Dbest Products Inc v. Henan Yiqi Tech Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dbest Products, Inc. (California)
  • Defendant: Henan Yiqi Tech Co., Ltd (China)
  • Plaintiff’s Counsel: Orbit IP, LLP
• Case Identification: 2:25-cv-04610, C.D. Cal., 05/21/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is subject to personal jurisdiction in the district through its business activities.
• Core Dispute: Plaintiff alleges that Defendant’s collapsible cart products, sold in the U.S. via Amazon.com, infringe two patents related to mechanisms for reinforcing collapsible cart sidewalls.
• Technical Context: The technology addresses a structural weakness in conventional collapsible utility carts, aiming to increase their rigidity and load-bearing capacity for transporting heavy objects.
• Key Procedural History: The complaint alleges that Plaintiff has complied with statutory marking requirements by placing its patent numbers on protected products, a fact that may be used to establish notice for claims of enhanced damages.

Case Timeline

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

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

The Invention Explained

• Problem Addressed: The patent identifies a problem in prior art collapsible carts where "the sidewalls may not be sufficiently sturdy to allow for transporting heavy objects" due to their collapsible design (’446 Patent, col. 1:13-16).
• The Patented Solution: The invention solves this by constructing the cart’s sidewalls from two separate panels that are hinged together. To provide rigidity when the cart is open, a "slideable member" moves along a track that spans both panels, locking them into a single, flat, and more durable plane (’446 Patent, col. 5:9-30). This locking mechanism is depicted in Figure 8 of the patent, which shows the slideable member (58) securing the two right panels (26, 28) together.
• Technical Importance: This approach provides a mechanism to selectively convert flexible, folding walls into rigid, load-bearing structures, enhancing the utility of portable carts.

Key Claims at a Glance

• The complaint asserts at least one claim of the patent (Compl. ¶12). Independent claim 1 is representative and includes the following essential elements:
  • 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 right panel and the second right panel.
  • A first slideable member cooperatively engaged with the first track, movable between an open position and a closed position to selectively lock the two right panels together.

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

The Invention Explained

• Problem Addressed: Like the ’446 Patent, this patent addresses the lack of sturdiness in prior art collapsible carts that prevents them from effectively transporting heavy objects (’546 Patent, col. 2:24-26).
• The Patented Solution: This invention discloses a collapsible cart with multi-panel walls that are secured by a different mechanism. The solution involves a "fastener" comprising two mating members that are "integrally disposed" on the edges of the adjacent wall panels (’546 Patent, col. 14:15-33). When engaged, these integral members hold the panels in a substantially coplanar alignment to create a rigid wall. Figure 35 of the patent illustrates an embodiment where a first panel (18) and a second panel (20) form a wall, locked by a latch mechanism (58).
• Technical Importance: This design offers an alternative method for reinforcing collapsible structures, focusing on integrated latching components rather than a separate sliding piece on a track.

Key Claims at a Glance

• The complaint asserts at least one claim of the patent (Compl. ¶20). Independent claim 9 is representative and includes the following essential elements:
  • A collapsible cart with a frame of at least five walls.
  • A third wall comprises a first panel and a second panel rotatably coupled together.
  • A fastener configured to selectively secure the panels in a "substantially coplanar alignment."
  • The fastener includes a first fastener member "integrally disposed on an edge" of the first panel and a second fastener member "integrally disposed on an edge" of the second panel.
  • The first and second fastener members are configured to "mate" to hold the panels in alignment.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as numerous "Accused Products" sold by the Defendant on Amazon.com (Compl. ¶¶11, 13). The complaint states that a schedule of Amazon Standard Identification Numbers (ASINs) for these products is attached as Exhibit C (Compl. ¶¶3-4).

Functionality and Market Context

The complaint alleges the Accused Products are collapsible carts that infringe the patents-in-suit (Compl. ¶¶13, 15, 20). It does not, however, provide a specific technical description of the Accused Products' features or operation beyond the conclusory allegation of infringement.

