Sichuan Chaohaowan Wenhuachuangyi Co Ltd v. Dbest Products Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Sichuan Chaohaowan Wenhuachuangyi Co., Ltd. (China)
  • Defendant: dbest products, Inc. (California)
  • Plaintiff's Counsel: LawMay P.C.
• Case Identification: 2:26-cv-03255, C.D. Cal., 03/26/2026
• Venue Allegations: Venue is alleged to be proper in the Central District of California because the defendant, dbest products, Inc., is a California corporation with its principal place of business in Carson, California, which is within the district.
• Core Dispute: Plaintiff seeks a declaratory judgment that its storage box products do not infringe Defendant's patents, and further that the asserted patents are invalid and unenforceable due to the alleged introduction of new matter during prosecution and failure to disclose material prior art.
• Technical Context: The technology at issue involves collapsible and stackable storage boxes, a product category common in consumer goods and organizational solutions.
• Key Procedural History: The complaint alleges that this dispute arose from patent infringement claims Defendant asserted against Plaintiff's products on the Amazon marketplace, which resulted in the removal of Plaintiff's product listings. Plaintiff alleges that Defendant improperly amended its patent applications to cover features of pre-existing products sold by Plaintiff's supplier, HAIXIN, and failed to disclose HAIXIN's prior commercial sales to the U.S. Patent and Trademark Office, forming the basis for its invalidity and inequitable conduct claims.

Case Timeline

Date	Event
2020-01-06	Earliest Priority Date for '546 and '446 Patents
2021-12-03	HAIXIN Chinese Patent (CN214987334) Publication Date
2022-01-01	Alleged first commercial sales of HAIXIN products on Amazon (at least as early as 2022)
2023-03-01	Defendant files provisional applications allegedly including new matter (at least as early as March 2023)
2025-04-15	U.S. Patent No. 12,275,446 Issues
2025-05-20	U.S. Patent No. 12,304,546 Issues
2025-11-07	Amazon removes Plaintiff's product listings based on Defendant's complaint
2025-11-14	Amazon removes additional Plaintiff product listings
2026-03-26	Complaint for Declaratory Judgment Filed

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

U.S. Patent No. 12,304,546 - "Collapsible Carts," Issued May 20, 2025 ('546 Patent)

The Invention Explained

• Problem Addressed: While not explicitly stated as a problem, the patent's background describes the well-established field of collapsible and stackable carts, implying a need for improvements in their design and functionality '546 Patent, col. 1:40 - col. 2:29
• The Patented Solution: The patent describes a collapsible cart or storage box with a frame of at least five walls, where at least three walls are designed to fold inwardly for compact storage '546 Patent, claim 1 A central feature is the construction of at least one of these folding walls from two separate panels-a first and second panel-that are rotatably coupled. These panels include corresponding "latch parts" or "fastener members" on their edges that mate to secure the panels together in a flat, common plane when the box is assembled for use '546 Patent, abstract '546 Patent, claim 9 Figures 35-41 of the patent illustrate the assembly process, showing walls folding up from a base and side-access doors opening '546 Patent, Figs. 35-41
• Technical Importance: The design aims to provide a storage container that can be conveniently collapsed but forms a structurally sound unit when assembled, with specific mechanisms for securing the multi-panel walls.

Key Claims at a Glance

• The complaint identifies independent claims 1, 9, and 17 for its invalidity arguments and specifically targets claim 9 for its non-infringement argument Compl. ¶29 Compl. ¶43
• Independent Claim 9 Elements:
  • A collapsible cart configured to transition from a closed to an open condition.
  • A frame with at least five walls, with at least three configured to fold inwardly.
  • A "third wall" comprising a first panel and a second panel rotatably coupled to the first.
  • A "fastener" to selectively secure the first and second panels in a "substantially coplanar alignment."
  • The fastener includes a first fastener member on the edge of the first panel and a second fastener member on the edge of the second panel.
  • The fastener members are configured to mate to hold the panels in alignment, and when disengaged, allow the second panel to rotate relative to the first.

