DCT
7:24-cv-10019
Yuhuanhongshengmaoyiyouxiangongsi v. Dbest Products Inc
I. Executive Summary and Procedural Information
- Case Name: Yuhuanhongshengmaoyiyouxiangongsi v. Dbest Products, Inc.
- Parties & Counsel:
- Plaintiff: Yuhuanhongshengmaoyiyouxiangongsi a/k/a Aocoom (P.R. China)
- Defendant: Dbest Products, Inc. (California)
- Plaintiff’s Counsel: Lance Liu, Esq.
- Case Identification: 1:24-cv-10019, S.D.N.Y., 01/02/2025
- Venue Allegations: Venue is based on Defendant’s business activities within the district, including sales of its products through local Lowe's and Home Depot stores.
- Core Dispute: Plaintiff seeks a declaratory judgment that its storage boxes do not infringe Defendant’s patent on stackable collapsible carts and that the patent is invalid, and further brings claims for patent misuse and tortious interference.
- Technical Context: The technology concerns collapsible containers, a mature product category where innovations often focus on folding mechanisms, durability, and portability features like wheels and handles.
- Key Procedural History: The complaint alleges that this action was precipitated by Defendant filing an infringement complaint against the Plaintiff on the Amazon platform on December 13, 2024, resulting in the lockdown of Plaintiff's e-commerce accounts. The Plaintiff identifies five prior art references it intends to use to challenge the patent's validity.
Case Timeline
| Date | Event |
|---|---|
| 2020-01-06 | Earliest Priority Date for '576 Patent |
| 2024-10-01 | U.S. Patent No. 12,103,576 Issued |
| 2024-12-13 | Defendant allegedly filed complaint against Plaintiff on Amazon platform |
| 2025-01-02 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,103,576 - "Stackable Collapsible Carts" (issued Oct. 1, 2024)
The Invention Explained
- Problem Addressed: The patent's background section notes that in prior art collapsible carts, the "sidewalls may not be sufficiently sturdy to allow for transporting heavy objects" ('576 Patent, col. 2:22-24).
- The Patented Solution: The invention is a collapsible cart designed for improved strength and functionality. It features a rigid frame with sidewalls that fold inward for compact storage ('576 Patent, col. 2:30-38). The patent describes specific sidewall constructions, such as a multi-panel design where panels are rotatably coupled, and a locking mechanism involving a slideable member that moves along a track to secure the panels in an open, rigid position ('576 Patent, col. 2:38-57). The design also contemplates features like a telescoping handle, wheels, and a top cover that can be used as a seat ('576 Patent, col. 8:16-24; col. 7:41-44).
- Technical Importance: The claimed combination of features aims to provide a product that is both easily collapsible for storage and sufficiently robust for carrying heavy loads when expanded.
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement on independent claims 1, 11, and 15, as well as their dependent claims (Compl. ¶¶ 17-19).
- Independent Claim 1: The essential elements include:
- A "collapsible cart"
- A rigid frame with four walls and a bottom, where the sidewalls fold inwardly
- A right sidewall comprising a "first right panel rotatably coupled to a second right panel"
- The second right panel is proportioned to fit within an opening in the first
- A "first track" formed along both panels
- A "first slideable member" that moves along the track to "selectively lock" the panels together
- Independent Claim 11: The essential elements include:
- A "cart"
- A rigid frame with inwardly folding sidewalls
- A right sidewall comprising a "first right panel rotatably coupled to a second right panel"
- The right sidewall also includes a "third right panel," where the second and third panels "collectively cover the opening in the first right panel"
- The second right panel has a "ribbed wall"
- A "first lock assembly" to lock the first and second right panels
Multi-Patent Capsule
- Patent Identification: U.S. Patent No. 12,103,576, "Stackable Collapsible Carts," issued Oct. 1, 2024.
- Technology Synopsis: Claim 15 is directed to a "stackable collapsible cart." It claims a specific structure including a rigid frame, multi-panel sidewalls, a lock assembly, and a "wheel assembly." It also requires a rigid top cover with an "indentation pattern" that is "configured to receive a wheel assembly from another identical collapsible cart when stacked vertically," enabling stable stacking. ('576 Patent, col. 13:28 - col. 14:18).
- Asserted Claims: Independent Claim 15 and dependent claims 16-18 (Compl. ¶17).
- Accused Features: Plaintiff alleges its storage box does not infringe Claim 15, stating that the product is not a "stackable collapsible cart" and lacks, among other elements, the claimed sidewall configuration, lock assembly, wheel assembly, and specific top cover with an indentation pattern for stacking (Compl. ¶11).
III. The Accused Instrumentality
- Product Identification: Plaintiff's "storage box" (Compl. ¶9).
- Functionality and Market Context: The complaint describes the accused instrumentality as a "storage box" and explicitly contrasts it with the "folding & rolling cart" it alleges is covered by the '576 Patent (Compl. ¶12). A side-by-side visual comparison provided in the complaint depicts the Plaintiff's product as a collapsible container without visible wheels or a telescoping handle, features shown in the patent's drawings (Compl. ¶12). The Plaintiff sells these storage boxes to U.S. consumers through Amazon.com (Compl. ¶1).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement, presenting its arguments in a tabular format. The analysis below summarizes the Plaintiff’s position.
