Guangzhou Fangtu Technology Co Ltd v. Dbest Products Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Guangzhou Fangtu Technology Co., Ltd. (China)
  • Defendant: Dbest Products, Inc. (California)
  • Plaintiff's Counsel: Envisage Law; Illovsky, Gates & Calia LLP
• Case Identification: Guangzhou Fangtu Technology Co., Ltd. v. Dbest Products, Inc., 2:26-cv-07860, C.D. Cal., 07/17/2026
• Venue Allegations: Venue is alleged to be proper as Defendant's principal place of business is within the Central District of California, where it regularly conducts business, advertises, and sells products.
• Core Dispute: Plaintiff seeks a declaratory judgment that its stackable storage bins do not infringe Defendant's patents related to collapsible carts, following Defendant's patent infringement complaints to Amazon that resulted in the removal of Plaintiff's product listings.
• Technical Context: The technology concerns collapsible containers, centering on the structural differences between wheeled utility "carts" and stationary storage "boxes."
• Key Procedural History: This action arises from an "actual controversy" created after Defendant submitted multiple patent infringement complaints to Amazon.com, causing Amazon to delist Plaintiff's products. The complaint also alleges a pattern of behavior by Defendant, citing a separate matter where Defendant allegedly asserted a patent against another party and then issued a covenant not to sue after a declaratory judgment action was filed.

Case Timeline

Date	Event
2020-01-06	Priority Date for '446 and '546 Patents
2024-12-05	Defendant allegedly submits infringement complaint to Amazon against a third party
2025-01-23	Defendant allegedly issues covenant not to sue to the third party
2025-04-15	U.S. Patent No. 12,275,446 ('446 Patent) Issues
2025-05-20	U.S. Patent No. 12,304,546 ('546 Patent) Issues
2026-02-21	Defendant submits infringement complaint to Amazon against Plaintiff
2026-04-17	Defendant submits another infringement complaint to Amazon against Plaintiff
2026-05-22	Defendant submits another infringement complaint to Amazon against Plaintiff
2026-06-23	Defendant submits another infringement complaint to Amazon against Plaintiff
2026-07-17	Complaint for Declaratory Judgment Filed

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

U.S. Patent No. 12,275,446 - "High Load Capacity Collapsible Carts"

• Patent Identification: U.S. Patent No. 12,275,446, titled "High Load Capacity Collapsible Carts," issued on April 15, 2025. Compl. ¶2 Compl. Ex. A

The Invention Explained

• Problem Addressed: The patent's background section notes that prior art collapsible carts may have sidewalls that are not "sufficiently sturdy" for transporting heavy objects due to their collapsible nature. '446 Patent, col. 1:12-16
• The Patented Solution: The patent describes a "compressible cart" with a reinforced structure to solve this problem. A key inventive concept is a sidewall constructed from a "first right panel rotatably coupled to a second right panel" via a hinge. A "first slideable member" moves along a track spanning both panels to lock them into a rigid, co-planar configuration for use, providing stability. '446 Patent, abstract '446 Patent, col. 5:8-25 This mechanism allows the cart to be both sturdy when open and foldable for storage.
• Technical Importance: The invention aims to enhance the structural integrity and load-bearing capability of collapsible carts, making them more suitable for heavy-duty applications than was previously practical. '446 Patent, col. 1:12-16

Key Claims at a Glance

• The complaint seeks a declaratory judgment of non-infringement of independent claims 1, 10, 16, and 22. Compl. ¶27
• Independent Claim 1 requires, among other elements:
  • A collapsible cart configured to transition between a closed and open condition.
  • A rigid frame with multiple walls.
  • A right sidewall comprising a "first right panel rotatably coupled to a second right panel."
  • A "first track" formed along both right panels.
  • A "first slideable member" that engages the track and is movable to "selectively lock the first right panel to the second right panel." Compl. ¶29
• Independent Claim 10 adds a requirement for a "first locking member" on the first right panel and a "second locking member" on the second right panel that "cooperatively engages" to align the panels. Compl. ¶31
• Independent Claim 16 requires a "first lock assembly integrated with the first right panel and the second right panel" to selectively lock them together. Compl. ¶33
• Independent Claim 22 describes a cart with at least five walls, where a "third wall" comprises a first and second panel rotatably coupled, and a "first fastener" is used to secure them. Compl. ¶35

U.S. Patent No. 12,304,546 - "Collapsible Carts"

• Patent Identification: U.S. Patent No. 12,304,546, titled "Collapsible Carts," issued on May 20, 2025. Compl. ¶2 Compl. Ex. B

