dbest products v. Amazon.com: Portable Cart Patent Dismissed Without Prejudice
dbest products, Inc. asserted US12103576B2 — a portable carts patent — against Amazon.com, Inc. in the Central District of California. The case closed voluntarily without prejudice just 77 days after filing, before Amazon filed any responsive pleading, leaving the door open for future enforcement.
Early voluntary exit before Amazon even answered the complaint
On May 21, 2025, dbest products, Inc. — a California-based consumer products company and holder of US12103576B2 — filed a patent infringement action against Amazon.com, Inc. in the United States District Court for the Central District of California. The suit alleged infringement of a patent covering portable carts, a product category in which dbest competes directly on the Amazon marketplace and elsewhere.
The case closed on August 6, 2025, just 77 days after filing, when dbest filed a unilateral notice of voluntary dismissal under Fed. R. Civ. P. 41(a)(1)(A)(i). Because Amazon had not yet filed an answer or a motion for summary judgment, dbest was entitled to dismiss as of right — no court order was required. Critically, the dismissal was entered without prejudice, meaning the underlying patent claims remain viable and dbest retains the right to re-file.
The 77-day timeline is notably short and suggests the parties may have reached a private resolution, or that dbest chose to withdraw strategically before incurring significant litigation costs. The public record is silent on any settlement terms. The without-prejudice designation preserves dbest’s enforcement position, and the mutual cost-bearing clause is consistent with an agreed exit rather than a concession of weakness.
Filing to Voluntary dismissal in 77 days
77 days — resolved well before any responsive pleading or scheduling order
Voluntarily dismissed without prejudice: what the exit means for both parties
Rule 41(a)(1)(A)(i) dismissal as of right — no court order needed
Fed. R. Civ. P. 41(a)(1)(A)(i) permits a plaintiff to dismiss without court approval if the defendant has not yet served an answer or motion for summary judgment. Here, Amazon had not filed any responsive pleading, so dbest exercised this right unilaterally. The filing itself operates as the dismissal — instantaneous and unconditional, subject only to the without-prejudice qualifier.
Pre-answer voluntary dismissalWithout prejudice: the distinction that keeps enforcement alive
A dismissal without prejudice does not adjudicate the merits and does not bar dbest from re-filing the same patent claims against Amazon or any other party. By contrast, a dismissal with prejudice would extinguish those claims permanently. The public record specifies ‘without prejudice’ explicitly, preserving dbest’s full enforcement rights under US12103576B2. The record is silent on any settlement or licensing agreement reached in parallel.
Re-filing rights preservedAmazon exits without any merits determination or cost exposure
Because the dismissal was entered before Amazon filed any responsive pleading, Amazon incurred no adjudicated liability and made no formal admissions. The mutual cost-bearing clause means Amazon will not seek attorneys’ fees, which is consistent with a clean exit. However, the without-prejudice dismissal means Amazon has no res judicata protection and remains exposed to re-assertion of the same portable cart patent claims.
No merits ruling; re-exposure riskShort lifecycle signals potential off-docket resolution or strategic repositioning
A 77-day case that closes before any responsive pleading is filed most commonly suggests either a private licensing or settlement agreement, or a deliberate tactical withdrawal to refile with stronger evidence or additional defendants. For competitors in the portable carts and consumer accessories category selling through Amazon’s marketplace, the survival of US12103576B2 in its unadjudicated state means freedom-to-operate risk persists across the product category.
FTO risk remains unresolvedFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | dbest products, Inc. | Company | Consumer products company — holder of US12103576B2 covering portable cartsSearch in Eureka ↗ |
| Defendant | Amazon.com, Inc. | Company | Amazon.com, Inc. — global e-commerce and marketplace platform operatorSearch in Eureka ↗ |
| Plaintiff counsel | Bruce G. Chapman | Attorney | Counsel for dbest products, Inc.Search in Eureka ↗ |
| Plaintiff counsel | David A. Randall | Attorney | Counsel for dbest products, Inc.Search in Eureka ↗ |
| Plaintiff counsel | Ehab M. Samuel | Attorney | Counsel for dbest products, Inc.Search in Eureka ↗ |
| Plaintiff law firm | Orbit IP LLP | Law Firm | Representing dbest products, Inc.Search in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | California Central District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal notice invokes Rule 41(a)(1)(A)(i) and confirms two prerequisites: Amazon had not filed an answer or summary judgment motion, and dbest had not previously dismissed a federal or state action on the same claims. The explicit ‘without prejudice’ designation, combined with the mutual cost-bearing clause, is the operative commercial language. It signals a clean procedural exit rather than a contested withdrawal, but provides no insight into whether a private agreement was reached. The patent remains unadjudicated.
