Shanghai Ruijun Culture Communication Co Ltd v. Dbest Products Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shanghai Ruijun Culture Communication Co., Ltd. (China)
  • Defendant: DBEST Products, Inc. (California)
  • Plaintiff’s Counsel: West Atlantic Law Firm, PLLC
• Case Identification: 1:25-cv-15487, N.D. Ill., 12/22/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Illinois because Defendant sells and ships products to customers in Illinois through Amazon.com and has directed patent enforcement activity (via infringement complaints to Amazon) toward Plaintiff’s product listings, which are available to Illinois customers.
• Core Dispute: Plaintiff seeks a declaratory judgment that its collapsible storage boxes do not infringe two of Defendant’s patents related to collapsible wheeled carts, and further that the patents are invalid.
• Technical Context: The technology at issue involves collapsible containers, a mature product category for consumer and commercial transport and storage applications.
• Key Procedural History: The litigation was precipitated by Defendant submitting one or more patent infringement complaints to Amazon.com, which resulted in the removal or disabling of Plaintiff’s product listings on the e-commerce platform.

Case Timeline

Date	Event
2020-01-06	Earliest Priority Date for ’446 and ’546 Patents
2025-04-15	U.S. Patent No. 12,275,446 Issues
2025-05-20	U.S. Patent No. 12,304,546 Issues
2025-11-21	Defendant submits infringement complaint(s) to Amazon
2025-12-22	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’s background section states that due to the "collapsible nature of the prior art cart design, the sidewalls may not be sufficiently sturdy to allow for transporting heavy objects" (’446 Patent, col. 2:13-16).
• The Patented Solution: The invention is a collapsible cart with enhanced structural integrity. The design features sidewalls composed of multiple panels that are rotatably coupled, such as a first panel hinged to a second panel (’446 Patent, col. 4:47-55). To provide rigidity when the cart is open, the panels are locked together by a "slideable member" that moves along a track spanning both panels, securing them in a coplanar alignment (’446 Patent, col. 5:19-25; Fig. 2).
• Technical Importance: This approach seeks to provide the convenience of a collapsible design while improving the load-bearing capacity and durability of the cart in its assembled state (’446 Patent, col. 2:13-18).

Key Claims at a Glance

• The complaint refers to the "asserted independent claims" without specifying claim numbers (Compl. ¶23). Claim 1 is the first independent claim of the patent.
• Essential Elements of Claim 1:
  • A rigid frame forming a compartment with front, rear, right, left, and bottom walls, where the sidewalls are configured to fold inwardly.
  • The right sidewall comprises a first right panel rotatably coupled to a second right panel.
  • A first track is formed along both the first and second right panels.
  • A first slideable member is engaged with the track and is 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 explicitly reserve the right to assert dependent claims, but refers generally to the "asserted claims" of the patents-in-suit (Compl. ¶23).

U.S. Patent No. 12,304,546 - "Collapsible Carts," issued May 20, 2025

The Invention Explained

• Problem Addressed: Similar to the ’446 Patent, the background identifies a need for improvements to collapsible carts, noting that prior art designs may lack the sturdiness required for heavy objects (’546 Patent, col. 2:22-26).
• The Patented Solution: The patent describes a collapsible cart with a frame of "at least five walls," where at least three walls can fold inwardly (’546 Patent, Claim 1). A key feature is a multi-panel sidewall where a first panel is rotatably coupled to a second panel. The panels are secured in a common plane by mating "latch parts" located on the edges of each panel, which hold the sidewall rigid when the cart is assembled (’546 Patent, col. 2:44-63; Claim 1). This mechanism, like that of the ’446 Patent, is designed to enhance structural stability.
• Technical Importance: The invention aims to create a more robust collapsible container by providing a specific mechanism to lock the folding sidewall panels into a rigid, load-bearing configuration (’546 Patent, col. 2:22-29).

Key Claims at a Glance

• The complaint refers to the "asserted independent claims" without specifying claim numbers (Compl. ¶23). Claim 1 is the first independent claim of the patent.
• Essential Elements of Claim 1:
  • A frame defining a compartment with at least five walls, three of which are configured to rotatably fold inwardly.
  • One of the opposing walls consists of a first panel and a second panel, with the second panel being rotatably coupled to the first.
  • A "first latch part" is disposed on an edge of the first panel.
  • A "second latch part" is disposed on an edge of the second panel.
  • The latch parts are configured to "mate with one another and hold the first and second panels in a common plane" when latched.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The "Freebat-US Products," identified as collapsible storage boxes sold on Amazon.com under ASINs B0CSJM8131 and B0D2NFZL89 (Compl. ¶10).

