DCT
1:25-cv-04305
Enhomee Direct v. Dbest Products Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: EnHomee-Direct (a private Chinese company)
- Defendant: Dbest Products Inc. (California)
- Plaintiff’s Counsel: TZZ Law
- Case Identification: EnHomee-Direct v. Dbest Products Inc., 1:25-cv-04305, N.D. Ill., 04/21/2025
- Venue Allegations: Venue is based on Defendant’s e-commerce sales to customers in Illinois and its patent assertion activities, conducted via a third-party tribunal (Amazon), which have allegedly impacted Plaintiff’s business in the state.
- Core Dispute: Plaintiff seeks a declaratory judgment that its stackable storage bins do not infringe Defendant’s patent related to stackable collapsible carts.
- Technical Context: The technology concerns collapsible storage carts, a consumer product category where features related to durability, ease of use, and stackability are key differentiators.
- Key Procedural History: The action was precipitated by Defendant filing a patent infringement complaint against Plaintiff through Amazon.com's intellectual property notice program, which resulted in the removal of Plaintiff’s product listings from the marketplace.
Case Timeline
| Date | Event |
|---|---|
| 2020-01-06 | Earliest Priority Date for U.S. Patent No. 12,103,576 |
| 2024-10-01 | Issue Date for U.S. Patent No. 12,103,576 |
| 2024-11-22 | Plaintiff receives notice of Defendant's infringement complaint filed with Amazon |
| 2025-04-21 | 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 notes that prior art collapsible carts may have sidewalls that are not "sufficiently sturdy to allow for transporting heavy objects" (’576 Patent, col. 1:21-23).
- The Patented Solution: The invention is a collapsible cart designed for improved structural rigidity. The solution involves sidewalls constructed from hinged panels that are locked together in the open position by a specific mechanism, described as a "slideable member" that moves along a "track" spanning the hinged panels (’576 Patent, Abstract; col. 11:40-12:2). This locking feature is intended to create a more robust container. The patent also discloses features for vertical stacking, such as a top cover with an "indentation pattern" shaped to receive the wheels of an identical cart placed on top (’576 Patent, col. 10:45-51, col. 14:12-17).
- Technical Importance: The described approach seeks to combine the convenience of a foldable, compact design with the strength and stability typically associated with rigid, non-collapsible containers.
Key Claims at a Glance
- The complaint identifies independent claims 1, 11, and 15 as being at issue (Compl. ¶24).
- Independent Claim 1: Essential elements include:
- A rigid frame with multiple walls, including a right sidewall with a first right panel rotatably coupled to a second right panel.
- A "first track" formed along both the first and second right panels.
- A "first slideable member" that engages with the track and is movable to lock the two panels together.
- Independent Claim 11: Essential elements include:
- A rigid frame with sidewalls, including a right sidewall with a first panel, a second panel, and a third panel.
- A "first lock assembly" integrated with the panels to lock them together.
- Independent Claim 15: Essential elements include:
- A rigid frame with a first right panel rotatably coupled to a second right panel.
- A "first lock assembly" for locking the panels.
- A "wheel assembly" coupled to the bottom.
- A "rigid top cover" with an "indentation pattern" aligned with the wheel assembly's vertical axis, configured to receive the wheel assembly of 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 entire patent (Compl. ¶1).
III. The Accused Instrumentality
Product Identification
- The accused products are Plaintiff's "stackable storage bins" sold on Amazon.com under various ASINs, which the complaint refers to collectively as the "Non-Infringing Product" (Compl. ¶2, ¶16).
Functionality and Market Context
- The products are described as stackable storage bins sold in competition with the Defendant on the Amazon e-commerce platform (Compl. ¶2). The complaint focuses on the products' non-infringing characteristics, alleging that they achieve panel locking and stacking through means different from those claimed in the ’576 Patent. Specifically, the complaint alleges the products secure panels using "magnets that attract metal screws" and have a top cover that lacks the specific indentation pattern required by the patent (Compl. ¶¶26-27). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint asserts non-infringement of independent claims 1, 11, and 15. The plaintiff’s non-infringement theories are summarized below.
