DCT
5:25-cv-02001
Kids2 LLC v. Baby Trend Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Kids2, LLC (Georgia)
- Defendant: Baby Trend, Inc. (California)
- Plaintiff’s Counsel: Foley & Lardner LLP
- Case Identification: 5:25-cv-02001, C.D. Cal., 08/01/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendant is incorporated in California, maintains its principal place of business in Fontana, California (within the District), and has committed the alleged acts of infringement in the District.
- Core Dispute: Plaintiff alleges that Defendant’s line of convertible high chair products infringes six patents related to high chairs that can be converted into standalone booster seats.
- Technical Context: The technology concerns children's high chairs that feature a removable upper seat which can function independently as a booster seat on a standard chair, designed to eliminate the need for a separate base component for the booster.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with pre-suit notice of infringement via correspondence. Plaintiff also alleges its own products are marked with the asserted patents pursuant to 35 U.S.C. § 287(a) via a public website.
Case Timeline
| Date | Event |
|---|---|
| 2011-09-13 | Priority Date for all six Asserted Patents |
| 2014-01-01 | Plaintiff's "Trio" product line, allegedly practicing the patents, first sold (at least by this date) |
| 2015-08-11 | U.S. Patent No. 9,101,225 Issued |
| 2018-02-06 | U.S. Patent No. 9,883,749 Issued |
| 2019-05-07 | U.S. Patent No. 10,278,513 Issued |
| 2020-11-17 | U.S. Patent No. 10,835,053 Issued |
| 2022-12-27 | U.S. Patent No. 11,534,006 Issued |
| 2023-05-23 | U.S. Patent No. 11,653,771 Issued |
| 2025-08-01 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,101,225 - "Convertible High Chair," issued August 11, 2015
The Invention Explained
- Problem Addressed: The patent describes a limitation in conventional convertible high chairs where the removable booster seat, when detached, "must be coupled to a separate base member" to be used on a standard chair (’225 Patent, col. 2:35-37). This adds complexity and cost.
- The Patented Solution: The invention is a high chair with two primary components: a main frame with a first seat, and a removable second seat. The key innovation is that the second seat is designed with an integrated, stable base surface, allowing it to be detached and placed "directly on a flat support surface" (like a dining chair) and function as a standalone booster seat without requiring an additional base part ('225 Patent, col. 6:1-8). The patent's Figure 7 illustrates this intended use, showing the detached second seat (20) resting on a standard chair (60) ('225 Patent, Fig. 7).
- Technical Importance: This design simplifies use, enhances convenience for caregivers, and reduces the number of components, which may lower manufacturing costs ('225 Patent, col. 5:56-65).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶41).
- Claim 1 requires:
- a frame configured for resting on a floor;
- a first child seat coupled to the frame;
- a second child seat removably coupled to the first child seat; and
- a base surface on the second child seat that is configured for two functions: engaging the first seat when coupled, and resting directly and stably on a flat surface when decoupled.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 9,883,749 - "Convertible High Chair," issued February 6, 2018
The Invention Explained
- Problem Addressed: As with the '225 Patent, the shared specification addresses the need for a more convenient convertible high chair whose booster seat does not require a separate base for standalone use (’749 Patent, col. 2:38-43).
- The Patented Solution: The '749 Patent claims a similar convertible high chair but focuses on the structural definition of the removable second seat. It is explicitly claimed as comprising "a base portion and a seatback portion," where the "same base portion" performs the dual function of engaging the main high chair and also resting directly on a flat surface when used as a booster ('749 Patent, col. 6:50-65).
- Technical Importance: This claim language emphasizes the integral, dual-purpose nature of the booster seat's base, distinguishing it from multi-part prior art systems.
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶54).
- Claim 1 requires:
- a first seat assembly including a frame and a first child seat;
- a second child seat comprising a base portion and a seatback portion;
- wherein the same base portion both engages the first seat assembly in the high chair configuration and also rests directly on a flat support surface in the booster configuration.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 10,278,513 - "Convertible High Chair," issued May 7, 2019
- Patent Identification: U.S. Patent No. 10,278,513, "Convertible High Chair," issued May 7, 2019 (Compl. ¶19).
- Technology Synopsis: This patent, part of the same family, claims a convertible high chair with a specific frame structure, comprising downwardly extending front and back leg members. The claims again focus on the second child seat being detachably coupled and having a base portion that can rest directly on a flat surface for use as a booster (Compl. ¶20).
- Asserted Claims: At least Claim 1 (Compl. ¶67).
- Accused Features: The complaint alleges the accused products' frame, leg members, and two-seat convertible structure infringe (Compl. ¶¶70-72).
