Huzhou Shunji E Commerce Co Ltd v. Dbest Products Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Huzhou Shunji E-Commerce Co., Ltd. a/k/a Sailun Home (China)
  • Defendant: Dbest Products, Inc. (California)
  • Plaintiff’s Counsel: Lance Liu, Esq.
• Case Identification: 1:25-cv-00353, S.D.N.Y., 01/14/2025
• Venue Allegations: Venue is based on allegations that Defendant conducts business in the judicial district through sales at retail stores and that its allegedly wrongful acts have caused harm to the Plaintiff within the district.
• Core Dispute: In this declaratory judgment action, Plaintiff seeks a court ruling that its "storage boxes" do not infringe Defendant's patent on "stackable collapsible carts," and that the patent is invalid, while also bringing claims for patent misuse and tortious interference.
• Technical Context: The technology relates to the field of collapsible containers, which are designed for convenient transport and storage of goods in both commercial and household settings.
• Key Procedural History: This action was filed after the Defendant, Dbest Products, Inc., allegedly filed an infringement complaint against the Plaintiff on the Amazon.com platform, resulting in the suspension of Plaintiff's online sales accounts. The Plaintiff characterizes the Defendant's enforcement action as "frivolous."

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

• Patent Identification: U.S. Patent No. 12,103,576, "STACKABLE COLLAPSIBLE CARTS," issued October 1, 2024.

The Invention Explained

• Problem Addressed: The patent's background section asserts that prior art collapsible carts often lack sufficient structural integrity, noting that "the sidewalls may not be sufficiently sturdy to allow for transporting heavy objects" (ʼ576 Patent, col. 1:22-24).
• The Patented Solution: The invention is a collapsible cart designed for improved strength and convenience. It features a rigid frame with sidewalls that fold inwardly for compact storage. At least one sidewall is constructed from multiple panels (e.g., a first panel rotatably coupled to a second) that can be locked together with a slideable member running along a track, creating a more robust structure when the cart is expanded for use (’576 Patent, Abstract; col. 2:36-59). Embodiments also include features like wheels, a telescoping handle, and a stackable design.
• Technical Importance: The design attempts to resolve a common trade-off in this product category by providing a container that is both easily collapsible for storage and structurally sound for carrying heavier items when assembled.

Key Claims at a Glance

• The complaint seeks a declaratory judgment of non-infringement for all claims, focusing on independent claims 1, 11, and 15.
• Independent Claim 1 recites:
  • A collapsible cart configured to transition from a closed condition to an open condition
  • a rigid frame with a front wall, rear wall, right sidewall, left sidewall, and bottom wall, where the sidewalls fold inwardly
  • the right sidewall comprising a first right panel rotatably coupled to a second right panel
  • a first track formed along the first and second right panels
  • a first slideable member that moves along the track to selectively lock the first right panel to the second right panel
• Independent Claim 11 recites a "cart" with inwardly folding sidewalls, where the right sidewall comprises a first, second, and third right panel, and includes a "first lock assembly" to secure the panels.
• Independent Claim 15 recites a "stackable collapsible cart" that includes, among other features, a "wheel assembly" and a "rigid top cover" with an "indentation pattern" configured to receive a wheel assembly from another cart for vertical stacking.

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are "storage boxes" sold by the Plaintiff on Amazon.com (Compl. ¶1).

Functionality and Market Context

• The complaint consistently distinguishes the Plaintiff's product from the patented invention by identifying it as a "storage box" rather than a "folding & rolling cart" (Compl. ¶7). The filing alleges that Defendant's patent enforcement actions against this product on Amazon.com led to the lockdown of Plaintiff's accounts, indicating that the online marketplace is a significant commercial channel for the product (Compl. ¶7, fn 1; ¶20). A visual comparison provided in the complaint depicts Plaintiff's product as a simple collapsible container without the wheels or telescoping handle shown on the patented cart (Compl. ¶12). This side-by-side comparison shows the Plaintiff's storage box next to Figure 8 from the '576 Patent (Compl. ¶12).

