DCT
1:25-cv-03324
Enhomee Direct v. Dbest Products Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: EnHomee-Direct (China)
- Defendant: Dbest Products Inc. (California)
- Plaintiff’s Counsel: TZZ Law
- Case Identification: 1:25-cv-03324, N.D. Ill., 03/28/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant conducts business nationwide, including in Illinois, through e-commerce storefronts and has directed its patent enforcement activities at Plaintiff, impacting its business in the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its stackable storage bins do not infringe Defendant’s patent for collapsible carts, following Defendant’s infringement complaint to Amazon.com which resulted in the removal of Plaintiff's product listings.
- Technical Context: The technology concerns collapsible, wheeled storage carts, focusing on the mechanical structures used to lock the foldable panels into a rigid, open position and to allow for stacking.
- Key Procedural History: The lawsuit was precipitated by Defendant’s filing of a patent infringement complaint against Plaintiff through Amazon's intellectual property notice program, which led to the delisting of Plaintiff’s products. The current action is Plaintiff’s response, seeking a judicial declaration of non-infringement to resolve the dispute and reinstate its listings.
Case Timeline
| Date | Event |
|---|---|
| 2020-01-06 | U.S. Patent No. 12,103,576 Priority Date |
| 2024-10-01 | U.S. Patent No. 12,103,576 Issue Date |
| 2024-11-22 | Defendant reports Plaintiff to Amazon.com for alleged patent infringement |
| 2025-03-28 | 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 addresses a perceived deficiency in prior art collapsible carts, noting that "the sidewalls may not be sufficiently sturdy to allow for transporting heavy objects" due to their collapsible nature (’576 Patent, col. 2:22-24).
- The Patented Solution: The invention is a collapsible cart with a specific locking mechanism to enhance its structural integrity when unfolded. The solution involves sidewalls made of multiple panels that are locked together. One embodiment uses a "slideable member" that moves along a "track" spanning two adjacent folding panels to secure them in an open position (’576 Patent, col. 2:42-59). The patent also describes features for vertical stacking, such as a top cover with an indentation pattern designed to receive the wheel assembly of an identical cart placed on top (’576 Patent, col. 4:46-52; FIG. 1).
- Technical Importance: The invention aims to provide a collapsible cart that combines the convenience of compact storage with the sturdiness required for carrying heavy loads, a common trade-off in the design of such products.
Key Claims at a Glance
- The complaint identifies independent claims 1, 11, and 15 as being at issue (Compl. ¶24).
- Independent Claim 1 recites a collapsible cart with:
- A rigid frame with a front wall, rear wall, right sidewall, left sidewall, and bottom wall.
- The right sidewall comprises a first right panel rotatably coupled to a second right panel.
- A "first track formed along the first right panel and the second right panel."
- A "first slideable member" that is movable along the track to lock the first right panel to the second right panel.
- Independent Claim 11 recites a cart with:
- A rigid frame with foldable sidewalls.
- The right sidewall comprises a first right panel rotatably coupled to a second right panel, where the second panel comprises a "ribbed wall with a plurality of ribs."
- A "first lock assembly integrated with the first right panel and the second right panel" for locking them together.
- Independent Claim 15 recites a stackable collapsible cart with:
- A rigid frame with a right sidewall comprising a first and second right panel.
- A "first lock assembly" to integrate the first and second right panels.
- A "wheel assembly" coupled to the bottom wall with a "first vertical axis."
- A "rigid top cover" with an "indentation pattern" that is substantially aligned with the wheel's vertical axis to receive a wheel from another cart for stacking.
- The complaint does not explicitly reserve the right to assert dependent claims but seeks a declaration of non-infringement of the '576 patent generally.
III. The Accused Instrumentality
- Product Identification: The accused products are Plaintiff’s "stackable storage bins" sold on Amazon.com under various ASINs (Compl. ¶¶ 2, 16).
- Functionality and Market Context:
- The complaint describes the accused products as stackable storage bins that do not possess the specific structural elements claimed in the '576 Patent (Compl. ¶18).
- Specifically, the plaintiff alleges its products do not use a track and slidable member system for locking (Compl. ¶25). Instead, the products allegedly secure their panels "using magnets that attract metal screws" (Compl. ¶28(2)).
- The complaint notes that sales on the Amazon marketplace account for "a significant portion of Plaintiff's business," which was disrupted by the delisting of the accused products (Compl. ¶14).
IV. Analysis of Infringement Allegations
The complaint references a claim chart in Exhibit 3, which was not filed with the complaint. The following summary is based on the narrative non-infringement allegations in the complaint body.
