DCT
1:24-cv-10045
Sanders Collection Inc v. Dbest Products Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Sanders Collection Inc. (New York)
- Defendant: dbest Products, Inc. (California)
- Plaintiff’s Counsel: Garson, Ségal, Steinmetz, Fladgate LLP
- Case Identification: 1:24-cv-10045, S.D.N.Y., 12/31/2024
- Venue Allegations: Plaintiff alleges venue is proper because a substantial portion of the events occurred in the district, Defendant maintains a website and sells products to customers in New York, and Defendant’s conduct has caused harm to Plaintiff in the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its stackable collapsible cart products do not infringe Defendant’s patent, following Defendant’s assertion of infringement to Amazon.com which resulted in the delisting of Plaintiff's products.
- Technical Context: The technology relates to collapsible, wheeled utility carts designed for convenient storage and transport of goods.
- Key Procedural History: The action was precipitated by Defendant's patent infringement report to Amazon, which caused Amazon to delist Plaintiff's products. Plaintiff alleges it sent a letter to Defendant detailing its non-infringement position, but Defendant’s response was non-committal, creating an ongoing controversy. The complaint also notes that Defendant has previously asserted the patent-in-suit against other companies and has a history of litigation tactics intended to secure favorable venue.
Case Timeline
| Date | Event |
|---|---|
| 2020-01-06 | Earliest Priority Date for ’576 Patent |
| 2024-10-01 | ’576 Patent Issue Date |
| 2024-11-26 | Sanders receives notice of alleged infringement from Amazon |
| 2024-12-04 | Sanders' counsel sends letter to Amazon asserting non-infringement |
| 2024-12-11 | Sanders' counsel sends letter to dbest asserting non-infringement |
| 2024-12-17 | dbest responds to Sanders' letter |
| 2024-12-31 | 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" due to their collapsible nature (’576 Patent, col. 1:21-24).
- The Patented Solution: The invention is a collapsible cart that transitions between a folded state for storage and an expanded state for use (’576 Patent, Abstract). It features a rigid frame with a front wall, rear wall, bottom wall, and two sidewalls (right and left) that are configured to "fold inwardly" (’576 Patent, Abstract). The sidewalls are composed of multiple panels, such as a first right panel rotatably coupled to a second right panel, which can be selectively locked together to provide structural integrity when the cart is in its open, expanded condition (’576 Patent, col. 2:38-50).
- Technical Importance: The design aims to provide the convenience of a collapsible cart with the sturdiness of a rigid container by using lockable, multi-panel sidewalls.
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement of independent claims 1, 11, and 15 (Compl. ¶¶ 41, 41(p.13)).
- Independent Claim 1 recites a collapsible cart comprising:
- A rigid frame with front, rear, right, and left sidewalls configured to fold inwardly.
- The right sidewall has a first right panel rotatably coupled to a second right panel, proportioned to fit within an opening in the first panel.
- A "first track" formed along the first and second right panels.
- A "first slideable member" engaged with the track, movable between open and closed positions to lock the first right panel to the second right panel.
- Independent Claim 11 recites a cart comprising:
- A rigid frame with front, rear, right, and left sidewalls configured to fold inwardly.
- The right sidewall has a first panel, a second panel, and a third panel, where the second and third panels conform in shape to collectively cover the opening in the first panel.
- A "first lock assembly" integrated with the first and second right panels with conditions for locking and unlocking them.
- Independent Claim 15 recites a stackable collapsible cart comprising:
- A rigid frame with right and left sidewalls configured to fold inwardly, with the right sidewall comprising a first right panel rotatably coupled to a second.
- A "first lock assembly" integrated with the first and second right panels.
- A wheel assembly and a rigid top cover with an indentation pattern for stacking.
- The complaint states that because the independent claims are not infringed, neither are the dependent claims (Compl. ¶ 41(p.13)).
III. The Accused Instrumentality
Product Identification
- The complaint identifies numerous "Accused Products" by their Amazon Standard Identification Numbers (ASINs), described as "stackable collapsible cart[s]" (Compl. ¶¶ 21, 28).
Functionality and Market Context
- The complaint alleges the Accused Products do not have the sliding lock mechanism recited in the ’576 Patent claims (Compl. ¶ 34). Instead, they are alleged to "contain a magnetic closure system" (Compl. ¶ 34).
- Plaintiff contends that the Accused Products have an "entirely rigid construction" and are "incapable of performing any folding actions" related to the sidewalls as described in the patent (Compl. p. 12-13, ¶ 41).
- The complaint highlights the commercial importance of the products by noting that their delisting from Amazon resulted in "numerous lost sales" (Compl. ¶ 31).
IV. Analysis of Infringement Allegations
The complaint’s non-infringement arguments center on structural and functional differences between the Accused Products and the patent’s claims.
