Dbest Products Inc v. Guangzhou Beidouhuliankeji Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dbest Products, Inc. (California)
  • Defendant: Guangzhou Beidouhuliankeji Co Ltd. (China)
  • Plaintiff’s Counsel: Orbit IP, LLP
• Case Identification: 2:25-cv-04623, C.D. Cal., 05/21/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is subject to personal jurisdiction in the district, where it allegedly conducts substantial business and has committed the accused acts of infringement.
• Core Dispute: Plaintiff alleges that Defendant’s portable collapsible carts infringe two U.S. patents related to the mechanical structure and locking mechanisms of such carts.
• Technical Context: The technology concerns wheeled, collapsible utility carts, a mature product category where innovation often centers on improving strength, stability, and ease of use in a foldable design.
• Key Procedural History: The complaint notes that Plaintiff has a policy of marking its products with the numbers of the patents-in-suit, a practice relevant to the calculation of potential damages. The patents-in-suit claim priority to a chain of applications originating with a provisional application filed in early 2020.

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 Issued
2025-05-20	U.S. Patent No. 12,304,546 Issued
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

The Invention Explained

• Problem Addressed: The patent identifies a deficiency in prior art collapsible carts, noting that their collapsible nature can result in sidewalls that "may not be sufficiently sturdy to allow for transporting heavy objects" (’446 Patent, col. 1:13-16).
• The Patented Solution: To enhance rigidity, the invention discloses a cart with sidewalls constructed from multiple hinged panels. A "first right panel" is rotatably coupled to a "second right panel," and the two are locked together in an open, planar configuration by a "first slideable member" that engages a "first track" extending across both panels (’446 Patent, Abstract; col. 5:10-30). This locking mechanism, illustrated in figures such as FIG. 2, is designed to transform the hinged sidewall into a solid, load-bearing structure when the cart is in use.
• Technical Importance: The described solution aims to combine the portability of a collapsible cart with the structural integrity required for carrying high loads, addressing a key trade-off in the design of such products (’446 Patent, col. 1:19-21).

Key Claims at a Glance

• The complaint alleges infringement of at least one claim, referencing a claim chart in an exhibit not provided with the complaint (Compl. ¶15). Independent Claim 1 is central to the patent.
• Essential elements of Independent Claim 1 include:
  • A collapsible cart configured to transition between a closed and 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" is formed along the first and second right panels.
  • A "first slideable member" is cooperatively engaged with the track and is movable between an open position (allowing the panels to fold) and a closed position to "selectively lock the first right panel to the second right panel."
• The complaint does not specify whether dependent claims are asserted.

U.S. Patent No. 12,304,546, Collapsible Carts, issued May 20, 2025

The Invention Explained

• Problem Addressed: Similar to its companion patent, the ’546 Patent addresses the general need for "improvements to collapsible carts" and notes that prior art designs have not "effectively addressed" the problem of sturdiness for heavy objects (’546 Patent, col. 1:25-28).
• The Patented Solution: This patent describes a cart architecture defined by the interaction of its walls during folding. The invention claims a cart with at least five walls, where at least three are configured to fold inwardly (’546 Patent, col. 14:7-10). A key feature is a "fastener" used to secure a multi-panel wall. This fastener consists of a "first fastener member integrally disposed" on one panel and a second member on the other, which mate to hold the panels in a "substantially coplanar alignment" (’546 Patent, col. 14:14-29).
• Technical Importance: The invention focuses on the specific geometry and fastening of the cart's panels to achieve a stable, locked configuration for use and a compact, predictable folded state for storage.

Key Claims at a Glance

• The complaint alleges infringement of at least one claim, referencing a claim chart in an exhibit not provided with the complaint (Compl. ¶20). Independent Claim 9 is a representative claim.
• Essential elements of Independent Claim 9 include:
  • A collapsible cart with a frame of at least five walls, where at least three fold inwardly toward a fifth wall.
  • A "third wall" that comprises a first panel and a second panel rotatably coupled together.
  • A "fastener" configured to selectively secure the first and second panels in a "substantially coplanar alignment."
  • The fastener comprises a "first fastener member integrally disposed on an edge of the first panel" and a second fastener member on the second panel, which are configured to mate.
• The complaint does not specify whether dependent claims are asserted.

III. The Accused Instrumentality

Product Identification

The complaint identifies the "Accused Products" as numerous portable carts sold by the Defendant on Amazon.com (Compl. ¶¶11, 13). A specific list of products by their Amazon Standard Identification Number (ASIN) is referenced in Exhibit C, which was not provided with the complaint (Compl. ¶13).

