Shenzhen Yihong Technology Co Ltd v. Dbest Products Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhen Yihong Technology Co., Ltd. d/b/a Vtopmart Direct (People's Republic of China)
  • Defendant: dbest products, Inc. (California)
  • Plaintiff’s Counsel: Carl J. Marquardt; Glacier Law LLP
• Case Identification: 2:24-cv-02043, W.D. Wash., 12/11/2024
• Venue Allegations: Venue is asserted based on the Defendant's "extra-judicial patent enforcement" efforts directed at Amazon.com, Inc., which has a place of business within the district, constituting a substantial part of the events giving rise to the action.
• Core Dispute: Plaintiff seeks a declaratory judgment that its "Stackable Storage Drawers" do not infringe Defendant’s patent on "Stackable Collapsible Carts," and further seeks a declaration that the patent-in-suit is invalid.
• Technical Context: The technology concerns the field of portable storage containers, centering on the structural differences between collapsible, folding carts and rigid, stackable drawers.
• Key Procedural History: This declaratory judgment action was initiated by the accused infringer (Plaintiff) after the patent holder (Defendant) filed an infringement complaint with Amazon.com, resulting in the removal of Plaintiff's product listings. The complaint also includes several prior art references intended 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 Issues
2024-12-06	Plaintiff receives notice from Amazon.com of product removal due to infringement complaint
2024-12-11	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 background notes that in prior art collapsible carts, "the sidewalls may not be sufficiently sturdy to allow for transporting heavy objects" ('576 Patent, col. 1:22-24).
• The Patented Solution: The invention is a collapsible cart designed to transition between a folded (closed) condition and an expanded (open) condition for use. The core mechanism involves sidewalls that are "configured to fold inwardly" ('576 Patent, Abstract). To achieve this, a sidewall is comprised of at least two separate panels rotatably coupled together, allowing the structure to collapse for storage and be locked into an open position for use ('576 Patent, col. 6:9-22).
• Technical Importance: The design purports to provide a solution to the long-standing challenge of creating a collapsible storage cart that is also structurally robust when assembled.

Key Claims at a Glance

• The complaint asserts non-infringement of independent claims 1, 11, and 15 (Compl. ¶18).
• Independent Claim 1 recites the following key elements:
  • 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.
  • A rigid frame with front, rear, right, left, and bottom walls, where the right and left sidewalls are configured to fold inwardly.
  • The right sidewall comprises 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 right panel."
  • A "first track" is formed along the first and second right panels.
  • A "first slideable member" engages the track to selectively lock the panels together.
• The complaint reserves the right to seek a declaration of non-infringement of all claims, including the 15 dependent claims (Compl. ¶30, 32).

III. The Accused Instrumentality

Product Identification

• The "Stackable Storage Drawers" sold by Plaintiff Vtopmart Direct on Amazon.com (Compl. ¶1, 20).

Functionality and Market Context

• The complaint describes the accused products as fundamentally different from the patented invention. They are characterized as "a traditional external enclosure paired with a sliding drawer" (Compl. ¶19).
• The products are constructed from "entirely of rigid plastic structures, lacking any elasticity, flexibility, or pivoting mechanisms necessary to achieve the collapsible functionality" (Compl. ¶19). The open and closed states are achieved by a drawer sliding within a fixed, non-collapsible enclosure (Compl. ¶22).
• The complaint alleges that the Amazon marketplace is the Plaintiff's "primary sales channel into the United States," making the delisting of its products a source of "immediate and irreparable harm" (Compl. ¶12, 14).

IV. Analysis of Infringement Allegations

This declaratory judgment action argues for non-infringement. The Plaintiff’s core theory is that its rigid drawer products are structurally and functionally distinct from the claimed collapsible cart.

To illustrate this alleged distinction, the complaint provides a side-by-side visual comparison of the patented invention and the accused product (Compl. ¶19).

