DCT

2:25-cv-00370

Henan Yiqi Technology Co Ltd v. Dbest Products Inc

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00370, W.D. Wash., 05/22/2025
  • Venue Allegations: Plaintiffs allege venue is proper because a substantial part of the events giving rise to the action, namely Defendant's patent enforcement actions directed at Amazon.com, Inc., took place within the district.
  • Core Dispute: Plaintiffs seek a declaratory judgment that their "Storage Bins" do not infringe Defendant's patent related to stackable collapsible carts and/or that the patent is invalid.
  • Technical Context: The technology concerns collapsible carts or bins, a consumer product category focused on balancing portability and storage with structural integrity when in use.
  • Key Procedural History: This action was prompted by Defendant submitting patent infringement complaints to Amazon.com, which resulted in the removal of Plaintiffs' product listings from the online marketplace. Plaintiffs assert this "extra-judicial patent enforcement" created a justiciable controversy and forms the basis for personal jurisdiction in the forum.

Case Timeline

Date Event
2020-01-06 ’576 Patent - Earliest Priority Date
2024-10-01 ’576 Patent - Issue Date
2024-12-07 Plaintiffs receive notice from Amazon regarding product removal
2025-05-22 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 (’576 Patent)

  • The Invention Explained:
    • Problem Addressed: The patent's background section notes that due to their collapsible nature, the sidewalls of prior art carts "may not be sufficiently sturdy to allow for transporting heavy objects" (’576 Patent, col. 1:21-23).
    • The Patented Solution: The invention is a collapsible cart with a rigid frame and sidewalls designed to fold inward for storage (’576 Patent, Abstract). To enhance sturdiness in the open position, the patent discloses a specific mechanical locking mechanism where multi-panel sidewalls are secured by a "slideable member" that moves along a "track" spanning the panels, locking them together (’576 Patent, col. 1:41-58; FIG. 42B). This design aims to provide a rigid structure when expanded while still allowing the cart to be collapsed.
    • Technical Importance: The invention addresses a fundamental trade-off in the design of collapsible containers between portability when folded and structural strength when in use.
  • Key Claims at a Glance:
    • The complaint asserts non-infringement of independent claims 1, 11, and 15 (Compl. ¶20).
    • Independent Claim 1:
      • A collapsible cart configured to transition between a closed and open condition.
      • A rigid frame with walls, where the sidewalls fold inwardly.
      • A 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 cooperatively engaged to the first track, movable between an open and closed position to selectively lock the first right panel to the second right panel.
    • Independent Claim 11:
      • A cart with a rigid frame and inwardly folding sidewalls.
      • A right sidewall comprising a first right panel rotatably coupled to a second right panel, and further comprising a third right panel.
      • The second and third right panels conform to collectively cover an opening in the first right panel, with the second panel having a ribbed wall.
      • A first lock assembly integrated with the first and second right panels, having conditions for locking and unlocking the panels.
    • Independent Claim 15:
      • A stackable collapsible cart with a rigid frame and inwardly folding sidewalls.
      • A first lock assembly integrated with the first and second right panels.
      • A wheel assembly coupled to the bottom wall.
      • A rigid top cover with an indentation pattern aligned with the wheel assembly's vertical axis to receive a wheel assembly from another cart when stacked.
    • The complaint notes that dependent claims 2-10 are not infringed because independent claim 1 is not infringed (Compl. ¶27).

III. The Accused Instrumentality

  • Product Identification: Plaintiffs' "Storage Bins" sold on Amazon.com under various ASINs, including B0C6Q4LWVZ and B0BZYP5LQT (Compl. ¶11, ¶12, ¶15).
  • Functionality and Market Context:
    • The accused products are collapsible storage bins with side doors or panels that allow access to the contents (Compl. ¶25).
    • The complaint alleges that the locking mechanism for the side doors on the accused Storage Bins is "entirely based on magnetic attraction" (Compl. ¶25). Specifically, each side door is equipped with a magnetic object that pairs with a matching magnet on the bin frame to secure the door (Compl. ¶25).
    • The complaint alleges that the Amazon marketplace is Plaintiffs' "primary sales channel into the United States" and the delisting has caused "immediate and irreparable harm" (Compl. ¶14, ¶24).

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. Its central argument is that the accused Storage Bins lack the specific mechanical locking mechanism recited in the asserted claims (Compl. ¶24). The complaint provides a comparative chart contrasting patent figures with product photos to illustrate this alleged difference (Compl. p. 8, Chart 1). This chart shows the patent's "slideable member" and "track" assembly alongside photos of the accused product, which uses "magnets" and "magnetic object[s]" for closure (Compl. p. 8, Chart 1).

