DCT
2:25-cv-04621
Dbest Products Inc v. Guangzhou Yichenkeji Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Dbest Products, Inc. (California)
- Defendant: Guangzhou Yichenkeji Ltd (Chinese company)
- Plaintiff’s Counsel: Orbit IP, LLP
- Case Identification: 2:25-cv-04621, C.D. Cal., 05/21/2025
- Venue Allegations: Venue is asserted on the basis that Defendant is subject to personal jurisdiction in the district, allegedly by conducting substantial business there, including committing the alleged acts of patent infringement.
- Core Dispute: Plaintiff alleges that Defendant’s collapsible utility carts infringe two patents related to structural features that enhance stability and locking mechanisms.
- Technical Context: The technology relates to the consumer goods market for portable, collapsible carts, where a key design challenge is balancing lightweight, foldable convenience with the structural rigidity needed to carry heavy loads.
- Key Procedural History: The patents-in-suit claim priority to provisional applications filed in 2020 and are the result of a lengthy chain of continuation and continuation-in-part applications. The complaint alleges that Plaintiff has complied with patent marking statutes, providing notice to the public of the patents covering its products.
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 (’446 Patent)
Issued April 15, 2025
The Invention Explained
- Problem Addressed: The patent describes a deficiency in prior art collapsible carts, noting that their collapsible nature often results in sidewalls that are not "sufficiently sturdy to allow for transporting heavy objects" (’446 Patent, col. 2:13-16).
- The Patented Solution: The invention is a collapsible cart with sidewalls composed of two distinct panels connected by a hinge. To provide rigidity when the cart is open, the design incorporates a "track" that spans both panels and a "slideable member" that moves along this track. When the slideable member is moved to a closed position, it locks the two panels together, creating a structurally sound sidewall capable of supporting a higher load. (’446 Patent, Abstract; col. 5:16-41).
- Technical Importance: This mechanism aims to provide the structural integrity of a rigid cart while retaining the convenient, space-saving storage of a foldable design. (’446 Patent, col. 2:10-16).
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 between a closed (folded) and open (expanded) 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 and extending across both the first and second right panels.
- A "first slideable member" cooperatively engaged to the first track, which is movable between an open position (allowing folding) and a closed position (locking the panels together).
- The complaint reserves the right to assert infringement of other claims.
U.S. Patent No. 12,304,546 - Collapsible Carts (’546 Patent)
Issued May 20, 2025
The Invention Explained
- Problem Addressed: Like the ’446 Patent, this patent addresses the problem that "the sidewalls may not be sufficiently sturdy to allow for transporting heavy objects" in conventional collapsible carts. (’546 Patent, col. 2:25-27).
- The Patented Solution: This invention describes a collapsible cart with five walls, where at least two opposing walls are comprised of a first and a second panel. The core inventive concept is a locking system consisting of a "first latch part" on the edge of the first panel and a "second latch part" on the edge of the second panel. These latch parts are configured to "mate with one another" to hold the panels in a common, rigid plane when the cart is in its open, usable state. (’546 Patent, col. 13:35-49).
- Technical Importance: This approach provides an alternative mechanism for reinforcing the foldable walls of a utility cart, seeking to improve its load-bearing capacity and stability during use. (’546 Patent, Abstract).
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, three of which fold inwardly.
- Two opposing walls are each rotatably coupled to a non-folding wall.
- One of the opposing walls consists of a first panel and a second panel rotatably coupled together.
- A "first latch part" on an edge of the first panel.
- A "second latch part" on an edge of the second panel.
- The latch parts are configured to mate to hold the panels in a common plane.
- The complaint reserves the right to assert infringement of other claims.
III. The Accused Instrumentality
Product Identification
- The "Accused Products" are identified as collapsible carts sold by Defendant on Amazon.com (Compl. ¶¶11, 13). The complaint states that a schedule of specific Amazon Standard Identification Numbers (ASINs) is attached as Exhibit C, which was not publicly filed with the complaint.
Functionality and Market Context
- The complaint alleges that the Accused Products are sold to consumers in the United States, including within the Central District of California (Compl. ¶11). It alleges these products directly infringe the patents-in-suit, implying they possess the structural features of the patented inventions, such as foldable, lockable sidewalls (Compl. ¶¶15, 20). The complaint does not provide specific technical details about the operation of the Accused Products beyond these general allegations of infringement.
IV. Analysis of Infringement Allegations
The complaint alleges that representative claim charts are attached as Exhibits D and E, but these exhibits were not filed on the public docket. The infringement theory is therefore based on the general allegations that the Accused Products practice each limitation of at least one claim of each patent.
No probative visual evidence provided in complaint.
