DCT
2:25-cv-04626
Dbest Products Inc v. Guangzhou Taijing Technology Co Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Dbest Products, Inc. (California)
- Defendant: Guangzhou Taijing Technology Co, Ltd. (China)
- Plaintiff’s Counsel: Orbit IP, LLP
- Case Identification: 2:25-cv-04626, C.D. Cal., 05/21/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is subject to personal jurisdiction in the district as a result of conducting substantial business there, including committing the alleged acts of patent infringement.
- Core Dispute: Plaintiff alleges that Defendant’s portable collapsible carts infringe patents related to mechanical structures for reinforcing and locking the walls of such carts.
- Technical Context: The technology concerns collapsible utility carts, a consumer product category where portability, storage size, and load-bearing capacity are key competitive features.
- Key Procedural History: The complaint alleges that Plaintiff has complied with its policy of marking its products with the numbers of the patents-in-suit, which may be relevant to the start date for potential damages.
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, issued April 15, 2025
The Invention Explained
- Problem Addressed: The patent identifies a shortcoming in prior art collapsible carts, stating that "the sidewalls may not be sufficiently sturdy to allow for transporting heavy objects" due to their collapsible nature ('446 Patent, col. 1:13-17).
- The Patented Solution: To solve this, the invention discloses a sidewall constructed from two separate panels that are rotatably coupled to each other ('446 Patent, col. 4:48-55). A key feature is a "first slideable member" that engages with a "first track" extending across both panels. This slidable member can be moved from an open position (allowing the panels to fold) to a closed position where it locks the two panels together, creating a rigid, planar sidewall ('446 Patent, Abstract; col. 5:16-29). This mechanism is illustrated in figures such as FIG. 2, which shows the slidable member (58) securing two panels (26, 28).
- Technical Importance: This design provides a specific mechanical solution to enhance the structural integrity and load-bearing capacity of a collapsible cart, allowing it to remain compact for storage but more robust when in use ('446 Patent, col. 1:20-23).
Key Claims at a Glance
- The complaint asserts at least one claim of the ’446 patent (Compl. ¶15). Independent claim 1 is representative.
- Independent Claim 1 requires:
- A collapsible cart configured to transition between a closed and open condition.
- A rigid frame forming a compartment with walls, where the sidewalls are configured to fold inwardly.
- A right sidewall comprising 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" that is cooperatively engaged with the first track and is movable between an open and closed position to selectively lock the first right panel to the second.
- 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: Like the ’446 Patent, this patent addresses the problem that prior art collapsible cart designs may lack the sturdiness required for heavy objects ('546 Patent, col. 2:25-28).
- The Patented Solution: This invention describes a collapsible cart with walls made of multiple panels that are rotatably coupled. To provide rigidity, it claims a system of a "first latch part" on the edge of a first panel and a "second latch part" on the edge of an adjacent second panel ('546 Patent, col. 13:33-41). These latch parts are "configured to mate with one another" to hold the two panels together in a "common plane," thereby forming a solid wall from separate foldable components ('546 Patent, Claim 1). The abstract also describes other features, such as a pivotable telescoping handle, but the core structural claim relates to the panel-latching mechanism.
- Technical Importance: The invention provides a method for creating a strong, load-bearing structure from panels designed to fold, addressing a fundamental trade-off between portability and strength in collapsible containers ('546 Patent, col. 2:25-28).
Key Claims at a Glance
- The complaint asserts at least one claim of the ’546 patent (Compl. ¶20). Independent claim 1 is representative.
- Independent Claim 1 requires:
- A collapsible cart with a frame of at least five walls, with at least three configured to fold inwardly.
- One of the opposing walls consisting of a first panel and a second panel that is "rotatably coupled to the first panel."
- 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 with one another" to 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 the "Accused Products" as portable carts sold by the Defendant on Amazon.com to consumers in the United States (Compl. ¶¶ 11, 13). A specific list of products by Amazon Standard Identification Number (ASIN) is referenced as Exhibit C, which was not provided with the complaint (Compl. ¶13).
Functionality and Market Context
The complaint alleges the Accused Products are collapsible carts that are offered for sale, sold, and/or distributed by the Defendant (Compl. ¶¶ 15, 20). The complaint does not contain specific technical descriptions or visual evidence of the Accused Products' functionality. No probative visual evidence provided in complaint.
Commercial Importance
The complaint does not make specific allegations about the market position or commercial success of the Accused Products, other than to state that they are sold on the Amazon retail platform (Compl. ¶11).
IV. Analysis of Infringement Allegations
The complaint references but does not include claim chart exhibits (Exhibits D and E) that purportedly detail infringement (Compl. ¶¶ 15, 20). The following analysis is based on the allegations in the complaint and the language of the representative independent claims.
