DCT
2:25-cv-11032
Dbest Products Inc v. Katziela Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: dbest products, Inc. (California)
- Defendant: Katziela Inc. (New York)
- Plaintiff’s Counsel: Orbit IP, LLP
- Case Identification: 2:25-cv-11032, C.D. Cal., 11/17/2025
- Venue Allegations: Plaintiff alleges venue is proper based on a mandatory forum-selection clause in a prior agreement between the parties and because Defendant allegedly committed acts of patent infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s portable pet carriers infringe a patent related to a rolling carrier system designed to keep a pet level during transport, and further alleges that this infringement violates a prior settlement agreement between the parties.
- Technical Context: The technology concerns wheeled pet carriers, a segment of the pet accessories market where design innovations focus on animal comfort, portability, and compliance with travel regulations.
- Key Procedural History: The complaint states that the parties entered into a Settlement and License Agreement on June 29, 2022. Plaintiff alleges that Defendant subsequently breached this agreement by selling new, allegedly infringing products without paying royalties, which forms the basis for the current claims of infringement and willfulness.
Case Timeline
| Date | Event |
|---|---|
| 2013-10-20 | ’766 Patent Priority Date |
| 2016-07-19 | ’766 Patent Issue Date |
| 2022-06-29 | Settlement and License Agreement executed |
| 2025-11-17 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,392,766 - "PORTABLE PET CARRIER TO TRANSPORT A PET FROM ONE LOCATION TO ANOTHER AND RETAIN THE PET IN THE CARRIER WHILE TRAVELING"
The Invention Explained
- Problem Addressed: The patent's background section describes prior art rolling pet carriers as having rigid carrying handles that require the carrier to be "rolled at an angle," which may lead to the pet's discomfort ('766 Patent, col. 1:44-48). Additionally, many existing carriers are described as too rigid or large for convenient storage or for fitting under an airplane seat (ʼ766 Patent, col. 1:36-43).
- The Patented Solution: The invention is a pet transportation system comprising a soft-sided pet carrier that is removably attached to a wheeled platform, or "flat base" ('766 Patent, Abstract). The platform features a telescoping handle connected via a "rotation mechanism" that allows the handle to be angled (e.g., to 45 degrees) relative to the base ('766 Patent, col. 2:3-10). This design permits a user to pull the carrier while it remains in a "horizontal orientation," which is intended to facilitate the pet's comfort during transport ('766 Patent, col. 2:55-59). The entire assembly is also designed to be folded flat for storage ('766 Patent, col. 2:15-18).
- Technical Importance: The described solution combines the benefits of a rolling cart with a design consideration for animal welfare, specifically by maintaining a level orientation for the pet during movement.
Key Claims at a Glance
The complaint alleges infringement of "at least one claim" of the ’766 Patent (Compl. ¶32). Independent Claim 1 is representative and includes the following essential elements:
- A flat base platform with four wheels, including two rear wheels rotating in a straight direction and two front rotating wheels.
- A handle attached to telescoping sections, connected to the base by a rotation mechanism that enables the handle to be rotated to a 45-degree angle relative to the base.
- The handle and base configuration allows a removably attached pet carrier to be "retained in a horizontal orientation" while the platform is rolled.
- The handle is also foldable and can be retained under the base for storage.
- A pet carrier containing a strap with hook/loop fasteners to wrap around the base, as well as a pair of hook/loop fasteners on its bottom surface to mate with fasteners on the platform's top surface.
- The carrier is foldable to be flat against the base platform for storage.
III. The Accused Instrumentality
Product Identification
The accused products are portable pet carriers offered for sale, sold, and/or distributed by Defendant in the U.S. on Amazon.com, identified by a list of Amazon Standard Identification Numbers (ASINs) (Compl. ¶33).
Functionality and Market Context
The complaint does not provide a technical description of the accused products' functionality. It alleges that Defendant sells products on Amazon.com to consumers in the United States and that Plaintiff identified "numerous products that infringe at least one claim of the '766 Patent" (Compl. ¶¶13-14). While the complaint references a claim chart in an exhibit that was not provided with the filing, it alleges this chart demonstrates how the accused products satisfy each limitation of at least one claim (Compl. ¶34).
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint alleges that a representative claim chart demonstrates infringement but does not include the chart (Compl. ¶34). The following table summarizes the likely infringement theory for the representative Claim 1 of the ’766 Patent based on the patent's description of the invention.