IV. Analysis of Infringement Allegations

The complaint alleges non-infringement by asserting that multiple required elements of the '576 Patent's claims are absent from the Plaintiff's product.

'576 Patent Infringement Allegations

Identified Points of Contention:

• Scope Questions: A central dispute will be whether the term "collapsible cart," as used in the patent, can be construed to read on the Plaintiff's product, which is presented as a "storage box." The complaint's repeated distinction between these product categories suggests this will be a primary focus (Compl. ¶¶ 7, 9).
• Technical Questions: The complaint raises the question of whether the accused product contains the specific mechanical features required by the claims. For example, what evidence exists that the accused "storage box" possesses inwardly folding multi-panel sidewalls, integrated tracks, or slideable locking members? The visual evidence provided by the Plaintiff suggests a fundamental structural difference (Compl. ¶12).

V. Key Claim Terms for Construction

• The Term: "collapsible cart"
• Context and Importance: This term, appearing in the preamble of independent claims 1, 11, and 15, is critical to the dispute. The Plaintiff's case for non-infringement is founded on the argument that its product is a "storage box" and not a "cart" (Compl. ¶9). The construction of this term may determine whether the patent claims apply to the accused product at all.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent's summary describes the invention in general terms as a "collapsible cart configured to transition from a closed condition... to an open condition," which could arguably encompass any container with this property (ʼ576 Patent, col. 2:30-33).
  • Evidence for a Narrower Interpretation: The patent consistently depicts embodiments with features for rolling transport, such as a "retractable handle mechanism" and "swivel wheels" (ʼ576 Patent, Abstract; Fig. 1; Fig. 8). Claim 15 explicitly requires a "wheel assembly." This consistent context may support an interpretation that a "cart" inherently implies features for wheeled mobility, which the Plaintiff's product allegedly lacks (Compl. ¶12).

VI. Other Allegations

• Frivolous Enforcement: While not a formal count, the complaint repeatedly alleges that the Defendant's enforcement action was "frivolous" (Compl. ¶7; ¶33). These allegations form the factual basis for the tortious interference and patent misuse claims, asserting that the Defendant knew or should have known that the Plaintiff's distinct "storage box" could not infringe a patent on a "folding & rolling cart" (Compl. ¶25).
• Patent Misuse and Antitrust Allegations: Count III alleges that the Defendant, by enforcing the '576 Patent beyond its legal scope, has leveraged its legal monopoly in the "folding & rolling cart market" in an attempt to illegally monopolize the separate "storage box market" in violation of the Sherman Act (Compl. ¶¶ 26-27).
• Tortious Interference Allegations: Count IV alleges that the Defendant knowingly and wrongfully interfered with the Plaintiff's business relationship with Amazon.com by filing a "frivolous complaint" of patent infringement, knowing that such a complaint would trigger the closure of Plaintiff's e-commerce stores (Compl. ¶¶ 31-35).

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

• A core issue will be one of product classification and claim scope: Can the claims for a "collapsible cart," which the patent specification and figures consistently illustrate with mobility features like wheels and a handle, be properly construed to cover the Plaintiff's product, which is described and depicted as a wheelless, handle-less "storage box"?
• A key evidentiary question will be one of structural correspondence: Independent of the "cart" definition, does the accused product contain the specific mechanical structures recited in the patent's independent claims—such as the multi-panel sidewalls, locking assemblies, and tracks—or their equivalents? The complaint's allegations and visual evidence suggest a significant structural mismatch.
• A third question, pivotal to the non-patent claims, will concern the Defendant's intent and conduct: Was the Defendant's enforcement of the '576 Patent on the Amazon platform an objectively baseless action, pursued with knowledge of non-infringement, that could potentially give rise to liability for patent misuse or tortious interference?