12,275,446 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 collapsible cart comprising: a rigid frame forming a compartment... | The complaint alleges the Accused Products are collapsible carts with a rigid frame forming a compartment, with specifics purportedly in Exhibit D. | ¶15 | col. 4:43-48 |
| the right sidewall comprising a first right panel rotatably coupled to a second right panel; | The complaint alleges the Accused Products have a sidewall made of at least two rotatably coupled panels, with specifics purportedly in Exhibit D. | ¶15 | col. 4:48-51 |
| a first track formed along the first right panel and the second right panel extending from a first position on the first right panel to a second position on the second right panel; and | The complaint alleges the Accused Products contain a track on the sidewall panels, with specifics purportedly in Exhibit D. | ¶15 | col. 5:8-15 |
| a first slideable member cooperatively engaged to the first track, the first slideable member is movable along the first track between an open position to a closed position to selectively lock the first right panel to the second right panel... | The complaint alleges the Accused Products have a slideable member that moves along the track to lock the panels, with specifics purportedly in Exhibit D. | ¶15 | col. 5:16-29 |
Identified Points of Contention
- Scope Questions: The central dispute will likely concern the scope of the terms "track" and "slideable member." A key question for the court will be whether the locking mechanism on the Defendant's products, whatever its specific form, meets the structural and functional requirements of these claim terms as defined in the patent.
- Technical Questions: Without visuals or technical descriptions of the Accused Products, it is an open question what evidence Plaintiff will present to show that the accused mechanism functions as a "slideable member" moving along a "track," rather than, for example, a simple snap-fit clip, a rotating latch, or another non-sliding fastener.
12,304,546 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... comprising: a frame defining a compartment, wherein: the frame comprises at least five walls, with at least three of the walls configured to rotatably fold inwardly... | The complaint alleges the Accused Products are collapsible carts with a frame of five or more walls, with specifics purportedly in Exhibit E. | ¶20 | col. 13:17-24 |
| 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 alleges the Accused Products have a sidewall made of at least two rotatably coupled panels, with specifics purportedly in Exhibit E. | ¶20 | col. 13:28-32 |
| 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... wherein the first latch part and the second latch part are configured to mate with one another... | The complaint alleges the Accused Products possess corresponding latch parts on adjacent panels that mate to secure the panels, with specifics purportedly in Exhibit E. | ¶20 | col. 13:33-41 |
Identified Points of Contention
- Scope Questions: The infringement analysis for this patent will likely hinge on the construction of "latch part" and what it means for two such parts to "mate." The parties may dispute whether this requires a specific type of mechanical interlock or can read on any two components that fasten together.
- Technical Questions: The court will need to examine the specific mechanism on the Accused Products to determine if it possesses distinct "latch parts" that "mate," as opposed to a unitary clip or a different fastening system. The relationship between the "latch part" of the ’546 patent and the "slideable member" of the ’446 patent may become a point of focus.
V. Key Claim Terms for Construction
From the ’446 Patent:
- The Term: "slideable member"
- Context and Importance: This term is central to the invention's novel locking mechanism. The definition will determine whether infringement requires a component that strictly slides along a defined path or if it could cover other movable fasteners. Practitioners may focus on this term because its scope will likely be the primary non-infringement argument.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language describes the member functionally as being "movable along the first track between an open position to a closed position" ('446 Patent, col. 7:27-29), which may support an interpretation covering any member that translates along the track to lock the panels.
- Evidence for a Narrower Interpretation: The specification consistently depicts the "first slideable member 58" as a specific, discrete component that physically encompasses portions of both panels when in the locked position, as shown in FIG. 2 and described as being "disposed across both the first right panel and second right panel" ('446 Patent, col. 2:42-44). A defendant may argue this limits the term to the specific sliding clasp embodiment shown.
From the ’546 Patent:
- The Term: "latch part"
- Context and Importance: This term defines the interlocking components of the claimed invention. Its construction is critical because it distinguishes the invention from the more specific "slideable member" of the ’446 patent and from prior art fasteners. Whether the Accused Products infringe may depend entirely on whether their fasteners are "latch parts."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent uses the term without providing an explicit definition, which may support giving the term its plain and ordinary meaning, potentially covering a wide range of interlocking fasteners. The claim only requires that they be "disposed on an edge" of each panel and "configured to mate" ('546 Patent, col. 13:33-41).
- Evidence for a Narrower Interpretation: While the patent does not provide a specific definition, all embodiments that could correspond to this feature, such as the slideable lock assembly shown in the related figures (e.g., '546 Patent, FIG. 42B), depict a specific type of slide-and-groove mechanism. A defendant could argue these embodiments limit the scope of "latch part" to something more specific than a generic clip or fastener.
VI. Other Allegations
The complaint does not provide sufficient detail for analysis of indirect or willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
A central issue will be one of claim differentiation and scope: How will the court construe the locking mechanism of the ’446 Patent ("slideable member" on a "track") relative to the seemingly broader "latch part" that "mates" from the ’546 Patent? The outcome will define the infringement landscape for both patents and address whether the claims cover distinct inventions or merely different levels of specificity for the same concept.
A key evidentiary question will be one of structural and functional correspondence: Since the complaint lacks technical details about the Accused Products, the case will depend on evidence (e.g., from discovery and expert analysis) demonstrating whether the specific locking mechanisms on Defendant's carts operate in a way that falls within the court's construction of the asserted claims. The dispute will likely move from claim construction to a direct comparison of the accused device's components against the claim language.