The Invention Explained

• Problem Addressed: Similar to the '446 Patent, the background addresses the problem that the sidewalls of prior art collapsible carts "may not be sufficiently sturdy to allow for transporting heavy objects." '546 Patent, col. 1:26-29
• The Patented Solution: This patent discloses a collapsible cart with a frame of at least five walls. The inventive concept centers on an opposing wall that "consists of a first panel and a second panel," which are rotatably coupled. The panels are held in a common plane by a "first latch part" on the edge of the first panel and a "second latch part" on the edge of the second panel, which are configured to mate. '546 Patent, claim 1 When unlatched, the second panel can rotate relative to the first, allowing the cart to collapse.
• Technical Importance: This design provides an alternative method for creating a foldable yet structurally sound cart, balancing the need for collapsibility with the strength required for use. '546 Patent, col. 1:26-29

Key Claims at a Glance

• The complaint seeks a declaratory judgment of non-infringement of independent claims 1, 9, and 17. Compl. ¶39
• Independent Claim 1 requires, among other elements:
  • A collapsible cart with a frame of at least five walls.
  • "one of the two opposing walls consists of a first panel and a second panel," with the second panel "rotatably coupled to the first panel."
  • A "first latch part" on the edge of the first panel and a "second latch part" on the edge of the second panel.
  • The latch parts are configured to "mate with one another and hold the first and second panels in a common plane."
  • When unlatched, the second panel is "capable of rotating relative to the first panel." Compl. ¶41
• Independent Claim 9 adds a requirement for a "fastener" to secure the first and second panels in a "substantially coplanar alignment," where the fastener comprises members "integrally disposed on an edge" of each panel. Compl. ¶43
• Independent Claim 17 requires specific dimensional relationships, where the height of the first and second walls is "less than half the length" of the third and fourth walls, such that they become "substantially coplanar" when folded. Compl. ¶45

III. The Accused Instrumentality

Product Identification

The accused products are "stackable storage bins" sold by Plaintiff Guangzhou Fangtu under the brand names "Fangtueh" and "QAVABIN" on Amazon.com. Compl. ¶¶5, 11, 12

Functionality and Market Context

The complaint characterizes the products as "collapsible storage boxes" designed for stationary storage, not transportation. Compl. ¶30a Compl. ¶60 It is alleged that they have two states: a folded state for compact storage and an expanded state for holding items. Compl. ¶30a A photograph in the complaint shows multiple individual bins stacked vertically. Compl. p. 9 Plaintiff alleges its products are sold on Amazon, its "primary sales channel," and that Defendant is a direct competitor in the same market with its "Quik Box" product line. Compl. ¶23 Compl. ¶24 Compl. ¶49 The complaint alleges that Defendant's infringement reports to Amazon caused Plaintiff's products to be delisted, halting its sales. Compl. ¶¶21-22

IV. Analysis of Infringement Allegations

'446 Patent Infringement Allegations

The complaint alleges non-infringement by arguing that the accused products lack key limitations of the asserted claims.

Claim Element (from Independent Claim 1)	Alleged Non-Infringing Functionality	Complaint Citation	Patent Citation
A collapsible cart...	Plaintiff's products are described as "collapsible storage boxes" for stationary use, not "carts" intended for transportation.	¶30a	col. 7:14-17
the right sidewall comprising a first right panel rotatably coupled to a second right panel	The complaint alleges the product's right sidewall is a "single, continuous, unitary molded plastic panel" with no sub-panels, pivot joints, or living hinges. A photograph of the product's unitary sidewall is provided as evidence.	¶30c; Compl. p. 17	col. 7:24-26
a first track formed along the first right panel and the second right panel...	The complaint alleges the product's unitary sidewall has "no track of any kind."	¶30d	col. 7:27-31
a first slideable member cooperatively engaged to the first track... to selectively lock the first right panel to the second right panel...	The complaint alleges the products lack any "slideable member moveable between an open position to a closed position."	¶30e	col. 7:32-38

'546 Patent Infringement Allegations

The complaint makes similar structural arguments for non-infringement of the '546 Patent.