U.S. Patent No. 10,835,053 - "Convertible High Chair," issued November 17, 2020
- Patent Identification: U.S. Patent No. 10,835,053, "Convertible High Chair," issued November 17, 2020 (Compl. ¶21).
- Technology Synopsis: This patent claims a convertible high chair where the base surface of the second child seat is specifically "dimensioned to nest within the first child seat." This "nesting" feature is a key limitation, in addition to the base's ability to provide a stable platform on a separate surface (Compl. ¶22).
- Asserted Claims: At least Claim 1 (Compl. ¶80).
- Accused Features: The complaint alleges infringement by the accused products' frame and the dimensional relationship between the first and second seats, which allegedly "nest" (Compl. ¶¶83-85).
U.S. Patent No. 11,534,006 - "Convertible Children's Highchair," issued December 27, 2022
- Patent Identification: U.S. Patent No. 11,534,006, "Convertible Children's Highchair," issued December 27, 2022 (Compl. ¶23).
- Technology Synopsis: This patent claims a convertible high chair where the second child seat comprises distinct "upper" and "lower" portions. The lower portion has a lower surface configured for resting on a flat support surface, and both portions are configured for detachable coupling to the first child seat (Compl. ¶24).
- Asserted Claims: At least Claim 1 (Compl. ¶93).
- Accused Features: The complaint accuses the frame and the two-part construction of the second child seat in the accused products (Compl. ¶¶96-98).
U.S. Patent No. 11,653,771 - "Booster Seat for Convertible High Chair," issued May 23, 2023
- Patent Identification: U.S. Patent No. 11,653,771, "Booster Seat for Convertible High Chair," issued May 23, 2023 (Compl. ¶25).
- Technology Synopsis: Unlike the other patents that claim the entire high chair system, this patent claims the child seat itself. The claims recite features enabling its dual use: fitting securely on a high chair assembly, resting on a flat surface, having a strap for securing it to a chair, and a compartment for storing the strap when not in use (Compl. ¶26).
- Asserted Claims: At least Claim 10 (Compl. ¶108).
- Accused Features: The complaint accuses the MUV and Snap Gear products' removable child seats, alleging they include a base portion that fits on a high chair, can rest on a flat surface, and include a strap and storage compartment (Compl. ¶¶109-112).
III. The Accused Instrumentality
Product Identification
- The complaint identifies the Baby Trend "MUV 7 in 1 High Chair," "Everlast 7 in 1 High Chair," and "Snap Gear 5 in 1 High Chair" as the Accused Products (Compl. ¶¶34, 36, 37, 41).
Functionality and Market Context
- The complaint alleges these products are convertible high chairs sold by Defendant through its own website and major online retailers like Amazon (Compl. ¶¶34-38). The infringement allegations are supported by photographs of the Accused Products, which depict a multi-mode functionality. For example, a photograph of the "Everlast 7 in 1 High Chair" shows it configured as a full high chair (Compl. ¶44). Another photograph shows the upper seat portion detached and resting on a dining room chair, functioning as a booster seat (Compl. ¶46). The complaint alleges this functionality mirrors the system claimed in the Asserted Patents.
IV. Analysis of Infringement Allegations
'225 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A convertible children's high chair comprising: a frame configured for resting on a floor; | The complaint alleges the Everlast 7 in 1 High Chair has a frame that rests on the floor, as shown in an evidentiary photograph. This photograph depicts the accused high chair's A-frame leg structure standing on a floor (Compl. p. 16). | ¶44 | col. 2:48-49 |
| a first child seat defining a first seating surface, the first child seat being coupled to the frame and supported above the floor; | The Everlast 7 in 1 High Chair is alleged to have a first child seat coupled to and supported by the frame. An evidentiary photograph shows this seat component as part of the main high chair structure (Compl. p. 17). | ¶45 | col. 2:49-51 |
| and a second child seat defining a second seating surface, the second child seat configured for being removably coupled to the first child seat; | The complaint alleges the product includes a second, removable child seat. A photograph shows this second seat detached from the main high chair and placed on a dining chair, demonstrating its removability (Compl. p. 18). | ¶46 | col. 2:52-54 |
| wherein the second child seat defines a base surface configured for engaging the first seating surface of the first child seat when the second child seat is coupled to the first child seat and for resting directly on a flat support surface...when the second child seat is decoupled... | The complaint alleges the second seat's base surface performs this dual function. When decoupled, it rests on a flat surface (a dining chair) to support the seat in a stable, upright position, as shown in the photograph at paragraph 46 (Compl. p. 18). | ¶46 | col. 6:1-8 |
'749 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A convertible children's high chair comprising: a first seat assembly comprising a frame configured for resting on a floor, and a first child seat attached to the frame and supported above the floor by the frame; | The Everlast 7 in 1 High Chair is alleged to be a first seat assembly with a frame and attached first child seat. Evidentiary photographs show the full high chair assembly with its frame resting on the floor and supporting the first seat (Compl. p. 19-20). | ¶¶57-58 | col. 2:48-52 |
| and a second child seat comprising a base portion and a seatback portion, wherein the same base portion both engages the first seat assembly when the second child seat is coupled...in a high chair configuration, and also rests directly on a flat support surface...to independently support the second child seat...when the second child seat is decoupled...in a booster seat configuration. | The complaint alleges the second seat has a single base portion that performs both functions. A photograph shows the second seat in the booster configuration, resting on a dining chair, which the complaint alleges demonstrates its ability to rest directly on a flat surface to independently support the seat (Compl. p. 21). | ¶59 | col. 6:50-65 |
Identified Points of Contention
- Scope Questions: A central question may be the scope of the term "resting directly on a flat support surface." The defense may argue that the accused booster is not sufficiently stable without the use of straps, or that the interface between the booster and a chair does not constitute "direct" rest as envisioned by the patent. Another question relates to the ’053 patent's term "dimensioned to nest," which may require a more specific fit than merely sitting on top of the first seat.