’576 Patent Infringement Allegations (Claim 1)
| 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 extending from a first position on the first right panel to a second position on the second right panel | The Accused Products are alleged not to have a "track" mechanism as defined in the patent. | ¶41 | col. 2:43-48 |
| a first slideable member cooperatively engaged to the first track... movable along the first track between an open position to a closed position to selectively lock the first right panel to the second right panel | The Accused Products are alleged to lack a "slideable member." Instead, they are alleged to use a "magnetic closure system" which is described as being in "stark contrast to the sliding mechanism shown in the '576 Patent." A visual comparison is provided in the complaint's "Comparison Chart 1," which depicts the patent's sliding lock alongside a photo of the accused product's magnetic closure. | ¶¶ 34, 41; p. 10 | col. 2:48-50 |
’576 Patent Infringement Allegations (Claims 11 & 15)
| Claim Element (from Independent Claims 11 & 15) | 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... | The complaint alleges the Accused Products "have no lock assembly at all." The complaint's "Comparison Chart 2" visually contrasts a figure from the patent showing a lock mechanism with a photograph of the accused product, which is alleged to lack such a feature. | ¶41; p. 11-12 | col. 13:4-9 |
| the right sidewall and the left sidewall are configured to fold inwardly in the closed condition | The complaint alleges the Accused Products have an "entirely rigid construction" and that the resulting assembly is "incapable of performing any folding actions." | p. 12-13, ¶ 41 | col. 2:36-38 |
Identified Points of Contention
- Scope Questions: A central dispute concerns whether the claim terms "first track" and "first slideable member" can be interpreted to read on the "magnetic closure system" of the Accused Products. A related question is whether the broader term "lock assembly" requires a mechanical, sliding structure as depicted in the patent's embodiments or could encompass other fastening means.
- Technical Questions: A key factual dispute appears to be whether the Accused Products are "configured to fold inwardly" as required by the claims. The complaint asserts they have an "entirely rigid construction," raising a direct question of fact about the product's physical capabilities compared to the claimed function.
V. Key Claim Terms for Construction
The Term: "a first track ... and a first slideable member"
Context and Importance: This combination of terms from Claim 1 is at the core of the non-infringement argument. The complaint explicitly contrasts this "sliding mechanism" with the accused "magnetic closure system" (Compl. ¶ 34). The outcome of the case may depend on whether a magnetic closure can be considered equivalent to the claimed track and slider.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states that the description is "made only by way of example and not as a limitation on the scope of the embodiments as claimed" (’576 Patent, col. 11:37-40), which a patentee might argue allows for interpretations beyond the specific embodiments shown.
- Evidence for a Narrower Interpretation: The specification consistently describes a physical "track" (46) and a "slideable member" (58) that moves along it, as illustrated in Figures 2, 42A, and 42B (’576 Patent, col. 7:4-13). This detailed description of a specific mechanical structure may support an interpretation that excludes functionally different mechanisms like magnets.
The Term: "lock assembly"
Context and Importance: This term appears in independent claims 11 and 15. The Plaintiff alleges the Accused Products "have no lock assembly at all" (Compl. ¶ 41). The construction of this term will determine whether the Accused Products meet a key limitation of these claims.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "lock assembly" is used in different contexts within the patent, including one for the side panels and another "integrated second lock assembly" for the top cover (’576 Patent, col. 14:38-40). A party could argue this shows the term is not limited to a single specific structure.
- Evidence for a Narrower Interpretation: The "first lock assembly" is explicitly defined in the summary as "comprising a first track and a first slideable member" (’576 Patent, col. 2:41-43). This language suggests that the term, at least in the context of the side panels, is coterminous with the track-and-slider mechanism, supporting a narrower reading.
VI. Other Allegations
- Allegations Against the Patentee: The complaint does not contain allegations of indirect or willful infringement by Sanders. Instead, it makes several allegations regarding the patentee's (dbest's) conduct. It alleges that dbest's infringement complaint to Amazon was sent in "bad faith, with malice, oppression, and fraud" because dbest allegedly knew the Accused Products did not contain the claimed limitations (Compl. ¶ 48). The complaint further alleges that dbest has a "history of willfully exploiting" legal procedures to "manipulate venue selection" (Compl. ¶ 36). These allegations form the basis for Sanders' claims of tortious interference and unfair competition, as well as its request for a finding that the case is "exceptional" under 35 U.S.C. § 285, which would permit an award of attorneys' fees (Compl. Prayer for Relief (e)).
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to hinge on a combination of claim construction and factual determinations regarding the accused product's operation. The central questions for the court will likely be:
- A core issue will be one of definitional scope: Can the claim terms "track" and "slideable member," which the patent describes as a specific mechanical sliding mechanism, be construed to cover the "magnetic closure system" allegedly used in the accused carts? Similarly, does the term "lock assembly" require this specific mechanical structure, or can it encompass other fastening methods?
- A key evidentiary question will be one of technical reality: Does the accused product’s structure, which the complaint alleges is "entirely rigid," possess the capability to have its sidewalls "fold inwardly" as required by multiple independent claims, or is there a fundamental mismatch in its physical construction and the claimed function?