Claim Element (from Independent Claim 1)	Alleged Non-Infringing Functionality	Complaint Citation	Patent Citation
A collapsible cart...	Plaintiff again argues its products are "collapsible storage boxes," not "carts."	¶42a	col. 13:19-22
one of the two opposing walls consists of a first panel and a second panel, the second panel rotatably coupled to the first panel	The complaint alleges that in its products, "both of the two opposing walls are single, unitary panels" and do not consist of two coupled sub-panels. A photograph is provided showing the product's exterior.	¶42b; Compl. p. 73	col. 13:30-34
a first latch part disposed on an edge of the first panel... and a second latch part disposed on an edge of the second panel... configured to mate...	The complaint alleges that because the opposing walls are unitary panels, there are no "'first panel' or 'second panel' edges on which latch parts could be disposed."	¶42c	col. 13:35-42
when the first and second latch parts are unlatched... the second panel is capable of rotating relative to the first panel.	The complaint alleges the opposing walls are "entirely incapable of collapsing at a center vertical joint between two sub-panels and rotating relative thereto." An interior photograph shows the unitary construction.	¶42d; Compl. p. 29	col. 13:43-45

• Identified Points of Contention:
  • Definitional Scope: A primary dispute will be the construction of the term "collapsible cart." Plaintiff advocates for a narrow definition tied to transportation, which it alleges its "storage boxes" do not satisfy. Compl. ¶¶60, 68 The court's interpretation of this term could be dispositive for all asserted claims.
  • Structural Mismatch: The complaint's core technical argument is a literal lack of infringement based on fundamental structural differences. It alleges the patents require two-panel, hinged, and lockable sidewalls, whereas the accused products allegedly use single, unitary molded plastic panels. Compl. ¶30c Compl. ¶42b A key question for the court will be whether there is a literal or equivalent structure in the accused products that meets these claim limitations.

V. Key Claim Terms for Construction

• The Term: "collapsible cart"
  • Context and Importance: This term appears in every independent claim of both patents. The Plaintiff's entire case strategy appears to hinge on distinguishing its "collapsible storage boxes" from what it defines as a "cart." Practitioners may focus on this term because its construction could resolve the infringement question for all asserted claims without a deeper technical analysis.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patents describe "compressible carts" and "collapsible carts" that are essentially boxes on wheels, and the abstract of the '446 Patent describes a "rigid frame" with walls, which could be read broadly. '446 Patent, abstract
    • Evidence for a Narrower Interpretation: The complaint cites the "plain and ordinary meaning" of "cart" as a "small vehicle used to carry or transport items." Compl. ¶60 The title of the '446 Patent, "High Load Capacity Collapsible Carts," and its stated purpose of improving sturdiness for "transporting heavy objects" may support an interpretation tied to a transportation function. '446 Patent, title '446 Patent, col. 1:12-16
• The Term: "rotatably coupled" (in reference to the sidewall panels)
  • Context and Importance: This term is central to the claimed mechanism for reinforcing the sidewalls. The complaint alleges the accused products use a single unitary panel, not two panels that are "rotatably coupled." Compl. ¶¶56-59 The dispute will center on whether the accused single-panel design can meet this limitation, either literally or under the doctrine of equivalents.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A defendant might argue that a living hinge or a pre-formed crease in a unitary piece of plastic that allows folding performs the function of being "rotatably coupled."
    • Evidence for a Narrower Interpretation: The patent specification and figures show two distinct panels joined by a physical hinge mechanism. For example, the '446 Patent specification describes a "first hinge 27" coupling the first and second right panels. '446 Patent, col. 4:49-52 The complaint explicitly denies the presence of a "living hinge groove" in the accused product. Compl. p. 17

VI. Other Allegations

• Indirect Infringement: The complaint is for a declaratory judgment of non-infringement and explicitly denies any direct, contributory, or induced infringement. Compl. ¶55 Compl. ¶64
• Willful Infringement: Willful patent infringement is not alleged. However, the complaint includes counts for business torts, such as trade libel and intentional interference with contractual relations. Compl. ¶¶71-95 It alleges that Defendant submitted its infringement complaints to Amazon with "actual malice knowing they were false or with reckless disregard for their truth or falsity," which is a key element for those separate claims. Compl. ¶74

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

• A core issue will be one of definitional scope: can the term "collapsible cart," which the patents describe in the context of transporting objects, be construed to cover Plaintiff's products, which are marketed and allegedly used as "stationary storage boxes"?
• A central evidentiary question will be one of structural infringement: does the accused product's alleged single-piece, unitary sidewall construction infringe claims that explicitly require a two-panel wall where the panels are "rotatably coupled" and secured by a distinct latch or fastener, either literally or under the doctrine of equivalents?
• A third significant question, lying outside of patent law, will be one of bad faith: did the Defendant knowingly or recklessly submit false infringement allegations to Amazon, potentially giving rise to liability for business torts such as trade libel and intentional interference, regardless of the ultimate outcome of the patent infringement analysis?