- Technical Questions: For the ’771 patent, a key technical question will be whether the accused product's base includes what can be legally defined as a "compartment for storing the at least one strap." The complaint provides a photograph purporting to show this feature (Compl. ¶112), but its primary design purpose and function will be a matter for factual determination.
V. Key Claim Terms for Construction
The Term: "resting directly on a flat support surface" (from '225 Patent, Claim 1)
- Context and Importance: This term is central to the patent's stated purpose of overcoming prior art that required a separate base for booster functionality. The infringement analysis for multiple asserted patents depends on whether the accused booster seat meets this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification contrasts the invention with prior art that "must be coupled to a separate base member" ('225 Patent, col. 2:35-37). A party could argue "resting directly" should be interpreted broadly to mean "without an intervening, separate structural base," which aligns with the stated goal of the invention.
- Evidence for a Narrower Interpretation: The specification also describes "non-slip pads" (32) on the base surface that "provide additional stability" ('225 Patent, col. 5:18-19). A party could argue that "stable upright position" sets a high standard that is not met without straps, or that the pads themselves mean the base does not rest "directly" on the support surface.
The Term: "the same base portion" (from '749 Patent, Claim 1)
- Context and Importance: Practitioners may focus on this term because it defines the dual-functionality requirement of the booster seat's base in a single, unitary component. The infringement case for the '749 patent hinges on whether the accused product's base acts as a single, indivisible element for both coupling to the main chair and resting on a flat surface.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification refers to the "bottom base surface 30" as a single element in the figures ('749 Patent, col. 4:55-56). A party could argue that as long as the base is a single molded part, it meets the "same base portion" limitation, even if different areas of that part perform different functions.
- Evidence for a Narrower Interpretation: A party could argue that if the section of the base that "engages" the first seat is functionally and structurally distinct from the section that "rests" on a chair, they are not "the same base portion" for the purposes of the claim, even if part of one piece of plastic. The specification describes a "recessed portion 31" within the base surface 30 ('749 Patent, col. 4:59-60), which could be used to argue that the "base portion" contains functionally distinct sub-regions.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, stating Defendant induces sales and assembly of the accused products in the U.S. (Compl. ¶42, 55). It further alleges Defendant sells to retailers like Amazon, which then sell to customers "who use it," suggesting inducement of end-user infringement (Compl. ¶35).
- Willful Infringement: The complaint alleges willful infringement based on Defendant's alleged "actual knowledge" of the Asserted Patents and the infringement, stemming at least from "pre-suit correspondence" from Plaintiff (Compl. ¶48, 61, 74, 87, 100, 114). The complaint also alleges willful blindness prior to receiving said correspondence.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim scope and construction: can terms like "resting directly", "stable upright position", and "dimensioned to nest" be construed to read on the specific design and performance of the accused products? The outcome will depend on whether the court adopts a broader, purpose-oriented definition focused on the elimination of a separate base, or a narrower, more literal definition based on specific embodiments and stability requirements.
- A key evidentiary question will be one of functional operation: does the accused product's removable seat, as a factual matter, operate in the manner required by the claims? For instance, with respect to the '771 patent, discovery will be needed to determine if a feature on the accused seat is, in fact, a "compartment" specifically configured for "storing" the safety strap, or if that is an incidental characteristic of the design.