IV. Analysis of Infringement Allegations

The complaint makes general allegations of direct infringement for both the ’446 and ’546 patents, referencing claim chart exhibits (Exhibits D and E) that were not provided with the publicly filed complaint (Compl. ¶¶12, 20). The complaint itself lacks specific factual allegations mapping the features of the Accused Products to the limitations of the asserted claims. A detailed side-by-side comparison is therefore not possible based on the provided documents.

Identified Points of Contention

• ’446 Patent: A central question will be evidentiary: do the Accused Products feature a locking mechanism that meets the definition of a "slideable member" that moves along a "track" spanning two hinged panels, as required by claim 1? The analysis will depend on the specific structure and operation of the Defendant's products.
• ’546 Patent: The key infringement question will be whether the Accused Products utilize a fastener with members that are "integrally disposed on an edge" of the panels, as recited in claim 9. This raises both a technical question of how the accused fasteners are constructed and a legal question regarding the scope of the term "integrally disposed."

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

From the ’446 Patent

• The Term: "first slideable member"
• Context and Importance: This term is the central inventive concept of claim 1. The outcome of the infringement analysis will depend on whether the accused locking component is a "slideable member" as construed by the court. Practitioners may focus on this term because its scope will determine whether the claim covers only specific sliding-latch embodiments or a broader range of locking mechanisms.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language requires only that the member be "cooperatively engaged to the first track" and "movable along the first track" (’446 Patent, col. 7:26-29), suggesting any component that slides along the defined track could suffice.
  • Evidence for a Narrower Interpretation: The specification's primary embodiment, shown in Figure 8, depicts a specific C-shaped sliding latch (58) (’446 Patent, col. 5:17-25). A party could argue that this embodiment limits the term to structures of that type.

From the ’546 Patent

• The Term: "integrally disposed on an edge"
• Context and Importance: This phrase defines the nature and location of the claimed fastener. The infringement question will turn on whether the accused product's latching components are "integral" to the panel edges. The term's construction is critical because it distinguishes the invention from carts that might use separate, non-integral fasteners.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue "integrally disposed" simply means the fastener forms a part of the edge, without requiring it to be molded as a single, unitary piece with the panel. The claims do not explicitly add such a limitation (’546 Patent, col. 14:22-26).
  • Evidence for a Narrower Interpretation: The figures, such as Figure 35, appear to show latching components (58) that are part of the same molded plastic as the panels themselves. A party could argue that "integrally" implies a unitary construction, distinguishing it from fasteners that are attached to the edge post-formation.

VI. Other Allegations

Indirect Infringement

The complaint does not allege indirect infringement (inducement or contributory infringement). The two counts are explicitly for direct infringement under 35 U.S.C. § 271 (Compl. ¶¶1, 15, 20).

Willful Infringement

The complaint does not contain a separate count for willful infringement. However, it alleges that Plaintiff marks its products with the relevant patent numbers in compliance with 35 U.S.C. § 287 (Compl. ¶10). This allegation may serve as a basis to argue that Defendant had pre-suit knowledge of the patents, which is a prerequisite for a later claim of willful infringement and potential enhanced damages.

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

1. A central issue will be evidentiary and factual: What is the precise mechanical structure of the Defendant's accused carts? The complaint lacks the specific factual allegations and exhibits needed to determine whether the products employ a sliding member on a track (implicating the ’446 Patent), integral edge-fasteners (implicating the ’546 Patent), or a different mechanism altogether.

2. The case will likely involve a significant claim construction dispute: The viability of the infringement claims will depend on the court’s interpretation of key phrases. A primary battleground will be the scope of "slideable member" in the ’446 Patent and the meaning of "integrally disposed on an edge" in the ’546 Patent.

3. A third question concerns the patentability distinction: The two asserted patents claim different solutions to the same technical problem. A key strategic question will be how Plaintiff differentiates the scope of the two patents and whether the Accused Products can be shown to read on the specific limitations of one, both, or neither of the claimed inventions.