DCT

3:25-cv-05344

iBeauty Ltd Co v. Dbest Products Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 5:25-cv-05344, N.D. Cal., 06/26/2025
  • Venue Allegations: Venue is asserted on the basis that a substantial part of the events giving rise to the claims, including Plaintiffs’ lost sales and reputational harm, occurred in the district where Plaintiffs market and sell products.
  • Core Dispute: Plaintiffs, a group of online sellers, seek a declaratory judgment that their storage bin products do not infringe two of Defendant’s patents related to collapsible carts, following Defendant’s infringement complaints to Amazon that resulted in the removal of Plaintiffs’ product listings.
  • Technical Context: The technology concerns collapsible, wheeled containers designed for storage and transport, with a focus on mechanical features that provide structural rigidity when the container is in its open, usable state.
  • Key Procedural History: The complaint alleges this action was precipitated by Defendant's patent infringement complaints submitted to Amazon, which caused the removal of Plaintiffs' product listings. The complaint also notes a prior, separate declaratory judgment action against Defendant concerning a different patent, which Defendant allegedly resolved by issuing a covenant not to sue, thereby avoiding judicial review.

Case Timeline

Date Event
2019 Alleged public availability of prior art product (ASIN B07YFFPK7B)
2020-01-06 Earliest Priority Date for '446 and '546 Patents
2024-12-05 Defendant allegedly submitted infringement complaint against a third-party seller
2025-01-23 Defendant allegedly issued covenant not to sue in prior third-party litigation
2025-04-15 U.S. Patent No. 12,275,446 Issues
2025-05-20 U.S. Patent No. 12,304,546 Issues
2025-06-25 Plaintiffs received notification from Amazon of product listing removals
2025-06-26 Complaint for Declaratory Judgment 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 render their sidewalls insufficiently sturdy for transporting heavy objects (’446 Patent, col. 2:13-16).
  • The Patented Solution: The invention is a collapsible cart with a rigid frame and sidewalls composed of multiple panels that fold inwardly. To solve the sturdiness problem, it introduces a locking mechanism consisting of a track extending across the panels of a sidewall and a "slideable member" that moves along this track to lock the panels together, providing rigidity in the open state (’446 Patent, col. 2:27-43). This mechanism is illustrated in figures such as FIG. 2, which shows the track (46) and slideable member (58) on a sidewall.
  • Technical Importance: The invention purports to offer an improved collapsible cart that combines the convenience of compact storage with the structural integrity needed to carry high loads, a persistent challenge in the field of portable containers (’446 Patent, col. 2:9-12).

Key Claims at a Glance

  • The complaint identifies independent claims 1, 10, 16, and 22 as relevant to the dispute (Compl. ¶35).
  • Independent Claim 1 requires, in part:
    • A collapsible cart with a rigid frame and inwardly folding sidewalls.
    • 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 engaged with the track, movable between an open position and a closed position to "selectively lock the first right panel to the second right panel."
  • The complaint does not specify any asserted dependent claims.

U.S. Patent No. 12,304,546 - "Collapsible carts," Issued May 20, 2025

The Invention Explained

  • Problem Addressed: Similar to the ’446 patent, this patent addresses the problem that prior art collapsible carts lack sidewall sturdiness, which limits their utility for carrying heavy loads (’546 Patent, col. 2:26-29).
  • The Patented Solution: This invention also describes a collapsible cart with a multi-wall frame where at least three walls fold inwardly. The patented solution for reinforcing the structure involves a specific latching system. One of the folding walls is made of two panels, and each panel has a "latch part" on its edge; these latch parts are "configured to mate with one another" to hold the panels securely in a common plane when the cart is open (’546 Patent, col. 13:32-42). The patent's detailed description focuses on the overall structure and folding action of the cart, with the specific "latch part" terminology appearing primarily in the claims (’546 Patent, col. 6:9-21).
  • Technical Importance: The claimed invention aims to provide a robust and stackable collapsible cart, improving on existing designs by creating a more secure method for locking the foldable walls into a rigid, load-bearing configuration (’546 Patent, col. 2:30-40).

Key Claims at a Glance

  • The complaint identifies independent claims 1, 9, and 17 as relevant to the dispute (Compl. ¶42).
  • Independent Claim 1 requires, in part:
    • A collapsible cart with a frame of at least five walls, two of which are opposing and fold inwardly.
    • One of the opposing walls consists of a first panel and a second panel rotatably coupled together.
    • 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 and hold the first and second panels in a common plane."
  • The complaint does not specify any asserted dependent claims.

III. The Accused Instrumentality

Product Identification

The products at issue are various models of "storage bins" sold by the several Plaintiffs on Amazon.com under storefronts including “IBEAUTY LIMITED COMPANY,” “XIANGHUO,” and “LYUSDD” (Compl. ¶¶ 20, 22, 24). The products are identified by specific Amazon Standard Identification Numbers (ASINs), such as B0CW97NT2B and B0CHRP96MS (Compl. ¶¶ 16, 22).

Functionality and Market Context

  • The complaint alleges that the accused products "serve solely as stationary storage containers" and are not used for transportation (Compl. ¶¶ 52, 59). It is asserted that the products do not include the specific locking mechanisms recited in the patents-in-suit, such as a "slideable member" or mating "latch parts" (Compl. ¶¶ 48, 56).
  • The complaint states that the Amazon marketplace is Plaintiffs' "primary sales channel into the United States" and that the removal of their product listings has caused "immediate and substantial harm" (Compl. ¶¶ 15-16, 32).