’766 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a. a flat base platform which has four wheels including two spaced apart rear wheels which are heavy duty luggage wheels that rotate in a straight direction and two spaced apart front wheels which are rotating wheels... | The accused carriers allegedly include a wheeled platform with a combination of fixed-direction rear wheels and rotating front wheels. | ¶¶32, 34 | col. 7:8-12 |
| b. a handle attached to telescoping sections with one telescoping section connected to the flat base platform by a rotation mechanism to enable the telescoping handle to be rotated to a 45 degree angle... | The accused carriers are alleged to have a telescoping handle that can be pivoted to an angle relative to the base. | ¶¶32, 34 | col. 7:13-18 |
| ...so that a pet transport carrier is removably attached to the flat base platform and retained in a horizontal orientation relative to the ground while the flat base platform is rolled... | The accused carriers, when pulled by the angled handle, allegedly maintain a level position for pet comfort. | ¶¶32, 34 | col. 7:18-22 |
| c. the pet transport carrier contains a strap having a pair of hook and/or loop strips... [and] a pair of spaced apart hook or loop fasteners on its bottom surface... | The accused carriers allegedly employ a dual-fastening system, including a strap that wraps around the platform and hook-and-loop pads on the carrier's underside. | ¶¶32, 34 | col. 7:26-39 |
| d. the pet transport carrier is foldable to be flat against the flat base platform... so that the entire assembly is very flat and folds to less than four inches in width... | The accused carrier system is alleged to be collapsible for compact storage. | ¶¶32, 34 | col. 7:40-47 |
Identified Points of Contention
- Scope Questions: A potential point of contention is the scope of the term "rotation mechanism." The dispute may center on whether the accused products' handle-pivoting feature is structurally and functionally the same as, or equivalent to, the mechanism required by the claims and disclosed in the patent specification.
- Technical Questions: A factual question may arise as to whether the accused products, in operation, actually keep the carrier "retained in a horizontal orientation" as claimed. Evidence of how the accused products perform when pulled by a user could be central to determining infringement of this functional limitation.
V. Key Claim Terms for Construction
The Term: "rotation mechanism"
- Context and Importance: This term is central to the patent's asserted point of novelty—the angled handle that allows for horizontal transport. The definition of this term will determine whether various types of hinges, joints, or pivots found on the accused products fall within the scope of the claims.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language describes the mechanism functionally, as one that "enable[s] the telescoping handle to be rotated to a 45 degree angle" (ʼ766 Patent, col. 7:15-16). A party could argue this language covers any structure that achieves the specified rotational function.
- Evidence for a Narrower Interpretation: The specification discloses a specific "rotatable mechanism 64" ('766 Patent, col. 5:13-15, Fig. 3). A party may argue that the claims should be limited to this disclosed embodiment and its structural equivalents, rather than covering any component that allows for rotation.
The Term: "retained in a horizontal orientation"
- Context and Importance: This functional language captures the primary benefit of the invention—pet comfort. Whether the accused products infringe may depend on how much deviation from perfectly horizontal is permitted while still meeting this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent contrasts the invention with prior art that rolls "at an angle," suggesting that "horizontal" should be interpreted as being substantially level and not tilted in the manner of the prior art, without requiring perfect geometric horizontality.
- Evidence for a Narrower Interpretation: The patent repeatedly links the horizontal orientation to "the pet's comfort" ('766 Patent, col. 2:57-59). A party could argue that the term requires an orientation that is demonstrably level enough to achieve this stated objective, potentially narrowing its scope based on functional considerations.
VI. Other Allegations
- Willful Infringement: The complaint alleges that Defendant's infringement was willful and intentional (Compl. ¶37). This allegation is based on the existence of the June 29, 2022 Settlement and License Agreement, which suggests Defendant had pre-suit knowledge of the ’766 Patent. The complaint further alleges that Defendant refused to report or pay royalties on new ASIN listings after being confronted, which may be presented as evidence of post-agreement, intentional infringement (Compl. ¶¶29, 37).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope and equivalence: does the handle connection on the accused carriers constitute a "rotation mechanism" as construed from the claims and specification of the ’766 Patent? The outcome may depend on whether the accused design is a structurally equivalent implementation or a distinct, non-infringing alternative.
- A central theme will likely be the impact of the prior settlement agreement. The existence of the agreement establishes Defendant's knowledge of the patent, creating a significant hurdle for Defendant to overcome the willfulness allegation. The narrative of a breached agreement could influence the court's view of the entire dispute.
- A key evidentiary question will be one of functional performance: does the accused carrier system actually maintain a "horizontal orientation" during typical use? This functional limitation is a cornerstone of the patent’s asserted value, and the infringement analysis will likely require factual evidence comparing the real-world operation of the accused products to the claim requirements.