Dbest Products Inc v. Yuhuanhongshengmaoyiyouxiangongsi

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dbest Products, Inc. (California)
  • Defendant: YUHUANHONGSHENGMAOYIYOUXIANGGONGSI, D/B/A AOCOOM (China)
  • Plaintiff’s Counsel: Orbit IP, LLP
• Case Identification: 2:25-cv-04592, C.D. Cal., 05/21/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is subject to personal jurisdiction in the Central District of California, based on doing substantial business in the district, including the alleged acts of infringement.
• Core Dispute: Plaintiff alleges that Defendant’s portable collapsible carts, sold in the U.S. via online retail platforms, infringe two patents related to high-load capacity collapsible cart designs.
• Technical Context: The technology relates to collapsible utility carts, a mature product category where innovations often focus on improving strength, stability, and ease of use when folded or deployed.
• Key Procedural History: Both asserted patents issued very recently, in April and May of 2025, with the complaint filed the day after the second patent issued. The patents claim priority to a provisional application filed in January 2020 and are part of a larger family of applications, suggesting an ongoing patent prosecution strategy by the Plaintiff. The complaint notes that Plaintiff marks its own products with patent numbers to provide public notice.

Case Timeline

Date	Event
2020-01-06	Earliest Priority Date for '446 & '546 Patents
2025-04-15	U.S. Patent No. 12,275,446 Issued
2025-05-20	U.S. Patent No. 12,304,546 Issued
2025-05-21	Complaint Filing Date

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

U.S. Patent No. 12,275,446 - "High Load Capacity Collapsible Carts"

• Patent Identification: U.S. Patent No. 12,275,446, "High Load Capacity Collapsible Carts," issued April 15, 2025.

The Invention Explained

• Problem Addressed: The patent describes a problem in the prior art where the collapsible nature of utility carts means their sidewalls 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 constructing the cart's sidewalls from multiple panels that are hinged together. To provide rigidity when the cart is open, the patent discloses a "first track" that extends across the hinged panels and a "first slideable member" that moves along this track to lock the panels together in a flat, stable configuration ('446 Patent, Abstract; col. 5:8-39). This mechanism is designed to prevent the sidewalls from buckling under load.
• Technical Importance: This design aims to provide the structural integrity of a rigid cart while retaining the storage convenience of a collapsible one, a key trade-off in this product space ('446 Patent, col. 1:13-18).

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 with a rigid frame (front wall, rear wall, right sidewall, left sidewall, bottom wall).
  • The right sidewall comprises a "first right panel rotatably coupled to a second right panel."
  • A "first track" is formed along both the first and second right panels.
  • A "first slideable member cooperatively engaged to the first track" is movable between an open position (allowing the panels to fold) and a closed position (locking the panels together).
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 12,304,546 - "Collapsible Carts"

• Patent Identification: U.S. Patent No. 12,304,546, "Collapsible Carts," issued May 20, 2025.

The Invention Explained

• Problem Addressed: Like the '446 Patent, this patent identifies the problem that prior art collapsible cart sidewalls "may not be sufficiently sturdy to allow for transporting heavy objects" ('546 Patent, col. 2:25-27).
• The Patented Solution: This patent proposes a similar multi-panel sidewall construction but claims a different locking mechanism. The solution involves a "first latch part" on the edge of one panel and a "second latch part" on the edge of the adjoining panel ('546 Patent, col. 13:31-43). These latch parts are configured to "mate with one another" to hold the panels "in a common plane," thereby creating a rigid sidewall.
• Technical Importance: This offers an alternative mechanical approach to solving the same sturdiness problem addressed by the '446 Patent, potentially covering a different range of product designs ('546 Patent, col. 14:1-17).

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 opposing walls consist of a first panel and a second panel.
  • The second panel is "rotatably coupled to the first panel."
  • A "first latch part" is disposed on an edge of the first panel.
  • A "second latch part" is disposed on an edge of the second panel.
  • The latch parts are configured to mate to "hold the first and second panels in a common plane."
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The "Accused Products" are identified as "numerous products" sold by Defendant on Amazon.com (Compl. ¶13). A schedule of specific Amazon Standard Identification Numbers (ASINs) is referenced as Exhibit C to the complaint (Compl. ¶¶1-2, Ex. C).