Functionality and Market Context

• The complaint alleges the accused products are "collapsible storage boxes" (Compl. ¶23).
• Critically, the plaintiff contends these products operate without key features claimed in the patents-in-suit, such as "wheeled cart structures, sliding engagement mechanisms, and multi-panel cooperative assemblies" (Compl. ¶23, ¶29).
• The parties are described as direct competitors on Amazon.com, and the dispute arose from Defendant’s infringement complaints to Amazon, which led to the removal of Plaintiff's product listings (Compl. ¶3, ¶5).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a claim-by-claim analysis in an attached Exhibit E, which was not provided with the filed complaint for this report (Compl. ¶24, ¶28). The infringement theory is therefore summarized from the narrative allegations in the complaint body.

The plaintiff’s central argument for non-infringement is that its "collapsible storage boxes" are fundamentally different from the "collapsible carts" claimed in the patents-in-suit (Compl. ¶23). The complaint asserts that the Freebat-US Products lack multiple structural and functional limitations required by the asserted claims, including "specific panel configurations, locking assemblies, track-and-slide mechanisms," and "wheeled cart structures" (Compl. ¶23, ¶29). This suggests the plaintiff’s non-infringement case rests on both a definitional mismatch (box vs. cart) and a technical mismatch regarding the specific locking mechanisms for the sidewalls.

• Identified Points of Contention:
  • Scope Questions: A primary issue may be whether the term "collapsible cart," as used in the independent claims, can be construed to cover a product described as a wheelless "storage box." While the patent specifications and figures consistently depict wheeled embodiments, several independent claims (e.g., Claim 1 of both patents) do not explicitly recite wheels, which are instead added in dependent claims (e.g., ’446 Patent, Claim 8; ’546 Patent, Claim 6). This raises the question of whether a wheeled structure is an inherent feature of a "cart" in the context of the patents.
  • Technical Questions: The complaint alleges a complete absence of the claimed locking mechanisms (Compl. ¶23). A central factual dispute will be whether the accused products possess any structure that could be argued to function as the "slideable member" on a "track" (’446 Patent) or as the mating "latch parts" (’546 Patent) required to lock the sidewall panels together.

V. Key Claim Terms for Construction

• The Term: "collapsible cart" (e.g., ’446 Patent, Claim 1)

  • Context and Importance: This term is foundational to the dispute, as the plaintiff characterizes its product as a "storage box" to distinguish it from the claimed "cart" (Compl. ¶23). Its construction may determine whether the patents apply to wheelless products. Practitioners may focus on this term because the patents' specifications exclusively depict wheeled embodiments, yet the independent claims do not explicitly require them.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patents do not provide an explicit definition of "cart" that requires wheels. The absence of "wheels" as an express limitation in the independent claims, while being added in dependent claims, may suggest that the term "cart" was intended to be broader than just wheeled vehicles.
    • Evidence for a Narrower Interpretation: The entirety of the patents’ disclosures, including the abstract, summary, detailed description, and all figures, consistently illustrate the invention as a wheeled apparatus for transport (’446 Patent, Abstract; Figs. 1-18). A party could argue that this uniform depiction limits the term "cart" to a wheeled device.

• The Term: "first slideable member" (’446 Patent, Claim 1); "latch part" (’546 Patent, Claim 1)

  • Context and Importance: Plaintiff alleges its products lack "locking assemblies" and "track-and-slide mechanisms" (Compl. ¶23). The definition of these terms will be critical to determining if any feature on the accused products meets these limitations.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A patentee might argue that these terms should be given their plain and ordinary meaning, covering any component that moves or latches to secure the panels, without being limited to the specific embodiments shown.
    • Evidence for a Narrower Interpretation: The ’446 Patent specification describes and illustrates a distinct component (58) that slides within a defined channel or track (46) spanning two panels (’446 Patent, col. 5:19-25; Fig. 2). A party seeking a narrower construction may argue that the term "slideable member" is limited to this type of structure and does not cover other forms of latches or fasteners. Similarly, for the ’546 Patent, the specific embodiments shown may be used to narrow the interpretation of "latch part."

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

• A core issue will be one of definitional scope: Can the term "collapsible cart," which is described and illustrated exclusively with wheels throughout the patent specifications, be construed to cover a wheelless "collapsible storage box," particularly when the asserted independent claims do not expressly recite wheels?
• A key evidentiary question will be one of technical presence: Do the accused storage boxes contain any mechanical structure that performs the specific function of the claimed locking mechanisms—namely, a "slideable member" moving along a "track" or mating "latch parts" designed to secure adjacent folding panels into a rigid, coplanar state—or are the products devoid of any such infringing components as the complaint alleges?