Dbest Products Inc v. Aborder Products Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: dbest products, Inc. (California)
  • Defendant: Aborder Products, Inc. (Texas)
  • Plaintiff’s Counsel: Orbit IP, LLP
• Case Identification: 2:25-cv-04591, C.D. Cal., 05/21/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendant, on information and belief, commits acts of infringement in the district and does substantial business there.
• Core Dispute: Plaintiff alleges that Defendant’s line of portable carts infringes two patents related to the design and features of high-load-capacity collapsible carts.
• Technical Context: The technology at issue involves mechanical improvements to foldable utility carts, focusing on features that enhance structural stability and ease of use when transitioning between collapsed and expanded states.
• Key Procedural History: The complaint alleges that Plaintiff marks its own cart products with the patent numbers-in-suit, which may be intended to establish constructive notice to the public and support a claim for damages.

Case Timeline

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

U.S. Patent No. 12,275,446, "High Load Capacity Collapsible Carts" (Issued Apr. 15, 2025)

• The Invention Explained:
  • Problem Addressed: The patent identifies a problem in prior art collapsible carts where the collapsible nature of the sidewalls renders them insufficiently sturdy for transporting heavy objects (’446 Patent, col. 1:13-16).
  • The Patented Solution: The invention addresses this by incorporating a specific locking mechanism for the foldable sidewalls. The sidewalls are composed of two hinged panels, and a "slideable member" moves along a track that spans both panels. When moved to a closed position, this member locks the two panels together, creating a rigid and stable sidewall suitable for higher loads (’446 Patent, Abstract; col. 5:18-39). The interaction of the slideable member (58) with the track (46) across two hinged panels (26, 28) is illustrated in patent figures such as FIG. 2 (’446 Patent, FIG. 2).
  • Technical Importance: This design aims to provide the convenience of a collapsible cart with the structural integrity of a rigid container, increasing its utility for heavier-duty applications.
• Key Claims at a Glance:
  • The complaint asserts at least one claim of the '446 Patent (Compl. ¶15). Independent claim 1 is representative.
  • Essential elements of Claim 1:
    • A collapsible cart configured to transition from a closed to an open condition.
    • A rigid frame with a front wall, rear wall, right sidewall, left sidewall, and bottom wall.
    • The right sidewall comprises 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 track, movable between an open position and a 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.

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

• The Invention Explained:
  • Problem Addressed: Similar to the '446 Patent, this patent addresses the need for improved structural stability in collapsible carts, noting that prior art sidewalls "may not be sufficiently sturdy to allow for transporting heavy objects" ('546 Patent, col. 2:24-27).
  • The Patented Solution: This patent discloses several inventive concepts for improving collapsible carts. The embodiment described in claim 1 focuses on a cart with five walls where at least three walls fold inwardly. A key feature is that one of the folding walls is composed of two rotatably coupled panels, each having a "latch part" on its edge. These latch parts are configured to mate with each other to hold the two panels in a common plane, thereby locking the wall in its open, expanded position (’546 Patent, col. 13:20-47).
  • Technical Importance: This approach offers an alternative mechanism for ensuring wall rigidity in a collapsible structure, potentially simplifying the design by integrating the locking feature directly into the edges of the folding panels.
• Key Claims at a Glance:
  • The complaint asserts at least one claim of the '546 Patent (Compl. ¶20). Independent claim 1 is representative.
  • Essential elements of Claim 1:
    • A collapsible cart with a frame of at least five walls, where three are configured to fold inwardly.
    • One of the folding 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 and hold the panels in a common plane.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

• Product Identification: The complaint identifies "numerous products (the 'Accused Products') sold by Defendant on Amazon" (Compl. ¶13). A specific list was purportedly provided as Exhibit C to the complaint, which was not available for this analysis.
• Functionality and Market Context: The complaint does not provide any specific details regarding the technical functionality, operation, or market context of the Accused Products. All substantive allegations regarding the products' features are deferred to external exhibits not available for this analysis (Compl. ¶¶ 15, 20).