'576 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A collapsible cart configured to transition from a closed condition where it is folded up to an open condition where it is expanded for use... | Plaintiff alleges its product is a "storage box," not a "collapsible cart," suggesting a categorical difference based on the absence of mobility features. | ¶9, #1 | col. 2:30-33 |
| a rigid frame forming a compartment... | Plaintiff concedes this element is present on its storage box. | ¶9, #2 | col. 6:13-17 |
| the right sidewall and the left sidewall are configured to fold inwardly in the closed condition; | Plaintiff alleges this element is not present on its storage box. | ¶9, #3 | col. 2:36-38 |
| the right sidewall comprising a first right panel rotatably coupled to a second right panel; | Plaintiff alleges this element is not present on its storage box. | ¶9, #4 | col. 2:38-40 |
| the second right panel proportioned to fit within an opening in the first right panel; | Plaintiff alleges this element is not present on its storage box. | ¶9, #5 | col. 2:40-42 |
| a first track formed along the first right panel and the second right panel... | Plaintiff alleges this element is not present on its storage box. | ¶9, #6 | col. 2:42-47 |
| a first slideable member cooperatively engaged to the first track, the first slideable member is movable... to selectively lock the first right panel to the second right panel... | Plaintiff alleges this element and its associated locking function are not present on its storage box. | ¶9, #8-10 | col. 2:47-57 |
- Identified Points of Contention:
- The complaint presents a side-by-side comparison of the patented cart from Figure 8 of the '576 Patent and a photograph of the Plaintiff's storage box to highlight their differences (Compl. ¶12). This visual evidence is central to the Plaintiff’s argument that its product is fundamentally different from what is claimed.
- Scope Questions: The primary dispute appears to be definitional. A court will need to determine if the term "collapsible cart" as used in the patent requires features of mobility (like wheels or a handle), or if it can be construed more broadly to read on any collapsible container with the claimed wall structure. The complaint argues for the former, positioning its product as a stationary "storage box" outside the patent's scope (Compl. ¶12).
- Technical Questions: Beyond the "cart" vs. "box" issue, the complaint raises factual questions about the mechanical structure of the accused product. Plaintiff flatly denies the presence of the claimed multi-panel sidewalls, the "track," and the "slideable member" locking mechanism (Compl. ¶9). A key evidentiary question will be whether any feature on the Plaintiff's product performs the function of the claimed "track" and "slideable member," even if structurally different.
V. Key Claim Terms for Construction
- The Term: "collapsible cart" / "cart" (from Claims 1, 11, and 15)
- Context and Importance: The distinction between a "cart" and a "storage box" is the foundation of the Plaintiff's non-infringement argument (Compl. ¶12). Practitioners may focus on this term because if the accused product is determined not to be a "cart" as a threshold matter, the infringement analysis for many claims could end there. The construction will determine whether mobility is an inherent requirement of the claimed invention.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The body of Claim 1 does not explicitly recite wheels or a handle, defining the "collapsible cart" primarily by its frame and folding wall structure. Defendant may argue that the term "cart" is a general descriptor and the patentability resides in the specific, claimed collapsible structure, which could be applied to containers with or without wheels.
- Evidence for a Narrower Interpretation: The patent's title is "Stackable Collapsible Carts." The specification repeatedly refers to features associated with transport, such as "transporting heavy objects" ('576 Patent, col. 2:24), a "retractable handle" (col. 8:16-17), and "rotatable swivel wheels" (col. 7:41-42). Dependent claim 10 explicitly adds a "wheel assembly," and independent claim 15 requires both a "wheel assembly" and features for stacking with other wheeled carts. Plaintiff may argue these references establish a context in which a "cart" is understood to be a mobile device.
VI. Other Allegations
- Indirect Infringement: The complaint states that the accused storage boxes do not infringe under the doctrine of equivalents because the doctrine must be applied to each individual element, many of which are alleged to be entirely missing (Compl. ¶18).
- Willful Infringement: While not a claim made by the Plaintiff, the complaint's allegations of "frivolous" and "baseless" enforcement of the patent against it on the Amazon platform form the basis for its claims of patent misuse and tortious interference (Compl. ¶¶ 25, 33). These allegations suggest Plaintiff believes Defendant knew or should have known that the Plaintiff's product did not infringe, which is the inverse of a typical willfulness allegation.
VII. Analyst’s Conclusion: Key Questions for the Case
Definitional Scope: The central issue is one of claim construction. Can the term "collapsible cart," used throughout a patent that repeatedly describes wheels and handles, be construed to cover a stationary "storage box" that allegedly lacks any features for transport? The answer will define the ultimate scope of the patent.
Factual and Technical Mismatch: If the accused product is found to be a "cart," a key evidentiary question will be whether its folding and locking mechanisms are structurally or functionally equivalent to the specific multi-panel, track-and-slider system required by the independent claims. The complaint's categorical denial of these elements suggests a significant structural divergence that the court will need to resolve.
Bad Faith Enforcement: A parallel question, central to the antitrust and tortious interference claims, is whether Defendant's assertion of the '576 Patent against Plaintiff's product on the Amazon platform was objectively baseless. This inquiry will depend heavily on the outcomes of the claim construction and infringement analyses.