’576 Patent Infringement Allegations (as framed by Plaintiffs' non-infringement contentions for Claim 1)

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a first track formed along the first right panel and the second right panel... The complaint alleges the accused product lacks this element, instead using discrete magnets on the frame and door panel. ¶25 col. 9:19-22
a first slideable member cooperatively engaged to the first track, the first slideable member is 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 complaint alleges the accused product lacks a "sliding locking mechanism," and instead secures its side doors via magnetic attraction between a magnetic object and a matching magnet. ¶24-26 col. 9:22-34
  • Identified Points of Contention:
    • Scope Questions: A central dispute will be whether the term "lock assembly integrated with the first right panel and the second right panel" (Claim 11) can be construed to read on a closure mechanism based on magnetic attraction. Similarly, the litigation will question if the accused product's magnetic closure meets the limitations of a "track" and a "slideable member" (Claim 1) under any proposed construction.
    • Technical Questions: The complaint frames the dispute as a fundamental difference in the way the locking function is performed, arguing the mechanisms are "completely different" (Compl. ¶26). A key question for the court will be whether the accused product's use of magnetic attraction is technically equivalent to the patented mechanical sliding lock, considering the function performed, the way it is performed, and the result achieved.

V. Key Claim Terms for Construction

  • The Term: "a first slideable member cooperatively engaged to the first track" (Claim 1)

  • Context and Importance: This term is at the core of the non-infringement argument. Plaintiffs contend their magnetic closure system does not contain a "slideable member" or a "track" as described in the patent (Compl. ¶25). The patentee’s ability to prove infringement will depend on construing this term broadly enough to encompass the accused magnetic system.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: A patentee might argue that the term should be interpreted functionally to cover any member that moves or slides into a locked position, regardless of the specific structure. The specification uses general language like "selectively secure or lock the first right panel" (’576 Patent, col. 7:8-10).
    • Evidence for a Narrower Interpretation: The patent specification and figures appear to disclose a specific mechanical structure. Figure 42B, for example, shows a physical member (58) designed to hook around a peg (42B) by sliding along a physical track (46) (’576 Patent, col. 9:22-34). The complaint explicitly contrasts this mechanical structure with its magnetic one (Compl. p. 8, Chart 1).

  • The Term: "a first lock assembly integrated with the first right panel and the second right panel" (Claims 11, 15)

  • Context and Importance: This term is slightly broader than the "slideable member" limitation but is also central to the dispute. Practitioners may focus on whether discrete magnets embedded in the panels can be considered an "integrated" "lock assembly" in the context of the patent.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patentee could argue that "lock assembly" is a generic term for any components that work together to secure the panels, and "integrated" simply means built into the panels rather than being a separate part like a latch.
    • Evidence for a Narrower Interpretation: The specification consistently describes the "lock assembly" in the context of the slideable member and track mechanism (e.g., ’576 Patent, col. 9:15-18, describing "first lock assembly 42A comprising a first slideable member 58"). This suggests that the term "lock assembly" as used in the patent refers to this specific mechanical configuration, not any locking means in general.

VI. Other Allegations

  • Indirect Infringement: The complaint seeks a declaratory judgment of non-infringement for both direct and indirect infringement but does not present specific factual allegations beyond the assertion that there can be no indirect infringement without underlying direct infringement (Compl. ¶16, ¶24).
  • Willful Infringement: Willfulness is not alleged by the patentee in this complaint. However, the declaratory judgment Plaintiffs allege that Defendant's infringement reports to Amazon were "objectively baseless" and seek a finding that the case is "exceptional" to recover attorney fees and enhanced damages (Compl. ¶1, ¶29; Prayer for Relief ¶F, G).

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

This case appears to center on a classic patent dispute involving claim scope and the doctrine of equivalents. The outcome will likely depend on the court's resolution of two key questions:

  • Definitional Scope: Can the mechanical terms used in the ’576 Patent's claims—such as "slideable member," "track," and "lock assembly integrated with"—be construed broadly enough to read on the accused product's magnetic closure system?
  • Technical Equivalence: If not literally infringed, does the accused product's use of magnetic attraction perform substantially the same function (securing the panels), in substantially the same way, to achieve substantially the same result (a stable, open cart) as the patented sliding mechanical lock, or does it represent a "completely different" technical approach as alleged by the Plaintiffs?