Visual Evidence

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

'446 Patent Infringement Allegations

This is a declaratory judgment action for non-infringement. The table reflects Plaintiffs' allegations that their products lack the claimed features.

Claim Element (from Independent Claim 1) Alleged Non-Infringing Functionality Complaint Citation Patent Citation
A collapsible cart configured to transition from a closed condition...to an open condition... Plaintiffs allege their products are "stationary storage containers," not "carts" as that term is properly construed. ¶52 col. 7:14-17
a rigid frame forming a compartment...the right sidewall and the left sidewall are configured to fold inwardly... The complaint does not provide a specific non-infringement theory for this element. ¶47 col. 7:18-24
the right sidewall comprising a first right panel rotatably coupled to a second right panel; The complaint does not provide a specific non-infringement theory for this element. ¶47 col. 7:25-26
a first track formed along the first right panel and the second right panel... The complaint does not provide a specific non-infringement theory for this element. ¶47 col. 7:27-30
a first slideable member cooperatively engaged to the first track...to selectively lock the first right panel to the second right panel... Plaintiffs allege the accused products do not include "a first slideable member cooperatively engaged to the first track." ¶48 col. 5:21-48

'546 Patent Infringement Allegations

This is a declaratory judgment action for non-infringement. The table reflects Plaintiffs' allegations that their products lack the claimed features.

Claim Element (from Independent Claim 1) Alleged Non-Infringing Functionality Complaint Citation Patent Citation
A collapsible cart configured to transition from a closed condition...to an open condition... Plaintiffs allege their products are "stationary storage containers," not "carts" as that term is properly construed. ¶59 col. 13:21-24
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 does not provide a specific non-infringement theory for this element. ¶55 col. 13:25-31
one of the two opposing walls consists of a first panel and a second panel...rotatably coupled... The complaint does not provide a specific non-infringement theory for this element. ¶55 col. 13:32-35
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 and hold the first and second panels in a common plane... Plaintiffs allege the accused products do not include this feature. ¶56 col. 13:36-42

Identified Points of Contention

  • Scope Questions: A central dispute will be whether Plaintiffs' "storage bins" fall within the scope of the term "cart" as used in the patents. The complaint advances a narrow definition of "cart" as a "small vehicle used to carry or transport items," arguing its products are stationary (Compl. ¶¶ 52, 59). The resolution of this claim construction issue may be dispositive for several claims.
  • Technical Questions: A key factual question will be whether the accused products contain structures that meet the limitations of a "slideable member" ('446 Patent) or mating "latch parts" ('546 Patent). The complaint makes conclusory denials of infringement on these elements (Compl. ¶¶ 48, 56), raising the question of what locking or fastening mechanisms, if any, the accused products actually employ and whether they are technically and legally distinct from the claimed inventions.

V. Key Claim Terms for Construction

  • The Term: "cart"
  • Context and Importance: This term appears in the preamble of all asserted independent claims. Plaintiffs' non-infringement position relies heavily on the argument that their "stationary storage containers" are not "carts" (Compl. ¶¶ 52, 59). The construction of this single term could therefore resolve, or substantially narrow, the infringement dispute.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party arguing for a broader definition may point to the patent titles ("High load capacity collapsible carts," "Collapsible carts") and the consistent use of the term throughout the specification. They may also argue that the presence of wheels and a handle, as described in the specification, inherently defines the invention as a device for transport, regardless of its marketing as a "storage bin" (’446 Patent, col. 5:50-70).
    • Evidence for a Narrower Interpretation: Plaintiffs explicitly argue for a narrow "plain and ordinary meaning" of a "small vehicle used to carry or transport items" (Compl. ¶52). They may argue that the specification's focus on "transporting heavy objects" and "rolling movement" requires that the primary purpose of the device be transportation, which they allege is not true for their products (’446 Patent, col. 2:15-16, col. 7:46-49).

VI. Other Allegations

State Law Claims

The complaint includes counts for Unfair Competition and Tortious Interference under California law (Compl. ¶¶ 61-70). The basis for these claims is the allegation that Defendant submitted "baseless" and "improper" patent infringement complaints to Amazon, knowing they would result in the removal of Plaintiffs' product listings and thereby interfere with their business relationships and prospective economic advantage (Compl. ¶¶ 63, 67). These allegations link the patent dispute directly to the commercial conduct between the parties on the Amazon platform.

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

This declaratory judgment action appears to center on three fundamental questions for the court:

  • A core issue will be one of definitional scope: Can the term "cart," which appears in every asserted claim and is described in the patents in the context of transport, be construed to read on products marketed and allegedly used as "stationary storage containers"? The outcome of this claim construction will significantly impact the infringement analysis.
  • A key evidentiary question will be one of technical presence: Assuming the accused products are "carts," do they in fact incorporate the specific locking mechanisms recited in the claims, such as the "slideable member" of the ’446 patent or the "mating latch parts" of the ’546 patent? This will require a direct factual comparison of the accused product design to the claim language.
  • A final question relates to commercial conduct: Did Defendant’s use of Amazon’s intellectual property reporting system, which resulted in the de-listing of Plaintiffs’ products, constitute an actionable business tort? This will likely depend on whether Defendant's infringement assertions are ultimately found to have been objectively baseless.