DCT
2:25-cv-11079
Wonderfold Corp v. Dongguan Jibaobao Internet Technology Co Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Wonderfold Corporation (California)
- Defendant: Dongguan Jibaobao Internet Technology Co., Ltd. (China)
- Plaintiff’s Counsel: Law Offices of Niria M. Arvizu
- Case Identification: 2:25-cv-11079, C.D. Cal., 11/19/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendant has committed acts of infringement in the district, placed infringing products into the stream of commerce with the expectation of use there, and conducted substantial sales and shipments into the district.
- Core Dispute: Plaintiff alleges that Defendant’s Cochildor stroller infringes one utility patent and one design patent related to foldable stroller wagons.
- Technical Context: The technology relates to the mechanical structures for foldable stroller wagons, a consumer product category focused on combining the portability of a stroller with the capacity of a wagon.
- Key Procedural History: The complaint notes that the asserted utility patent, U.S. Patent No. 10,464,588, was subject to an Ex Parte Reexamination, and the complaint asserts infringement of an amended claim resulting from that proceeding. The arguments and claim amendments made during reexamination may be significant for determining the scope of the asserted claim.
Case Timeline
| Date | Event |
|---|---|
| 2019-01-02 | ’588 Patent Priority Date |
| 2019-04-25 | ’301 Patent Priority Date |
| 2019-11-05 | ’588 Patent Issue Date |
| 2022-06-21 | ’301 Patent Issue Date |
| 2024-01-01 | Earliest Alleged Date of Defendant's Marketing |
| 2025-10-22 | ’588 Patent Ex Parte Reexamination Certificate Issue Date |
| 2025-11-19 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,464,588 - "Foldable Baby Stroller"
The Invention Explained
- Problem Addressed: The patent’s background section describes prior art baby strollers as often being large, difficult to fold conveniently, and potentially lacking in structural stability and safety ('588 Patent, col. 1:10-18).
- The Patented Solution: The invention discloses a specific folding frame for a stroller designed to improve stability and foldability. The solution centers on a folding assembly with two "lateral folding holders," each of which includes a system of interconnected upper and lower "fence tubes" that connect the front and rear wheel assemblies to a "middle holder." This middle holder contains upper and lower folding joints that enable the structure to collapse into a compact state, as illustrated in the transition from the unfolded view in Figure 3 to the folded view in Figure 1 ('588 Patent, col. 1:51-67; Figs. 1, 3).
- Technical Importance: The claimed mechanical arrangement purports to provide a foldable stroller with high structural stability when unfolded, enhancing its safety and durability ('588 Patent, col. 1:40-44).
Key Claims at a Glance
- The complaint asserts amended independent Claim 1, which resulted from an Ex Parte Reexamination (Compl. ¶¶ 15, 64).
- Essential elements of amended Claim 1 include:
- A front wheel assembly with a front wheel holder.
- A rear wheel assembly with an inverted U-shaped rear wheel holder connected to a push rod.
- A folding assembly with two lateral folding holders, each comprising an upper-front fence tube, a lower-front fence tube, an upper-back fence tube, a lower-back fence tube, and a middle holder.
- The middle holder comprises an upper folding joint, a lower folding joint, and a support stand rod connecting them.
- A specific arrangement of pivotal connections between the front and rear ends of the fence tubes and the respective wheel holders and folding joints.
- A cross-sectional view of the upper folding joint is inverted U-shaped with an upper-end positioning slot.
- A cross-sectional view of the lower folding joint is U-shaped with a lower-end positioning slot.
- The complaint states that Plaintiff reserves the right to assert infringement of other claims (Compl. ¶63).
U.S. Patent No. D955,301 - "Stroller"
The Invention Explained
- Problem Addressed: Design patents do not solve technical problems but instead protect the novel, non-functional, ornamental appearance of an article of manufacture.
