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 (P.R. 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 Defendant conducting business within the district through sales at retail stores and committing alleged wrongful acts that caused harm to the Plaintiff in the district.
• Core Dispute: Plaintiff seeks a declaratory judgment that its storage boxes do not infringe Defendant's patent on collapsible carts and that the patent is invalid, and further alleges patent misuse and tortious interference by Defendant.
• Technical Context: The technology relates to the field of portable, collapsible containers, a market segment that values both storage capacity and compact, convenient transport when not in use.
• Key Procedural History: This declaratory judgment action was filed after the Defendant, Dbest Products, Inc., allegedly filed a complaint with Amazon.com asserting the patent-in-suit against the Plaintiff. This action allegedly resulted in the lockdown of Plaintiff’s Amazon sales accounts, which forms the basis for the tortious interference and patent misuse claims.

Case Timeline

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's background section notes that prior art collapsible carts often have sidewalls that are not "sufficiently sturdy to allow for transporting heavy objects." (’576 Patent, col. 1:21-24).
• The Patented Solution: The invention is a collapsible cart designed for improved sturdiness and functionality. It features a rigid frame with sidewalls that fold inward for storage. Key embodiments describe multi-panel sidewalls, where a first panel is rotatably coupled to a second panel, and a "slideable member" moves along a track to lock the panels together in the open position, providing structural reinforcement. (’576 Patent, Abstract; col. 2:30-58). Figure 8, for example, illustrates a wheeled cart with multi-part sidewalls in a partially collapsed state. (’576 Patent, Fig. 8).
• Technical Importance: The design aims to provide the convenience of a collapsible container with the rigidity and load-bearing capacity more typical of a non-collapsible one. (’576 Patent, col. 1:21-24).

Key Claims at a Glance

• The complaint seeks a declaratory judgment of non-infringement as to independent claims 1, 11, and 15. (Compl. ¶17).
• Independent Claim 1: A "collapsible cart" comprising:
  • A rigid frame with a front wall, rear wall, right sidewall, left sidewall, and bottom wall, 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" extending along the first and second right panels.
  • A "first slideable member" that engages the track and is movable to lock the first right panel to the second right panel.
• Independent Claim 15: A "stackable collapsible cart" comprising:
  • A rigid frame with inwardly folding sidewalls and a rotatably coupled two-panel right sidewall.
  • A "first lock assembly" to secure the panels.
  • A "wheel assembly" coupled to the bottom wall.
  • A "rigid top cover" with an "indentation pattern" configured to receive a wheel assembly from another identical cart when stacked.
• The complaint notes that claims 2-10, 12-14, and 16-18 are dependent on these independent claims. (Compl. ¶8).

III. The Accused Instrumentality

Product Identification

• Plaintiff’s "storage boxes" sold on Amazon.com. (Compl. ¶1).

Functionality and Market Context

• The complaint describes the accused product primarily by distinguishing it from the patented invention. It is characterized as a "storage box" rather than a "cart." (Compl. ¶9). The Plaintiff alleges that its product does not have key features of the patented invention, such as the ability to transition from a closed to an open condition, inwardly folding sidewalls, or multi-panel walls with locking mechanisms. (Compl. ¶¶9, 11). A side-by-side visual comparison in the complaint contrasts a patent figure of a rolling cart with a photograph of the Plaintiff's product, which appears as a simple, open-top container with two hinged side doors. (Compl. ¶12). The complaint alleges that Defendant is attempting to improperly control the "storage box market" despite its patent being directed to the "folding & rolling cart market." (Compl. ¶7).

IV. Analysis of Infringement Allegations

’576 Patent Infringement Allegations (Claim 1)

Identified Points of Contention

• Scope Questions: The central dispute appears to be definitional: does the term "collapsible cart," as used in the patent, read on the Plaintiff's product, which it characterizes as a "storage box"? The complaint's visual comparison highlights this alleged categorical difference, contrasting the patent's wheeled cart with the Plaintiff's simpler container. (Compl. ¶12).
• Technical Questions: A key factual question will be whether the accused product contains the specific mechanical structures recited in the claims. The complaint alleges a complete absence of the claimed multi-panel sidewalls, the "track," and the "slideable member" locking mechanism. The court will have to determine if any feature of the accused product performs the functions of these claimed elements, either literally or under the doctrine of equivalents.

V. Key Claim Terms for Construction

The Term: "collapsible cart"

• Context and Importance: The construction of this term appears dispositive. Plaintiff's entire non-infringement case is premised on its product being a "storage box," not a "cart." Practitioners may focus on this term because if the accused product is found not to be a "collapsible cart," infringement of any claim may fail at the first limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not appear to provide an explicit definition of "cart." A party could argue that any portable, collapsible container for carrying objects falls within the plain and ordinary meaning of the term. Claim 1 does not explicitly require wheels or a handle.
  • Evidence for a Narrower Interpretation: The patent's title is "Stackable Collapsible Carts." (’576 Patent, Title). The abstract, summary, and nearly all figures depict an object with wheels and often a telescoping handle, features commonly associated with a "cart" that is rolled. (’576 Patent, Abstract; Figs. 1-18). Independent claim 15 explicitly recites a "wheel assembly." (’576 Patent, col. 14:4-6). This consistent depiction and specific inclusion of wheels in other claims may support an interpretation that a "cart" requires features for rolling.

The Term: "first slideable member"

• Context and Importance: Plaintiff's non-infringement case relies heavily on the absence of this specific locking mechanism. Practitioners may focus on this term because it is a detailed mechanical limitation that may not be present in a simpler container.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term itself is generic. A party might argue that any piece that moves relative to another to create a lock constitutes a "slideable member," even if it does not move along a defined, separate "track" structure.
  • Evidence for a Narrower Interpretation: The specification describes this element in detail, showing a distinct member (58) that is "cooperatively engage[d]" with and "movable along" a "first track" (46) to "selectively secure or lock the first right panel 26 to the second right panel 28." (’576 Patent, col. 7:4-10). This specific structural relationship could be used to argue for a narrower construction that excludes other types of latches or locks.

VI. Other Allegations

Indirect Infringement

• The complaint does not provide sufficient detail for analysis of potential indirect infringement theories.

Willful Infringement

• Willfulness is not alleged by the patent holder in this declaratory judgment complaint. However, the Plaintiff (the accused infringer) alleges that the Defendant's assertion of the patent was "frivolous" and was made with knowledge that Plaintiff was not infringing. (Compl. ¶¶7, 33). These allegations form the basis for Plaintiff's claims of patent misuse and tortious interference, which are the inverse of a typical willfulness claim. (Compl. Counts III, IV).

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

• A core issue will be one of definitional scope: can the term "collapsible cart," which is consistently depicted in the patent with wheels and handles for rolling, be construed to cover a product that the Plaintiff identifies as a simple "storage box"? The outcome of this claim construction may be determinative.
• A second key question will be one of technical presence: does the accused storage box contain the specific mechanical structures recited in the patent's independent claims, such as the multi-panel, inwardly-folding sidewalls and the "slideable member" on a "track" locking mechanism? The complaint alleges a complete absence of these features.
• Finally, the case presents a significant question of enforcement conduct: did the patent holder's act of filing an infringement complaint with Amazon constitute an improper attempt to leverage its patent on "carts" to monopolize the separate market for "storage boxes," thereby constituting patent misuse or tortious interference?