringement theories, but these exhibits were not provided. Therefore, a tabular analysis is not possible. The narrative infringement theory is summarized below.

No probative visual evidence provided in complaint.

• '446 Patent Infringement Allegations
  The complaint alleges that Defendant directly infringes the '446 Patent by making, selling, and/or offering for sale the Accused Products in the United States (Compl. ¶15). The complaint states that a claim chart in Exhibit D demonstrates how the Accused Products satisfy each limitation of at least one claim (Compl. ¶¶9-10). Without this exhibit, the specific factual basis for how the Accused Products allegedly incorporate a "rigid frame," a two-panel "right sidewall," a "first track," and a "first slideable member" is not available for analysis from the complaint document.

• '546 Patent Infringement Allegations
  The complaint alleges direct infringement of the '546 Patent through the sale and distribution of the same Accused Products (Compl. ¶20). It refers to a claim chart in Exhibit E for a detailed breakdown of how the products meet the limitations of at least one claim (Compl. ¶20). As this exhibit is also missing, the complaint's specific theory of how the Accused Products allegedly meet the limitations of a five-wall frame with two-panel walls that utilize mating "latch parts" to lock them in a "common plane" is not detailed in the provided document.

• Identified Points of Contention:

  • Factual Questions: A central question for discovery will be to determine the precise mechanical structure of the Accused Products. The case will depend on the evidence produced showing whether those products contain structures corresponding to the claimed locking mechanisms.
  • Scope Questions ('446 Patent): An issue for the court may be whether the accused carts contain a structure that meets the specific definitions of a "track" and a "slideable member" that moves along it to "selectively lock" the panels, or if they use a different locking mechanism that Plaintiff will argue is equivalent.
  • Scope Questions ('546 Patent): The infringement analysis will likely focus on whether the Accused Products feature components that can be properly characterized as mating "latch parts" on the edges of the folding panels and whether those parts function to hold the panels in a "common plane" as required by the claims.

V. Key Claim Terms for Construction

• Term ('446 Patent, Claim 1): "first slideable member"

  • Context and Importance: This term defines the active locking component of the '446 Patent's invention. The infringement analysis will hinge on whether a component in the accused product "slides" along a "track" to lock the panels, as opposed to snapping, rotating, or otherwise fastening.
  • Intrinsic Evidence for a Broader Interpretation: The specification describes the member functionally, stating it "may cooperatively engage the first track" and is "movable between an open position... to a closed position" ('446 Patent, col. 5:19-23). This language could support an interpretation covering any component that moves linearly along a guide to achieve a lock, regardless of its specific shape.
  • Intrinsic Evidence for a Narrower Interpretation: The patent figures depict a specific embodiment of the slide lock (58) that fits over and slides along a raised rail or track (46) ('446 Patent, FIG. 2, FIG. 8). A defendant may argue the term should be construed more narrowly to be consistent with this disclosed structure, which travels along the exterior of the panels.

• Term ('546 Patent, Claim 1): "latch part"

  • Context and Importance: This term is central to the '546 Patent and distinguishes its claimed invention from the "slideable member" of the '446 Patent. Whether the accused device infringes the '546 patent will depend on whether its fastening components are properly construed as "latch parts."
  • Intrinsic Evidence for a Broader Interpretation: The claims use broad, functional language, requiring a "first latch part" and a "second latch part" that are "configured to mate with one another" ('546 Patent, col. 13:42-47). This could be argued to encompass any pair of corresponding interlocking features (e.g., a hook and eye, a tab and slot) on the edges of the panels.
  • Intrinsic Evidence for a Narrower Interpretation: The term "latch" itself often implies a mechanism with a catch and movable keeper. Furthermore, the claim requires the latch parts to "hold the first and second panels in a common plane" ('546 Patent, col. 13:47-49). This functional result could be argued to limit the scope of the term to only those fastener types that achieve this specific planar alignment, potentially excluding other connectors.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain allegations of indirect infringement. It pleads only "direct infringement" (Compl. ¶1).
• Willful Infringement: The complaint does not contain an explicit allegation of willful infringement.

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

• A primary question will be evidentiary and factual: given the absence of claim charts, what evidence will Plaintiff introduce to demonstrate that the Accused Products incorporate the specific locking mechanisms of the '446 and '546 patents—namely, a "slideable member" on a "track" for the '446 Patent, and mating "latch parts" for the '546 Patent?
• A dispositive issue will likely be claim construction: how will the court define the scope of the central locking elements? Specifically, does the term "first slideable member" ('446 Patent) require the specific external sliding lock shown in the patent's figures, and does the term "latch part" ('546 Patent) encompass any mating feature or is it limited to a more conventional latching mechanism?
• A key strategic question will involve the distinction between the asserted patents: how will Plaintiff differentiate its infringement theories for the '446 Patent (based on a "slideable member") and the '546 Patent (based on "latch parts") when applied to the same set of Accused Products, and can Defendant exploit any perceived overlap or inconsistency in those theories?