’576 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first track formed along the first right panel and the second right panel...and a first slideable member cooperatively engaged to the first track...movable...to selectively lock the first right panel to the second right panel | Plaintiff's product does not include a track and slidable member for locking the panels together. | ¶25, ¶28(1) | col. 11:51-65 |
’576 Patent Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first lock assembly integrated with the first right panel and the second right panel, the first lock assembly having a first condition for locking the first right panel to the second right panel | Plaintiff's product secures panels using magnets that attract metal screws, which is alleged to not be an "integrated lock assembly." | ¶26, ¶28(2) | col. 13:3-9 |
’576 Patent Infringement Allegations
| Claim Element (from Independent Claim 15) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| 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 product’s top cover allegedly lacks the specified indentation pattern and does not securely fit when folded. | ¶27, ¶28(3) | col. 14:12-17 |
- Identified Points of Contention:
- Scope Questions: The dispute raises the question of whether the term "integrated lock assembly" can be construed to read on a mechanism that uses "magnets that attract metal screws," as the Plaintiff alleges its product uses (Compl. ¶26). Similarly, the case will question whether the term "track and slidable member" can encompass the Plaintiff's panel-securing mechanism (Compl. ¶25).
- Technical Questions: A central technical question is whether the top surface of the Plaintiff's product includes any structure that could be considered an "indentation pattern" for the purpose of stacking as claimed, or if there is a fundamental structural difference as alleged (Compl. ¶27).
V. Key Claim Terms for Construction
The Term: "track ... and ... slideable member"
Context and Importance: This two-part mechanism is the core of the locking feature in independent claim 1. Plaintiff’s primary non-infringement argument for this claim is that its product lacks this specific structure entirely (Compl. ¶25). Practitioners may focus on this term because its construction will determine whether a broader range of mechanical fasteners could be seen as infringing equivalents.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language describes the components functionally, as a "track" and a "slideable member" that moves along it to "selectively lock" the panels (’576 Patent, col. 11:51-65).
- Evidence for a Narrower Interpretation: The patent’s figures (e.g., FIG. 2, FIG. 42B) depict a specific embodiment of a physical channel (46) and a sliding clasp (58). A party could argue the terms should be limited to structures resembling this disclosed embodiment.
The Term: "integrated lock assembly"
Context and Importance: This term appears in both claims 11 and 15 and is a point of direct dispute, as Plaintiff alleges its use of magnets and screws does not meet this limitation (Compl. ¶26). The definition will be critical to determining infringement of these claims.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term itself is general. The claims state the assembly is "integrated with the first right panel and the second right panel" to perform a locking function, which could arguably cover any components built into the panels that work together to lock them (’576 Patent, col. 13:3-9).
- Evidence for a Narrower Interpretation: The specification, in describing the "first lock assembly," repeatedly refers to the "first slideable member" embodiment (’576 Patent, col. 9:22-30). This could support an interpretation that limits the "lock assembly" to the specific mechanical interlock shown, rather than a magnetic system.
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaratory judgment of non-infringement both directly and indirectly, as well as under the doctrine of equivalents (Compl. ¶30). No specific facts concerning indirect infringement are alleged, as this is a defensive pleading.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the claim terms "track and slidable member" and "integrated lock assembly," which are described in the patent specification as specific mechanical interlocks, be construed broadly enough to read on the magnet-and-screw fastening system allegedly used in the Plaintiff's product?
- A second central question will concern the functional requirements of stacking: what specific structure is required to meet the "indentation pattern configured to receive a wheel assembly" limitation of claim 15? The case may turn on whether the accused product's top cover, even if different, performs a substantially similar function in a substantially similar way to achieve a substantially similar result, raising questions under the doctrine of equivalents.