'576 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Non-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...	The accused product is a rigid, non-collapsible storage drawer with a sliding mechanism, not a folding cart. It is described as lacking "collapsible functionality."	¶19	col. 11:41-44
...the right sidewall and the left sidewall are configured to fold inwardly in the closed condition...	The accused product's sidewalls are described as "entirely rigid" and are not designed to fold inward.	¶20, 24	col. 11:48-50
...the right sidewall comprising a first right panel rotatably coupled to a second right panel...	The accused product's sidewall is alleged to be "a single, integral piece" that does not include multiple, rotatably coupled panels.	¶21	col. 11:51-52
...a first track formed along the first right panel and the second right panel...	The complaint alleges the accused product does not include or form the claimed "first track" structure.	¶21	col. 11:56-59

Identified Points of Contention

• Scope Questions: The central dispute raises a definitional question: Does the term "collapsible cart," as defined and described in the '576 Patent, read on a rigid, non-folding stackable drawer that uses a sliding mechanism rather than folding panels? The complaint argues it does not (Compl. ¶19, 23).
• Technical Questions: A key factual question will be whether the accused product's "single, integral piece" sidewall (Compl. ¶21) possesses any structure that could be argued to meet, either literally or under the doctrine of equivalents, the claim limitation of a "first right panel rotatably coupled to a second right panel" ('576 Patent, cl. 1). The complaint's visuals, such as the photo of the accused product showing a simple drawer in an enclosure, suggest a significant structural and operational difference (Compl. p. 5).

V. Key Claim Terms for Construction

The Term: "collapsible cart"

• Context and Importance: This term is foundational to the dispute. Plaintiff’s entire non-infringement case rests on its product being a rigid "stackable storage drawer" and not a "collapsible cart" (Compl. ¶19). The construction of this term may be dispositive.
• Intrinsic Evidence for a Broader Interpretation: The Defendant (patentee) may argue the term should be read broadly to encompass various forms of portable storage. The patent title itself is "Stackable Collapsible Carts", suggesting a focus on storage utility.
• Intrinsic Evidence for a Narrower Interpretation: The Plaintiff will likely argue the patent repeatedly defines the term by its function. Claim 1 itself requires the cart be "configured to transition from a closed condition where it is folded up" and that its sidewalls "are configured to fold inwardly" ('576 Patent, col. 11:41-50). The abstract, summary, and figures all consistently describe and depict a folding, collapsing structure ('576 Patent, Abstract; col. 2:30-37; FIG. 8).

The Term: "first right panel rotatably coupled to a second right panel"

• Context and Importance: This term describes a specific structural mechanism for achieving collapsibility. Plaintiff alleges its product, having a "single, integral" sidewall, completely lacks this feature (Compl. ¶21).
• Intrinsic Evidence for a Broader Interpretation: A patentee might argue for a broad reading of "coupled," but the complaint's description of the accused product as a single piece of plastic presents a high bar for such an argument.
• Intrinsic Evidence for a Narrower Interpretation: The specification provides clear, narrow support for this term, describing two distinct panels connected by a hinge. The detailed description states, "The first right panel 26 may be coupled with a first hinge 27 to the second right panel 28 along a first vertical axis 30" ('576 Patent, col. 6:35-38). This language suggests a specific mechanical arrangement that Plaintiff alleges is absent from its product.

VI. Other Allegations

Indirect Infringement

• The complaint seeks a declaratory judgment of non-infringement both directly and indirectly (Compl. ¶32). However, it does not set forth a specific theory of indirect infringement that it is seeking to refute.

Willful Infringement

• As a declaratory judgment action, the complaint does not allege willful infringement by the Plaintiff. Instead, it alleges bad-faith conduct by the Defendant (patentee), asserting that its infringement reports to Amazon were "objectively baseless" and "materially false" (Compl. ¶7, 50). These allegations form the basis for the Plaintiff's state-law claims and its request for a finding that the case is "exceptional" under 35 U.S.C. § 285, which would permit an award of attorney's fees (Compl. Prayer for Relief ¶F).

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

The resolution of this case appears to hinge on two primary questions for the court:

• A core issue will be one of definitional scope: can the term "collapsible cart", rooted in the patent’s consistent description of a folding structure with hinged panels, be construed to cover the Plaintiff’s rigid, non-folding storage unit that operates with a sliding drawer?
• A key evidentiary question will be one of structural mismatch: does the accused product's single-piece, integral sidewall contain any component or feature that meets the specific claim limitation of a "first right panel rotatably coupled to a second right panel", either literally or under the doctrine of equivalents?