U.S. Patent No. 12,275,446 - "High Load Capacity Collapsible Carts," Issued April 15, 2025 ('446 Patent)

The Invention Explained

• Problem Addressed: The patent specification states that prior art collapsible carts "may not be sufficiently sturdy to allow for transporting heavy objects" '446 Patent, col. 1:13-16
• The Patented Solution: The invention is a collapsible cart with features intended to increase its structural rigidity when assembled. The solution involves sidewalls constructed from two rotatably joined panels, similar to the '546 Patent. To enhance sturdiness, the design includes a "first track" that extends across both panels and a "first slideable member" that moves along this track. By sliding this member from an open position to a closed position, a user can lock the two panels together, reinforcing the sidewall '446 Patent, abstract '446 Patent, col. 2:21-44
• Technical Importance: This slidable locking mechanism is presented as a way to overcome the structural weakness often associated with collapsible containers, making them suitable for higher-load applications.

Key Claims at a Glance

• The complaint asserts that independent claim 22 is invalid and not infringed Compl. ¶48 Compl. ¶54
• Independent Claim 22 Elements:
  • A collapsible cart configured to transition from a closed to an open condition.
  • A frame with at least five walls, including a first, second, third, fourth, and fifth wall.
  • "at least three of the walls are configured to fold inwardly toward the fifth wall" in the closed condition.
  • The "third wall" comprises a first panel and a second panel, with the second rotatably coupled to the first.
  • A "first fastener" selectively secures the panels in an open condition, operating between a "first state for securing" and a "second state for releasing" the panels.
  • The fastener is integrated with the panels in both closed and open conditions.

III. The Accused Instrumentality

Product Identification

Plaintiff's "Seller's Products" are a line of storage boxes sold on Amazon.com, identified in the complaint by a list of Amazon Standard Identification Numbers (ASINs) Compl. ¶9

Functionality and Market Context

The products are collapsible and stackable storage boxes Compl. p. 4 The complaint includes photographs of the accused storage boxes, depicting their appearance both individually and when stacked Compl. p. 4 Plaintiff alleges these are "top-selling ASINs," indicating they are commercially significant products whose removal from the Amazon platform has caused substantial harm Compl. ¶24 The core of the non-infringement argument is based on the products' alleged operation: their walls are described as rigid, planar structures that "rotate" into place rather than "fold" Compl. ¶43

IV. Analysis of Infringement Allegations

The plaintiff seeks a declaratory judgment of non-infringement. The following charts summarize the plaintiff's primary arguments for why its products do not meet specific limitations of the asserted claims.

'546 Patent Infringement Allegations

Claim Element (from Independent Claim 9)	Alleged Non-Infringing Functionality	Complaint Citation	Patent Citation
at least three of the walls are configured to fold inwardly	The complaint alleges the walls of the Seller's Products do not "fold inwardly." It contends the walls are rigid panels that "retain their generally planar shape" and "rotate comparatively to one another," which is distinct from the common definition of "fold" as laying one part of something over another.	¶43	col. 2:25-27

'446 Patent Infringement Allegations

Claim Element (from Independent Claim 22)	Alleged Non-Infringing Functionality	Complaint Citation	Patent Citation
at least three of the walls are configured to fold inwardly toward the fifth wall when the cart is in the closed condition	The complaint makes an identical argument as for the '546 Patent, stating the product walls rotate but do not "fold inwardly" as required by the claim. It alleges the walls do not have a part that "lays or doubles over another part of the same wall."	¶54	col. 2:24-26

Identified Points of Contention

• Scope Questions: The primary dispute appears to be one of claim construction. The case may turn on whether the term "fold inwardly," as used in the patents, can be interpreted to cover the action of a rigid wall panel rotating or pivoting into place. The complaint advances a narrow definition based on an extrinsic dictionary source, raising the question of what definition is supported by the patents' intrinsic evidence Compl. ¶43
• Technical Questions: A key technical question, intertwined with the invalidity allegations, is whether the asserted claims are supported by the original patent disclosures. The complaint alleges the "inward-folding storage box structure" was new matter added years after the priority date and after similar products were already on the market, raising the question of whether the claims are invalid for lack of written description Compl. ¶14 Compl. ¶19 Compl. ¶21 The complaint provides a side-by-side comparison of a figure from Defendant's 2023 provisional application and a figure from the allegedly prior-art HAIXIN patent to support its claim that Defendant copied a pre-existing design Compl. p. 8 Another visual chart compares photographs from Defendant's provisional application with photos of what the complaint identifies as HAIXIN's products sold in 2022, alleging they are identical Compl. p. 10