Functionality and Market Context

• The complaint alleges that the Accused Products are portable collapsible carts (Compl. ¶¶7, 13). It does not provide a technical description of how the Accused Products operate, instead referencing claim chart exhibits (Exhibits D and E) for a detailed breakdown of the alleged infringement (Compl. ¶¶15, 20). The complaint suggests the market for such carts is competitive, stating that Plaintiff "regularly monitors retail platforms" to identify infringing products (Compl. ¶12).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant directly infringes the '446 and '546 patents by selling the Accused Products in the United States (Compl. ¶¶15, 20). The complaint references claim chart exhibits (Ex. D for the '446 Patent, Ex. E for the '546 Patent) that purportedly demonstrate how the Accused Products meet each limitation of at least one claim of each patent (Compl. ¶¶15, 20). As these exhibits were not included with the complaint document, a detailed element-by-element analysis is not possible. The infringement theory is based on the assertion that the physical construction and operation of the Accused Products embody the patented inventions.

• Identified Points of Contention:
  • Technical Questions: The central technical dispute for the '446 Patent will be whether the Accused Products possess a locking mechanism that functions as a "slideable member" moving along a "track" as claimed. For the '546 Patent, the question will be whether the products employ distinct "latch parts" on the edges of the folding panels that "mate" to secure the wall. The case will depend on whether the accused locking mechanisms operate in the specific manner required by the claims of each respective patent.
  • Scope Questions: The infringement analysis may turn on the scope of key terms. For the '446 Patent, a question is whether the accused feature constitutes a "track" or if it is merely a guide or slot that falls outside the claim's scope. For the '546 Patent, the definition of "latch part" will be critical—does it cover any interlocking feature, or is it limited to a more specific type of mechanism?

V. Key Claim Terms for Construction

• '446 Patent
  • The Term: "a first slideable member cooperatively engaged to the first track" (Claim 1)
  • Context and Importance: This phrase describes the core locking mechanism of the '446 Patent. The interpretation of what constitutes a "slideable member" and a "track" will be determinative of infringement, as it defines the specific mechanical action patented.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself does not restrict the shape or material of the member or track, which could support an interpretation covering any component that slides along a defined path to lock the panels ('446 Patent, col. 7:26-39).
    • Evidence for a Narrower Interpretation: The specification discloses a specific embodiment where the slideable member is a clip-like structure (58) that engages a groove (46) ('446 Patent, col. 5:20-39; Fig. 2). A defendant may argue that the term should be limited to this disclosed structure or its equivalents.
• '546 Patent
  • The Term: "a first latch part" and "a second latch part" (Claim 1)
  • Context and Importance: These terms define the locking mechanism of the '546 Patent, distinguishing it from the "slider and track" of the '446 Patent. The definition of what qualifies as a "latch part" is central to the infringement analysis for this patent. Practitioners may focus on this term because the patent's own figures appear to show the slider-and-track mechanism of the '446 patent, not a distinct "latch part" mechanism, creating a potential ambiguity between the claims and the written description.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term "latch part" is a general mechanical term. A plaintiff may argue it should be given its plain and ordinary meaning, covering any pair of corresponding features that interlock or mate ('546 Patent, col. 13:40-49).
    • Evidence for a Narrower Interpretation: A defendant may argue that the claim's requirement that the parts "mate" to "hold" the panels in a plane implies a specific type of interlocking connection beyond a simple friction fit or clip. The potential inconsistency between the claims and the figures ('546 Patent, Figs. 1-9) may be used to argue for a narrower construction tied to the claim language alone.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain allegations of indirect infringement (i.e., induced or contributory infringement). The claims are limited to direct infringement under 35 U.S.C. § 271 (Compl. ¶¶4, 15, 20).
• Willful Infringement: The complaint does not explicitly allege willful infringement. While it states that Plaintiff marks its products with patent numbers, which can serve as notice to the public (Compl. ¶10), it does not allege that Defendant had pre-suit knowledge of the patents or engaged in conduct rising to the level of willfulness.

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

1. A central issue will be one of technical specificity: The two asserted patents claim distinct mechanical locking solutions for collapsible carts—a "slider on a track" ('446 Patent) and "mating latch parts" ('546 Patent). A primary question for the court will be whether the Defendant’s accused products practice the precise technical elements of one, both, or neither of these patented inventions.
2. The case will also present a key question of claim construction and scope: The meaning of terms like "slideable member" and "latch part" will be critical. In particular for the '546 patent, the court may need to resolve the potential tension between the "latch part" language in the claims and the "slider-and-track" mechanism depicted in the patent's own figures to determine the proper scope of the invention.
3. Finally, a core evidentiary question will be what proof Plaintiff offers to show infringement. As the complaint relies on non-public exhibits, the case will turn on the evidence, such as product teardowns and expert analysis, that Plaintiff presents to demonstrate that the accused carts sold on Amazon incorporate the specific structures and functionalities required by the patent claims.