’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 complaint alleges the Accused Products are collapsible carts offered for sale and sold by Defendant. | ¶15 | col. 7:13-16 |
| a rigid frame forming a compartment, the rigid frame having a front wall, a rear wall, a right sidewall, a left sidewall, and a bottom wall... | The complaint alleges the Accused Products infringe, which suggests they possess a corresponding frame structure. | ¶15 | col. 7:17-21 |
| the right sidewall comprising a first right panel rotatably coupled to a second right panel; | The complaint’s infringement allegation suggests the Accused Products possess a right sidewall made of two rotatably coupled panels. | ¶15 | col. 7:22-23 |
| a first track formed along the first right panel and the second right panel... | The complaint’s infringement allegation suggests the Accused Products possess a track spanning the two right-side panels. | ¶15 | col. 7:24-27 |
| a first slideable member cooperatively engaged to the first track, the first slideable member is movable...to selectively lock the first right panel to the second right panel... | The complaint’s infringement allegation suggests the Accused Products possess a corresponding slideable member that locks the sidewall panels. | ¶15 | col. 7:28-34 |
’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... | The complaint alleges the Accused Products are collapsible carts offered for sale and sold by Defendant. | ¶20 | col. 13:20-27 |
| 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’s infringement allegation suggests the Accused Products possess an opposing wall made of two rotatably coupled panels. | ¶20 | col. 13:30-34 |
| 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 complaint’s infringement allegation suggests the Accused Products possess corresponding latch parts on the panel edges. | ¶20 | col. 13:35-40 |
| 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’s infringement allegation suggests the latch parts in the Accused Products mate to hold the panels in a rigid, common plane. | ¶20 | col. 13:41-44 |
Identified Points of Contention
- Scope Questions: A central issue for the ’446 Patent will be the interpretation of "track" and "slideable member." The court will need to determine if these terms are limited to the specific channel-and-slider embodiments shown in the patent’s figures or if they can be read more broadly to cover other forms of sliding lock mechanisms. Similarly, for the ’546 Patent, the scope of "latch part" and what it means to "mate" will be critical.
- Technical Questions: The primary technical question will be evidentiary. As the complaint lacks specific details on the accused products' construction, the case will turn on whether Plaintiff can demonstrate that the actual physical structure of Defendant’s carts includes elements that meet every limitation of the asserted claims. A mismatch in the mechanical operation of the locking features could form the basis of a non-infringement defense.
V. Key Claim Terms for Construction
The Term: "a first slideable member cooperatively engaged to the first track" (’446 Patent, Claim 1)
Context and Importance: This term defines the core locking mechanism of the ’446 Patent. The interpretation of "cooperatively engaged" will be critical; it determines whether the claim requires a specific, guided interaction (like a slider in a channel) or could read on a wider array of sliding clasps or locks. Practitioners may focus on this term because it appears to be the primary point of novelty.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is general, referring only to a "slideable member" and a "track" without further structural limitation. Plaintiff may argue that this language should be given its plain and ordinary meaning, covering any member that slides along a defined path to lock the panels.
- Evidence for a Narrower Interpretation: The specification consistently depicts a specific embodiment where the track (46) is a channel and the slideable member (58) is a component that fits within and slides along that channel (’446 Patent, Fig. 2, Fig. 8; col. 5:16-24). A defendant may argue that the term should be limited to this disclosed structure or its equivalents, pointing to the term "cooperatively engage" as requiring this specific physical relationship.
The Term: "latch part" (’546 Patent, Claim 1)
Context and Importance: This term is central to the locking mechanism of the ’546 Patent. Its construction will determine what types of connecting hardware fall within the scope of the claims. The dispute may center on whether any pair of connecting elements constitutes "latch parts" or if the term implies a more specific mechanical interlock.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "latch" is a generic mechanical term. Plaintiff could argue it should be construed broadly to encompass a wide variety of fasteners, hooks, or clips that serve to join the two panels.
- Evidence for a Narrower Interpretation: The claims require the latch parts to "mate" in a way that holds the panels "in a common plane" (’546 Patent, col. 13:41-44). A defendant may argue this functional requirement narrows the term's scope to only those mechanisms that provide sufficient structural alignment and rigidity, potentially excluding simple clasps that do not enforce coplanarity.
VI. Other Allegations
The complaint pleads only direct infringement under 35 U.S.C. § 271 and does not contain allegations of indirect or willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction and scope: Can the terms "slideable member" and "track" in the ’446 Patent be construed broadly enough to cover the specific locking mechanism used in the Accused Products, or are they limited to the channel-and-slider structure depicted in the patent's figures? A similar question of scope applies to the term "latch part" in the ’546 Patent.
- A key evidentiary question will be one of technical proof: Given the absence of detailed infringement contentions in the public complaint, the case will depend entirely on Plaintiff's ability to present evidence—likely through expert testimony and analysis of the physical products—demonstrating that the accused carts meet every structural and functional limitation of the asserted claims. The defense will likely focus on identifying any technical or operational mismatch between the accused mechanism and the claim language.