V. Key Claim Terms for Construction

• The Term: "configured to fold inwardly"
• Context and Importance: This term appears in the independent claims of both asserted patents and is the sole basis for the plaintiff's non-infringement arguments. The outcome of the infringement analysis may depend entirely on the legal construction of this term. Practitioners may focus on this term because the plaintiff's non-infringement defense is staked on a narrow definition that excludes the accused products' rotational assembly mechanism.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent specifications state that the sidewalls "are configured to fold inwardly in the closed condition" but do not provide an explicit definition of "fold" '446 Patent, col. 2:24-26 '546 Patent, col. 2:25-27 Figures in the patents, such as Figure 8 of the '446 Patent, depict entire, seemingly rigid wall panels pivoting inward from the base, an action that could be argued to fall within a broad interpretation of "folding" in this mechanical context.
  • Evidence for a Narrower Interpretation: The absence of a specific definition in the patents for "fold" may lead parties to argue for applying its plain and ordinary meaning. The complaint suggests this meaning requires a bending or "doubling over" action, which it alleges the accused products' rigid, rotating panels do not perform Compl. ¶43 The ultimate construction will depend on how a court weighs the specification's language and figures against the term's ordinary meaning to a person of skill in the art.

VI. Other Allegations

The complaint contains significant allegations against the defendant concerning the validity and enforceability of the patents-in-suit.

• Invalidity based on New Matter and Lack of Written Description: The complaint alleges that the core features of the asserted claims-specifically the "inward-folding storage box structure"-were not present in the defendant's earlier patent applications from which priority is claimed Compl. ¶14 Compl. ¶19 It alleges these features were introduced for the first time in 2023 provisional applications and constitute new matter, which would invalidate the asserted claims under 35 U.S.C. § 112 and strip them of their claimed 2021 priority date Compl. ¶19 Compl. ¶21 Compl. ¶22 Compl. ¶48
• Invalidity based on Prior Art: If the claims are not entitled to their earlier priority date, the complaint alleges they are anticipated or rendered obvious by prior art, including a Chinese patent issued to Plaintiff's supplier, HAIXIN, in 2021 and public sales of HAIXIN's products on Amazon since at least 2022 Compl. ¶13 Compl. ¶28 Compl. ¶49
• Unenforceability based on Inequitable Conduct: The complaint includes a count for unenforceability of the '546 Patent based on inequitable conduct Compl. ¶¶31-39 The plaintiff alleges that the defendant knew of HAIXIN's prior art, including its patent and its commercial sales, at the time of filing its provisional applications Compl. ¶35 It is alleged that Defendant submitted photographs of HAIXIN's products as its own invention and, while disclosing the HAIXIN patent to the USPTO, intentionally withheld the fact of HAIXIN's prior commercial sales, which constitute a separate basis for invalidity Compl. ¶¶36-38 This conduct is alleged to have been undertaken with an intent to deceive the USPTO Compl. p. 17

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

• A core issue will be one of definitional scope: can the term "configured to fold inwardly," as used in the patents for collapsible containers, be construed to encompass the inward rotation of single, rigid wall panels, or does it require a narrower bending or creasing action as argued in the complaint?
• A second key issue concerns patent validity and priority: are the asserted claims, particularly their limitations regarding the inward-folding storage box design, adequately supported by the original 2021 patent application? The court's determination of whether new matter was improperly added will decide the effective priority date and which prior art references are applicable.
• The case also presents a significant evidentiary question of inequitable conduct: can the plaintiff prove by clear and convincing evidence that the defendant, with intent to deceive, withheld material information from the USPTO, specifically the alleged prior commercial sales of the HAIXIN products? The answer will turn on evidence of what the defendant knew and when.