Hangzhou Jinmi Digital Technology Co Ltd v. Dbest Products Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Hangzhou Jinmi Digital Technology Co., Ltd. (China)
  • Defendant: Dbest Products, Inc. (California)
  • Plaintiff's Counsel: Valley & Summit Law P.C.
• Case Identification: 2:26-cv-07495, C.D. Cal., 07/10/2026
• Venue Allegations: Venue is alleged to be proper in the Central District of California because the Defendant is a resident of the District.
• Core Dispute: Plaintiff seeks a declaratory judgment that its portable pet carriers do not infringe Defendant's patent and/or that the patent is invalid, following Defendant's assertion of the patent through Amazon.com's intellectual property enforcement program.
• Technical Context: The technology concerns wheeled, collapsible pet carriers designed for travel, focusing on features that enhance portability, storage, and pet comfort.
• Key Procedural History: The action was precipitated by Defendant lodging an intellectual property complaint with Amazon.com, asserting U.S. Patent No. 9,392,766 against Plaintiff's products. This resulted in the deactivation of Plaintiff's product listings. The complaint highlights that during patent prosecution, the patent examiner specifically noted the feature of the handle being positioned "beneath the platform" for storage as a reason for allowance over the prior art.

Case Timeline

Date	Event
2013-10-20	'766 Patent Priority Date
2016-07-19	'766 Patent Issue Date
2025-12-19	Plaintiff notified by Amazon of product listing removal
2026-02-23	'766 Patent assigned to Defendant DBEST PRODUCTS, INC.
2026-05-26	Amazon informs Plaintiff that the '766 Patent was the basis for the takedown
2026-07-10	Complaint for Declaratory Judgment filed

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

U.S. Patent No. 9,392,766 - "Portable pet carrier to transport a pet from one location to another and retain the pet in the carrier while traveling"

• Patent Identification: U.S. Patent No. 9,392,766, titled "Portable pet carrier to transport a pet from one location to another and retain the pet in the carrier while traveling," issued on July 19, 2016.

The Invention Explained

• Problem Addressed: The patent's background describes issues with prior art pet carriers, noting that rigid carriers are difficult to store and that wheeled carriers often require being pulled at an angle, which is uncomfortable for the pet inside '766 Patent, col. 1:39-52
• The Patented Solution: The invention is a pet carrier system combining a soft-sided, foldable carrier with a detachable, wheeled base platform '766 Patent, col. 2:1-4 A key feature is a telescoping handle that can be angled for transport, allowing the carrier to remain horizontal, and can also be folded and rotated to be stored under the base platform for compact storage, such as under an airplane seat '766 Patent, col. 2:5-18 '766 Patent, FIG. 4
• Technical Importance: The design sought to create a pet carrier that is comfortable for the animal during transport, convenient for the owner to pull, and highly compact for storage during travel '766 Patent, abstract

Key Claims at a Glance

• The complaint identifies independent claims 1, 2, and 10 as being at issue Compl. ¶12
• Independent Claim 1 recites a pet transport carrier combination including:
  • A flat base platform with four wheels.
  • A handle attached to telescoping sections, connected to the platform by a rotation mechanism.
  • The handle is "foldable rotatable and to be horizontally aligned with an underside of the flat base platform and then rotated so that it is retained under the flat base platform when in storage".
  • A pet transport carrier with a strap and hook/loop fasteners to removably attach to the platform.
  • The carrier is foldable to be flat against the platform for storage.
• Independent Claim 2 recites a similar combination with more specific details about the telescoping handle mechanism and the pet carrier construction, but also includes the limitation that the handle can be "rotated horizontally under the base and retained under horizontal surface of the base".
• The complaint does not specify assertion of dependent claims but seeks a declaration of non-infringement as to the entire patent Compl. ¶42

III. The Accused Instrumentality

Product Identification

• The complaint identifies Plaintiff's "Petseek" brand portable pet carriers, sold on Amazon.com, as the accused products Compl. ¶19 An exemplary image of the product is included in the complaint Compl. p. 9

Functionality and Market Context

• The products are portable pet carriers that assist users in transporting pets, for example, through airports Compl. ¶18 According to the complaint, Defendant's assertion of the '766 Patent led to the takedown of Plaintiff's Amazon listings, affecting over 900 units of inventory valued at approximately $43,102.96 Compl. ¶26 The Plaintiff argues that its products feature a handle that, when folded, rests atop the base platform and is physically prevented by its hinge design from rotating to a position underneath the platform Compl. ¶¶31-33

IV. Analysis of Infringement Allegations

This is a declaratory judgment action for non-infringement. The following table summarizes the Plaintiff's central argument for why its product does not infringe, focusing on the key disputed limitation as presented in the complaint.