- The Patented Solution: The patent claims the specific ornamental design for a stroller, as depicted in its figures ('301 Patent, Figs. 1-8). The design's overall visual impression is characterized by its rectangular, wagon-like body with fabric and mesh panels, a particular U-shaped handle, and the specific proportions and arrangement of its frame, wheels, and body ('301 Patent, Fig. 1).
- Technical Importance: In the consumer goods market, a distinctive ornamental design can function as a source identifier and a significant driver of commercial success, differentiating a product from its competitors.
Key Claims at a Glance
- The patent contains a single claim for "the ornamental design for a stroller, as shown and described" ('301 Patent, "CLAIM").
III. The Accused Instrumentality
Product Identification
- The "Cochildor stroller" (Compl. ¶2).
Functionality and Market Context
- The complaint identifies the Cochildor stroller as a foldable stroller wagon that is a direct competitor to Plaintiff's products (Compl. ¶38). The infringement allegations for the '588 patent are supported by annotated photographs of the accused product in a folded state, which purport to show the various components of its folding frame, such as the wheel holders, fence tubes, and folding joints (Compl. ¶¶ 64(a)-(j)).
- Plaintiff alleges that Defendant markets the Cochildor stroller as an "EXACT dupe for the wonderfold" and sells it at a lower price point, suggesting a market strategy of targeting consumers looking for an alternative to Plaintiff's product (Compl. ¶¶ 39, 44). An advertisement for the accused product on Temu.com is presented as evidence of this marketing (Compl. p. 20).
IV. Analysis of Infringement Allegations
'588 Patent Infringement Allegations
| Claim Element (from Amended Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a front wheel assembly, comprising a front wheel holder, a front-left wheel and a front-right wheel disposed at the bottom of the front wheel holder | The Cochildor stroller includes a front wheel assembly with a front wheel holder and left and right wheels. | ¶64(a) | col. 1:52-54 |
| a rear wheel assembly, comprising a rear wheel holder, a rear-left wheel and a rear-right wheel disposed at the bottom of the rear wheel holder, wherein the rear wheel holder is inverted U-shaped, connected to a push rod... | The Cochildor stroller includes a rear wheel assembly with a rear wheel holder, left and right wheels, an inverted U-shaped holder, and a push rod. | ¶64(b) | col. 1:55-58 |
| a folding assembly, comprising two lateral folding holders... wherein each lateral folding holder comprises an upper-front fence tube, a lower-front fence tube, an upper-back fence tube, a lower-back fence tube and a middle holder | The Cochildor stroller includes a folding assembly with two lateral folding holders, each comprising the specified set of fence tubes and a middle holder. | ¶64(c) | col. 1:59-64 |
| the middle holder comprises an upper folding joint, a lower folding joint and a support stand rod disposed therebetween and connecting the upper folding joint to the lower folding joint | The Cochildor stroller’s middle holder is alleged to contain an upper folding joint, a lower folding joint, and a connecting support stand rod. | ¶64(e) | col. 1:65-67 |
| a cross-sectional view of the upper folding joint is inverted U-shaped and a bottom of the upper folding joint is provided with an upper-end positioning slot | The upper folding joint of the accused stroller is alleged to be inverted U-shaped and to include an upper positioning slot at its bottom. | ¶64(h) | col. 2:47-51 |
- Identified Points of Contention:
- Scope Questions: The complaint asserts infringement of an amended claim from a reexamination. A principal issue will be how the prosecution history of that proceeding affects the interpretation of key terms. The reasons for amendment or arguments made to the USPTO could narrow the scope of terms like "middle holder" or "positioning slot."
- Technical Questions: The infringement allegations rely on observations from product advertisements (Compl. ¶64). A key factual question will be whether the internal mechanics of the Cochildor stroller's folding joints, which are not visible externally, possess the specific "inverted U-shaped" cross-section and "upper-end positioning slot" required by limitation 1(h). The complaint's annotated image shows the alleged "front wheel assembly" and "front wheel holder" on the accused product, but does not depict internal mechanics (Compl. p. 28).