’576 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first track formed along the first right panel and the second right panel | Plaintiff alleges its product lacks this element, stating "There is no track that is formed along the first and second right panels." | ¶25 | col. 2:42-47 |
| a first slideable member cooperatively engaged to the first track...movable along the first track...to selectively lock the first right panel to the second right panel | Plaintiff alleges its product lacks this element, stating "there is no slidable member whatsoever in the accused product." | ¶25 | col. 2:48-59 |
Additional Non-Infringement Contentions (Claims 11 & 15)
- Claim 11: The complaint alleges non-infringement because the accused products "do not include a ribbed wall" and "there is no lock assembly present...that integrates the locking mechanism" as claimed (Compl. ¶26).
- Claim 15: The complaint alleges non-infringement on multiple grounds, stating the product lacks a "lock assembly," none of the "wheel assemblies have a vertical axis," the "top cover is placed separately...and is never fixed," and the top cover "has no indentation pattern" for stacking as claimed (Compl. ¶27).
Identified Points of Contention:
- Technical Question: A central factual dispute will be the mechanism used to secure the panels of the accused product. The complaint asserts the use of "magnets that attract metal screws," which it contends is structurally and functionally different from the claimed "track" and "slideable member" or integrated "lock assembly" (Compl. ¶28(2)). Evidence regarding the actual construction of the accused product will be critical.
- Scope Question: The case may turn on whether the term "lock assembly", as used in claims 11 and 15, can be construed broadly enough to read on the alleged magnet-and-screw mechanism of the accused product.
- Structural Mismatches: Plaintiff identifies several alleged structural differences for Claim 15, including the absence of a "vertical axis" for the wheel assembly and the lack of a specific "indentation pattern" on the top cover (Compl. ¶27). The existence and functional significance of these features in both the patent and the accused product will be points of dispute.
- No probative visual evidence provided in complaint.
V. Key Claim Terms for Construction
The Term: "lock assembly" (Claim 11), "first lock assembly" (Claim 15)
Context and Importance: This term appears in the independent claims that do not recite the more specific "track" and "slideable member" of Claim 1. Its construction is critical because the plaintiff alleges its product uses magnets and screws, not an "integrated lock assembly" (Compl. ¶28(2)). The court's interpretation will determine whether the plaintiff's magnetic system falls within the scope of these claims.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not appear to provide an explicit definition of "lock assembly". A party could argue that the term should be given its plain and ordinary meaning, which might encompass any mechanism that serves to lock panels together, including a magnetic one.
- Evidence for a Narrower Interpretation: The specification consistently describes the locking mechanism in the context of the "first track" (46) and "first slideable member" (58) embodiment (e.g., ’576 Patent, col. 7:4-13; FIG. 2). A party could argue that the patent's disclosure limits the scope of "lock assembly" to mechanical sliding or interlocking structures, as opposed to magnetic ones.
The Term: "a first track" (Claim 1)
Context and Importance: The plaintiff bases its non-infringement argument for Claim 1 on the complete absence of a "track" (Compl. ¶25). Practitioners may focus on this term because its presence or absence is a dispositive factual question. The dispute will involve comparing the structure of the accused product to the patent's description of a track.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims do not specify the material or precise form of the track, only that it is "formed along the first right panel and the second right panel" and allows a slidable member to move along it (’576 Patent, col. 12:50-55).
- Evidence for a Narrower Interpretation: The figures, such as FIG. 2, depict the track (46) as a distinct, raised rail-like structure upon which a slideable member (58) moves. An argument could be made that the term "track" is limited to such a physical guideway and does not read on other forms of alignment or connection.
VI. Other Allegations
- Tortious Interference: The complaint includes a second count for tortious interference with contract and business relations under state law (Compl. ¶¶ 32-43). It alleges that Defendant knew of Plaintiff's relationship with Amazon and intentionally interfered with it by "wrongfully complaining" of patent infringement, causing Plaintiff to lose revenue (Compl. ¶¶ 35-36, 41).
- Exceptional Case: Plaintiff seeks a judgment that the case is "exceptional" under 35 U.S.C. § 285, which would entitle it to attorneys' fees. The basis for this allegation is Defendant's "anticompetitive actions aimed at eliminating a competitor's product by falsely claiming" infringement (Compl. ¶3; Prayer for Relief ¶3).
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to center on fundamental, dispositive questions of claim scope and technical comparison. The outcome will likely depend on the court's resolution of these issues:
- A core issue will be one of claim construction: Can the term "lock assembly" from claims 11 and 15 be interpreted to cover the accused product's alleged use of magnets and screws, or is its meaning limited by the specification's disclosure of a mechanical sliding mechanism?
- A key evidentiary question will be one of structural comparison: Does the accused product, as a matter of fact, incorporate a physical "track" as required by Claim 1 and a wheel assembly with a "vertical axis" and a top cover with an "indentation pattern" as required by Claim 15? The plaintiff's assertion of a complete absence of these features suggests the infringement analysis may be a direct, element-by-element comparison rather than a nuanced equivalents argument.
- A secondary issue is the viability of the tortious interference claim: Can the plaintiff prove that the defendant's infringement report to Amazon was not just incorrect but was wrongful and made in bad faith, especially given the presumption that a patent holder is entitled to enforce its rights?