DCT
1:24-cv-13287
Jinhuashiyehedianzishangwuyouxiangongsi v. Dbest Products Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: jinhuashiyehedianzishangwuyouxiangongsi d/b/a Huohuachichi (China)
- Defendant: Dbest Products Inc. (California)
- Plaintiff’s Counsel: Bishop Diehl & Lee, LTD.
- Case Identification: 1:24-cv-13287, N.D. Ill., 12/27/2024
- Venue Allegations: Venue is based on Defendant's e-commerce sales directed at Illinois residents and its patent enforcement actions through Amazon's reporting system, which allegedly caused Plaintiff business harm within the district.
- Core Dispute: Plaintiff seeks a declaratory judgment of non-infringement and invalidity of Defendant's patent related to stackable collapsible carts, following Defendant's infringement allegations made through an e-commerce platform's intellectual property reporting system.
- Technical Context: The technology at issue involves collapsible wheeled carts, a consumer product category where portability and structural strength are key competing design considerations.
- Key Procedural History: The action was precipitated by Defendant's patent infringement report filed with Amazon against Plaintiff on or around December 5, 2024, which threatened the removal of Plaintiff's product listings and prompted Plaintiff to file this declaratory judgment action.
Case Timeline
| Date | Event |
|---|---|
| 2020-01-06 | Earliest Priority Date for '576 Patent |
| 2024-10-01 | U.S. Patent No. 12,103,576 Issued |
| 2024-12-05 | Defendant reports Plaintiff to Amazon for infringement |
| 2024-12-27 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
- U.S. Patent No. 12,103,576, "STACKABLE COLLAPSIBLE CARTS," issued October 1, 2024
The Invention Explained
- Problem Addressed: The patent background describes a technical problem with prior art collapsible carts, noting that their collapsible nature can result in sidewalls that are not "sufficiently sturdy to allow for transporting heavy objects" (’576 Patent, col. 2:21-24).
- The Patented Solution: The invention claims to solve this problem with a collapsible cart featuring multi-panel sidewalls that can be locked together to enhance rigidity when the cart is in its open, expanded condition (’576 Patent, Abstract). For example, a right sidewall may have a first panel and a second panel that fits within an opening in the first; a "slideable member" then moves along a "track" spanning both panels to lock them together, creating a more robust structure (’576 Patent, col. 1:41-57).
- Technical Importance: The described approach seeks to combine the storage convenience of a collapsible design with the structural integrity of a rigid cart, addressing a primary performance trade-off in the field.
Key Claims at a Glance
- The complaint identifies independent claims 1, 11, and 15 as being at issue (Compl. ¶¶29-31).
- Independent Claim 1: Recites a collapsible cart with a rigid frame and foldable sidewalls, where a right sidewall includes a first panel rotatably coupled to a second panel, a "first track" formed along both panels, and a "first slideable member" that moves along the track to lock the panels together.
- Independent Claim 11: Recites a cart where the right sidewall comprises a first panel, a second panel, and a "third right panel," which together "conform in shape to collectively cover the opening in the first right panel," along with a "first lock assembly."
- Independent Claim 15: Recites a stackable collapsible cart with a wheel assembly and a "rigid top cover" that has an "indentation pattern" that is "at least substantially aligned with the vertical axis of the wheel assembly" to receive a wheel from an identical cart stacked on top.
III. The Accused Instrumentality
Product Identification
The accused products are "Plaintiff's stackable storage bins," identified as the "Non-Infringing Product" (Compl. ¶3). The complaint lists specific Amazon Standard Identification Numbers (ASINs): B0CGD1R87W, B0DGTP4PZJ, B0CGD1W4P6, B0D93RMSVD, and B0D9BCZJSK (Compl. ¶15).
Functionality and Market Context
The complaint, being for declaratory judgment, does not provide a detailed technical description of the accused products' functionality. It focuses instead on alleging what the products lack in relation to the patent claims. The complaint alleges that sales on the Amazon marketplace account for a "significant portion of Plaintiff's business" (Compl. ¶14).
IV. Analysis of Infringement Allegations
The complaint does not provide affirmative infringement allegations but rather specific denials of infringement. The following tables summarize Plaintiff's non-infringement theories for the asserted independent claims.