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant directly infringes the '446 Patent and the ’546 Patent by "offering for sale, selling, and/or otherwise distributing the Accused Products" in the United States (Compl. ¶¶ 15, 20). The pleading's narrative theory of infringement is conclusory, stating that the Accused Products satisfy the limitations of the patents and referencing claim chart exhibits (Exhibits D and E) that were not available for this analysis (Compl. ¶¶ 15, 20).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • '446 Patent: A central issue will be factual and evidentiary: do the Accused Products contain a locking mechanism for their sidewalls that meets the claim limitations of a "first track" and a "first slideable member" movable along that track? The analysis will depend on the specific structure and operation of the locking features on Defendant’s carts.
  • '546 Patent: The key question for infringement of the ’546 Patent will be whether the Accused Products employ mating "latch parts" disposed on the edges of two rotatably coupled panels, as required by claim 1. This raises a technical question of whether any locking feature on the accused carts functions as the claimed "latch part" and is located "on an edge" of the panels.

V. Key Claim Terms for Construction

'446 Patent:

• The Term: "first slideable member" (from Claim 1)
• Context and Importance: This term is the central active component of the locking mechanism in claim 1. The infringement analysis will hinge on whether the feature on the accused product that secures the folding panels can be properly characterized as a "slideable member" that moves along a "track."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term itself is functionally broad. The claims do not impose specific structural limitations on the "slideable member" beyond its cooperative engagement with the "first track" and its movement between open and closed positions (’446 Patent, col. 7:27-32).
  • Evidence for a Narrower Interpretation: The specification consistently depicts the slideable member as a specific type of clasp (58) that slides over the junction of the two panels (e.g., ’446 Patent, FIG. 2, 8). A party may argue that the term should be limited to the structure of this disclosed embodiment, particularly its function of sliding over a track rather than within it.

'546 Patent:

• The Term: "latch part" (from Claim 1)
• Context and Importance: The definition of "latch part" and the requirement that two such parts "mate with one another" are critical to the infringement theory for claim 1. This distinguishes the invention from other locking mechanisms, such as an overlying sliding clasp.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: "Latch part" is a generic mechanical term. The claim only requires that it be "disposed on an edge" of a panel and be "configured to mate" with another latch part (’546 Patent, col. 13:31-43). This could arguably encompass a wide variety of interlocking features.
  • Evidence for a Narrower Interpretation: The claim's description of two distinct "latch parts" on opposing edges that "mate" suggests a direct, complementary engagement (e.g., a hook-and-eye, or a tab-and-slot), rather than a single, separate piece that slides over both panels. A court may construe this term to require such a two-part, directly interacting structure, distinguishing it from the invention of the '446 Patent.

VI. Other Allegations

• Indirect Infringement: The complaint does not include counts for, or allege specific facts to support, indirect infringement (i.e., induced or contributory infringement).
• Willful Infringement: The complaint does not contain an explicit allegation of willful infringement. However, it does allege that Plaintiff complies with its statutory duty to mark its patented products with the appropriate patent numbers (’446 Patent, col. 2:10-16; Compl. ¶10). This allegation of constructive notice under 35 U.S.C. § 287 could be used later in the litigation to support a claim that any post-issuance infringement was knowing and therefore willful.

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

• A primary issue is one of evidentiary support: The complaint is "bare-bones" and relies on unprovided exhibits for all of its substantive infringement contentions. A key question is whether discovery will produce evidence demonstrating that the specific mechanical structures of the Accused Products read on each element of the asserted patent claims.
• The case will also turn on a question of technical differentiation and claim scope: The two asserted patents claim distinct locking mechanisms—one using a "slideable member" on a "track" ('446 Patent) and the other using mating "latch parts" on panel edges ('546 Patent). A central question for the court will be the construction of these terms and whether the Defendant's products practice one, both, or neither of these specific patented solutions.