'766 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Non-Infringing Functionality	Complaint Citation	Patent Citation
...the telescoping handle is foldable rotatable and to be horizontally aligned with an underside of the flat base platform and then rotated so that it is retained under the flat base platform when in storage...	Plaintiff alleges its product's handle does not meet this limitation. The handle folds to rest atop the base platform. The complaint includes an annotated image asserting that the handle hinges have a wall in the swing channel that physically prevents over-rotation to a position underneath the base.	¶¶31-34	col. 2:12-18

The complaint provides a key visual to support its non-infringement argument. An annotated image of the accused product's base platform shows the handle in a folded position, resting on top of the platform, with arrows pointing to the "Handle hinges" and identifying the "Top of base platform" and "Bottom of base platform" Compl. ¶32, p. 12

• Identified Points of Contention:
  • Prosecution History Estoppel: The complaint alleges that the patent examiner's reasons for allowance explicitly relied on the novelty of the handle being "positioned beneath the platform when necessary for storage" Compl. ¶36 This raises the question of whether the patentee is now estopped from arguing for an interpretation of "under the... platform" that is broad enough to read on a product where the handle rests on top.
  • Scope Question: A central dispute will be the interpretation of "retained under the flat base platform." Does this require the entire handle assembly to be located in the space geometrically beneath the platform, as the patent's Figure 4 seems to depict '766 Patent, FIG. 4, or could it be interpreted more broadly to cover a handle folded into a compact state adjacent to the platform's bottom surface?
  • Technical Question: The complaint makes a factual assertion that its product is "physically incapable of being folded underneath the base platform" Compl. ¶33 A key question for the court will be whether this technical assertion is accurate and if there is any configuration in which the accused product's handle could be considered "retained under" the platform.

V. Key Claim Terms for Construction

• The Term: "retained under the flat base platform when in storage"
• Context and Importance: This term appears in all three independent claims and is the sole basis for the non-infringement argument detailed in the complaint (Compl. ¶¶31; Compl. ¶35). The plaintiff's entire non-infringement case, as pleaded, rests on the assertion that its products "clearly lack a handle retained under a base platform when folded" Compl. ¶31 Practitioners may focus on this term because the plaintiff has explicitly linked it to the examiner's reasons for allowance, suggesting a potential prosecution history estoppel argument that could significantly narrow the term's scope Compl. ¶36
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party seeking a broader interpretation might argue that "under" does not strictly require being within the footprint of the platform but could mean generally associated with the bottom side or in a stowed position that is not the top. The patent describes the handle being "retained under the platform, both while the pet carrier portion is stored under a seat and for purposes of storage" '766 Patent, col. 2:16-18, which could suggest the function (storage) is as important as the precise location.
  • Evidence for a Narrower Interpretation: The specification provides strong support for a narrow, literal interpretation. It explicitly describes the handle being "rotated horizontally under the base and retained under the horizontal surface of the base" '766 Patent, col. 4:30-33 Furthermore, Figure 4, which is a bottom plan view, clearly depicts the handle (60) positioned between the wheels and fully within the boundaries of the base platform (14), seemingly "under" it '766 Patent, FIG. 4 Compl. p. 7 The plaintiff also points to the prosecution history, where the examiner allegedly relied on this specific configuration for allowance Compl. ¶36

VI. Other Allegations

• Indirect Infringement: This declaratory judgment complaint does not contain allegations of indirect infringement; it focuses on establishing the plaintiff's non-infringement.
• Willful Infringement: Willfulness is not alleged, as this action is brought by the accused infringer, not the patentee.
• Invalidity and Unenforceability: In addition to non-infringement, the plaintiff seeks a declaration that the '766 Patent is invalid under 35 U.S.C. §§ 102, 103, and/or 112, citing several prior art patents and published applications Compl. ¶¶44-45 The prayer for relief also requests a declaration that the patent is unenforceable due to inequitable conduct, though no specific facts supporting this allegation are pleaded in the body of the complaint Compl. p. 17

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

This case appears to hinge on a focused, and potentially dispositive, claim construction issue coupled with a straightforward factual dispute. The key questions for the court are likely to be:

• A core issue will be one of claim construction and prosecution history: Can the claim term "retained under the flat base platform," which was identified by the patent examiner as a basis for allowance, be interpreted to cover a device where the handle rests on top of the platform, or is the patentee estopped from asserting such a broad scope?
• A determinative question will be one of physical fact: Assuming a narrow construction of "under the platform," is the plaintiff's product, as a matter of engineering and design, physically incapable of folding its handle to the claimed "under" position, as alleged in the complaint?