US12103576B2 — Portable Carts Mechanical Design Patent
US12103576B2 (application number US18/542495) covers portable cart technology — a product category encompassing compact, foldable, and rolling cart designs used in consumer, retail, and light commercial settings. The patent reflects dbest’s efforts to protect specific structural or functional innovations in cart design that differentiate its products from commodity alternatives. The application number suggests a relatively recent filing, consistent with dbest’s active enforcement posture in this product category.
Portable carts are a high-volume consumer category sold extensively through e-commerce platforms, making marketplace enforcement a natural enforcement vector. dbest’s decision to assert this patent directly against Amazon — rather than against a smaller marketplace seller — suggests confidence in the patent’s claim scope and a desire to address platform-level distribution of potentially infringing products. The patent’s unadjudicated status means no claim construction has occurred, preserving both its enforcement value and its uncertainty for the market.
Should you run an FTO analysis against US12103576B2?
Any company designing, manufacturing, importing, or distributing portable carts — particularly those sold through Amazon or other major e-commerce platforms — should evaluate their exposure to US12103576B2. The patent has never been construed or invalidated in litigation, meaning its full claim scope remains uncontested. Product teams developing compact, foldable, or rolling cart solutions should review their designs against the issued claims before market entry or platform listing.
PatSnap Eureka’s FTO Search Agent can map the claim language of US12103576B2 against your product specifications, identify prior art that might support an invalidity argument, and flag related continuation or design patent applications in dbest’s portfolio that could create additional enforcement exposure. Running a structured FTO analysis now — before any re-filed action — is the most cost-effective approach to managing risk in the portable carts category.
Run a freedom-to-operate analysis on US12103576B2 to assess your product’s exposure
Run FTO in Eureka →Similar portable cart and consumer product patent cases in C.D. Cal.
Cases involving portable cart and consumer accessories patents in the Central District of California, including enforcement actions against major e-commerce platforms and marketplace distributors.
What this case signals for the portable carts and consumer accessories IP landscape
A rapid pre-answer dismissal without prejudice rarely ends the story — it typically resets it. Here is what IP professionals should watch.
Without-prejudice dismissal keeps US12103576B2 fully armed for re-assertion
The dismissal does not extinguish or narrow dbest’s patent rights. Any company making, selling, or offering portable carts — particularly those distributed through Amazon or similar marketplaces — should treat US12103576B2 as an active enforcement risk. An FTO analysis against this patent remains prudent for any product that competes in this category.
Pre-answer exits in C.D. Cal. often precede licensing deals or refiled actions
The Central District of California sees frequent pre-answer voluntary dismissals in consumer product patent cases, often following early demand letter resolution or parallel licensing negotiations. The mutual cost-bearing clause here is consistent with a consensual exit. IP teams monitoring dbest’s enforcement activity should track both licensing filings and any re-filed actions in the 12 months following dismissal.
dbest v Amazon.com — key questions answered
The dismissal without prejudice means the case was terminated without any ruling on the merits of dbest’s infringement claims. dbest retains the right to refile the same claims under US12103576B2 against Amazon or other parties in the future. No res judicata bar was created and the patent remains fully enforceable.
Fed. R. Civ. P. 41(a)(1)(A)(i) permits a plaintiff to dismiss as of right — without seeking court approval — provided the defendant has not yet served an answer or a motion for summary judgment. The dismissal notice confirmed Amazon had not filed either, so dbest’s unilateral filing was sufficient to close the case.
The asserted patent is US12103576B2 (application no. US18/542495), covering portable carts. The case was filed as an infringement action in the Central District of California on May 21, 2025, and closed 77 days later on August 6, 2025, without any claim construction or merits adjudication.
The without-prejudice dismissal does not protect Amazon from future assertion of the same claims. Amazon made no formal admissions and faces no res judicata bar, but equally received no patent licence or invalidity ruling. Third-party marketplace sellers are entirely separate from this dismissal and would need to evaluate their own exposure to US12103576B2 independently.
The case lasted 77 days, from filing on May 21, 2025, to closure on August 6, 2025. This is a notably short duration, closing before Amazon filed any responsive pleading. The timeline is consistent with early-stage settlement discussions or a strategic tactical withdrawal by the plaintiff.
PatSnap Eureka searches patents and litigation data to answer instantly.