No probative visual evidence provided in complaint.
'576 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Feature (Reason for Non-Infringement) | Complaint Citation | Patent Citation |
|---|---|---|---|
| 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 | Plaintiff's products "lack the 'a first track' limitation." | ¶29 | col. 12:48-54 |
'576 Patent Infringement Allegations
| Claim Element (from Independent Claim 15) | Alleged Non-Infringing Feature (Reason for Non-Infringement) | Complaint Citation | Patent Citation |
|---|---|---|---|
| wherein the rigid top cover has an indentation pattern being at least substantially aligned with the vertical axis of the wheel assembly, the indentation pattern configured to receive a wheel assembly from another identical collapsible cart when stacked vertically | Plaintiff's products lack the limitation that "the rigid top cover has an indentation pattern being at least substantially aligned with the vertical axis of the wheel assembly." | ¶31 | col. 14:12-19 |
Identified Points of Contention
- Technical Questions: The primary disputes appear to be factual and technical in nature. For Claim 1, the question is whether the accused product has a structure that meets the definition of "a first track." For Claim 11, the question is whether the accused product's sidewall has a "third right panel" as claimed (Compl. ¶30). For Claim 15, the dispute centers on whether the accused product's top cover has the specific "indentation pattern" for stacking as recited in the claim.
- Scope Questions: The resolution of the technical questions will depend heavily on claim construction. The scope of terms like "track," "third right panel," and "indentation pattern" will determine whether the accused products' features are covered.
V. Key Claim Terms for Construction
"a first track" (Claim 1)
Context and Importance
This term is critical because Plaintiff's primary defense to infringement of Claim 1 is that its product lacks this element entirely (Compl. ¶29). The definition of what constitutes a "track" for the "slideable member" will be a central point of contention.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The specification describes the element functionally as a structure that a "slideable member" can be "movable along" to lock two panels together (’576 Patent, col. 12:56-61). A party could argue that any guide or rail that performs this function meets the definition.
- Evidence for a Narrower Interpretation: The patent figures, such as Figure 42B, depict a specific physical structure for the track (46) and the cooperating slideable member (58). A party could argue the term should be construed more narrowly to be limited to the disclosed structure or a close equivalent.
"indentation pattern" (Claim 15)
Context and Importance
Plaintiff's non-infringement argument for Claim 15 hinges on the absence of this feature (Compl. ¶31). The case may turn on whether any recessed or textured feature on the accused product's lid can be considered an "indentation pattern" that is "substantially aligned" with the wheels for stacking.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The claim language itself is functional, defining the pattern as being "configured to receive a wheel assembly from another identical collapsible cart when stacked vertically" (’576 Patent, col. 14:16-19). This could support a construction covering any surface feature that achieves this purpose.
- Evidence for a Narrower Interpretation: Figure 62 illustrates a specific indentation pattern (62a) that appears to be a distinct recess shaped to match the wheel assembly's footprint. This could support an argument that the term requires a specific, mating recess, not merely a textured surface.
VI. Other Allegations
Indirect Infringement
The complaint includes a general denial of indirect infringement (Compl. ¶26), but as a declaratory judgment action, it provides no specific facts for analysis on this issue.
Willful Infringement
There is no allegation of willful infringement. Instead, Plaintiff alleges that Defendant's infringement accusations are "baseless and exceptional" and seeks an award of attorneys' fees pursuant to 35 U.S.C. § 285 (Compl. ¶33). This allegation suggests Plaintiff believes Defendant's enforcement activities lacked a good-faith basis.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim construction: can the term "a first track," as shown in specific embodiments in the patent, be construed broadly enough to read on the mechanism used to join the wall panels of the accused product, or is it limited to a structure the accused product does not have?
- A key factual and evidentiary question will be one of structural correspondence: does the top cover of the accused product possess a physical "indentation pattern" for stacking that is "substantially aligned" with its wheels as required by Claim 15, or is there a fundamental structural mismatch?
- Beyond patent law, a core issue for the court will be one of enforcement conduct: was Defendant's use of Amazon’s IP reporting system a legitimate exercise of its patent rights, or does the evidence support Plaintiff’s claim that the allegations were "baseless," potentially giving rise to liability for tortious interference and rendering the case exceptional?