Functionality and Market Context

The complaint describes the Accused Products as infringing portable carts offered for sale and sold to consumers in the United States via online retail platforms (Compl. ¶¶11, 15, 20). It does not provide any specific technical details regarding the operation, materials, or construction of the Accused Products. The complaint suggests a competitive market by describing Plaintiff's own line of carts as "highly successful" and "frequently featured on QVC" (Compl. ¶7).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

The complaint alleges direct infringement of the ’446 and ’546 patents but relies entirely on claim chart exhibits that were not included with the public filing (Compl. ¶¶15, 20). The complaint itself offers no narrative infringement theory or specific facts mapping elements of the Accused Products to the limitations of the asserted patent claims. Therefore, the complaint does not provide sufficient detail for a full analysis of the infringement allegations.

Identified Points of Contention

Based on the language of the asserted patents, the infringement analysis, once developed, may center on the following questions:

• Technical Questions: Does the locking mechanism on the Defendant's carts function in the manner required by the claims? For the ’446 Patent, this raises the question of whether an accused feature moves "along the first track" to "selectively lock" the hinged panels (’446 Patent, col. 7:28-38). For the ’546 Patent, a key question is whether the accused fastener holds the panels in a "substantially coplanar alignment" and is "integrally disposed" on the panels as claimed (’546 Patent, col. 14:14-22).
• Scope Questions: The dispute may turn on the scope of the patent claims. For instance, do the terms "track" and "slideable member" in the ’446 Patent read on the specific components used in the Defendant's products? Similarly, does the "fastener" of the ’546 Patent encompass the mechanism used in the accused carts, or is there a material difference in structure or operation?

V. Key Claim Terms for Construction

’446 Patent

• The Term: "first slideable member cooperatively engaged to the first track" (Claim 1)
• Context and Importance: This term defines the core locking mechanism. The infringement analysis will hinge on whether the component used in the Accused Product meets the structural ("track," "slideable member") and functional ("cooperatively engaged," "movable along") requirements of this limitation. Practitioners may focus on this term because it is the central point of novelty for securing the multi-panel wall.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language requires the member be "movable along the first track," which a plaintiff could argue is a broad functional description covering any component that slides along a guide to lock the panels (’446 Patent, col. 7:29-30).
  • Evidence for a Narrower Interpretation: The specification's primary embodiment shows a specific C-shaped sliding clip (58) engaging a raised track (46) (’446 Patent, FIG. 2; col. 5:18-24). A defendant may argue that the term should be limited to a structure that substantially resembles this disclosed embodiment.

’546 Patent

• The Term: "first fastener member integrally disposed on an edge of the first panel" (Claim 9)
• Context and Importance: The construction of "integrally disposed" is critical. If construed narrowly to mean "molded as a single, unitary piece," it could provide a straightforward path to a non-infringement argument if the accused product's fastener is a separately attached component.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not provide an explicit definition for "integrally disposed." Plaintiff may argue the term should be given its plain and ordinary meaning, which could include being permanently and securely fixed to the panel, not just co-molded.
  • Evidence for a Narrower Interpretation: The related ’446 patent, which is incorporated by reference, repeatedly describes the panels as being "formed of molded rigid plastic" (’446 Patent, col. 4:57-58). A defendant could leverage this context to argue that "integrally disposed" in the ’546 Patent implies being formed as part of the same molding process, rather than being a distinct component attached later.

VI. Other Allegations

• Indirect Infringement: The complaint exclusively pleads "direct infringement" and does not include separate counts or factual allegations to support claims for either induced or contributory infringement (Compl. ¶¶1, 15, 20).
• Willful Infringement: The complaint does not contain an allegation of willful infringement. While it states that Plaintiff marks its products with the patent numbers, providing constructive notice to the public, it does not allege that Defendant had pre-suit knowledge of the patents or acted with objective recklessness (Compl. ¶10).

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

• A primary issue will be one of evidentiary demonstration: Given the complaint's complete reliance on unprovided exhibits for its infringement theory, a key question is what evidence Plaintiff will produce to show that the Accused Products meet each limitation of the asserted claims, especially the specific structural and functional details of the patented locking mechanisms.
• The case will also turn on a question of claim scope: The dispute will likely focus on the construction of key claim terms. A central battleground will be whether the "slideable member cooperatively engaged to the first track" (’446 Patent) and the "fastener member integrally disposed" (’546 Patent) are broad enough in scope to read on the specific design and components of the Defendant's carts, or if they are limited to the particular embodiments disclosed in the patent specifications.