'301 Patent Infringement Allegations
- The complaint alleges infringement of the design patent by asserting that the overall ornamental appearance of the Cochildor stroller is "the same or substantially the same" as the claimed design, such that it would deceive an ordinary observer (Compl. ¶55). The complaint presents side-by-side images comparing "Figure 1 of '301 patent" with photographs of the accused "Cochildor Stroller" to visually support this allegation (Compl. p. 25).
- Identified Points of Contention:
- The legal test for design patent infringement is whether an ordinary observer, familiar with the prior art designs, would be deceived into purchasing the accused product believing it to be the patented one. The dispute may focus on whether the visual differences between the products are sufficient to avoid such deception, or conversely, whether the similarities in the overall aesthetic are what define the product in the observer's eye. Defendant may also raise the question of whether certain similarities are dictated by function and are therefore not protectable as part of the ornamental design.
V. Key Claim Terms for Construction
The Term: "middle holder" ('588 Patent, Claim 1)
Context and Importance: This term describes the central hub of the patented folding mechanism, which connects the fence tubes through the upper and lower folding joints. The definition of this term will be critical for determining whether the accused product's central folding structure is encompassed by the claim.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself defines the "middle holder" by its components: "an upper folding joint, a lower folding joint and a support stand rod" ('588 Patent, col. 6:1-3). Plaintiff may argue this term covers any structure containing these three elements that performs the claimed connecting function.
- Evidence for a Narrower Interpretation: The specification discloses a specific embodiment where the support stand rod is connected to a "joint fixation base" and "assistant support slope rods" ('588 Patent, col. 4:46-58; Fig. 2). A defendant may argue that the term "middle holder" should be construed more narrowly to include these additional structural features shown in the preferred embodiment.
The Term: "upper-end positioning slot" ('588 Patent, Claim 1)
Context and Importance: This term appears in limitation 1(h) and describes a specific feature within the upper folding joint. Infringement of this element may depend entirely on whether a corresponding "slot" exists in the accused product and performs the same function. Practitioners may focus on this term because its meaning may have been specifically defined or narrowed during the reexamination proceeding.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not appear to provide an explicit definition of "slot." Plaintiff may argue the term should be given its plain and ordinary meaning, covering any groove, recess, or aperture that serves to position the ends of the fence tubes within the joint.
- Evidence for a Narrower Interpretation: Without a textual definition, interpretation may be limited to the structure as depicted in the patent's figures and as potentially constrained by arguments made during reexamination to distinguish the invention from prior art.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant induces infringement by selling the Cochildor stroller to retail partners and end users with knowledge that their use of the product will infringe the '588 patent (Compl. ¶67).
- Willful Infringement: Willfulness is alleged based on Defendant’s purported actual knowledge of the '588 patent "based on at least the filing and service of this Complaint" (Compl. ¶66). For both patents, the complaint alleges Defendant's infringement was "willful and deliberate" (Compl. ¶72).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue for the '588 utility patent will be one of claim scope defined by prosecution history: how does the language of amended Claim 1, particularly terms like "middle holder" and "positioning slot" that were subject to a reexamination proceeding, apply to the specific mechanical assembly of the accused Cochildor stroller's folding mechanism?
- For the '301 design patent, the case will turn on the application of the ordinary observer test: are the overall visual similarities between the accused Cochildor stroller and the patented design, as highlighted in the complaint's side-by-side comparisons, substantial enough to deceive an ordinary purchaser, or are any differences sufficient to distinguish the products in the marketplace?
- A key evidentiary question will be one of factual correspondence: what will discovery reveal about the internal, non-visible structures of the accused product's folding joints, and do those structures meet the specific geometric and functional requirements of the asserted claims (e.g., an "inverted U-shaped" cross-section with a "positioning slot")?