dbest products v. Guangzhou Nafenai: Portable Cart Patent Action Dismissed
dbest products, Inc. asserted two portable cart patents against Chinese trading company Guangzhou Nafenai Trading Co., Ltd. in California’s Central District. The plaintiff voluntarily dismissed the action without prejudice just 117 days after filing, before the defendant filed any responsive pleading.
A pre-answer dismissal that leaves the portable cart dispute unresolved
dbest products, Inc., a California-based maker of portable carts, filed this infringement action on 21 May 2025 in the Central District of California against Guangzhou Nafenai Trading Co., Ltd., a Chinese trading company. The complaint asserted two utility patents — US12275446B2 and US12304546B1 — both directed at portable cart technology. The case was handled on the plaintiff side by Orbit IP LLP, with attorneys Bruce G. Chapman, David A. Randall, and Ehab M. Samuel on record.
On 15 September 2025, dbest voluntarily dismissed the action without prejudice pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), confirming that Guangzhou Nafenai had not yet filed an answer or a motion for summary judgment. The dismissal was also conditioned on each party bearing its own costs, fees, and expenses. A without-prejudice dismissal at this stage does not adjudicate the merits and preserves dbest’s right to refile substantially the same claims in a future action.
The 117-day span from filing to dismissal, ending before any responsive pleading, is consistent with an early-stage resolution — potentially driven by a private settlement, a licensing arrangement, the defendant ceasing the allegedly infringing activity, or a strategic reassessment by plaintiff. The public record is silent on the underlying reason for dismissal. Because the case ended before the defendant engaged, no claim construction, damages, or validity findings were made, leaving the patent strength untested in this proceeding.
Filing to Voluntary dismissal in 117 days
117 days — resolved before defendant filed any answer or motion
Voluntarily dismissed without prejudice: what the ruling means for both parties
Rule 41(a)(1)(A)(i): dismissal as of right, no court approval needed
Fed. R. Civ. P. 41(a)(1)(A)(i) permits a plaintiff to dismiss an action without a court order at any time before the defendant serves an answer or a motion for summary judgment. Because Guangzhou Nafenai had not filed either, dbest had an unqualified right to dismiss. No judicial ruling on the merits was required or issued, and the case terminates automatically upon filing of the notice.
Pre-answer voluntary dismissalWithout prejudice: dbest retains the right to refile
A dismissal without prejudice means the action is terminated without any adjudication of the underlying patent claims. dbest explicitly confirmed the without-prejudice character in its notice. This preserves the plaintiff’s ability to bring the same infringement claims again in a future action, subject to any applicable statute of limitations. Importantly, Rule 41(a)(1)(B)’s ‘two-dismissal rule’ would convert a second voluntary dismissal of the same claims into a dismissal with prejudice.
Refiling remains possibleGuangzhou Nafenai exits without liability — but patent risk persists
The defendant faces no injunction, damages award, or finding of infringement from this proceeding. Having never filed a responsive pleading, Guangzhou Nafenai also has no invalidity counterclaim on the record. However, because the dismissal is without prejudice, the underlying patent assertions against its portable cart products remain unresolved. Continued sale of the same products could trigger a refiled action, potentially in the same court.
No liability found — risk remainsUnresolved patents signal ongoing IP risk for portable cart importers
Both US12275446B2 and US12304546B1 remain in force and untested by this litigation. Competitors and importers of portable carts — particularly those sourcing from Chinese manufacturers — should treat this outcome as a signal that dbest is actively monitoring and enforcing its portfolio. The pre-answer dismissal, combined with no cost award against the plaintiff, suggests dbest retains full flexibility to re-engage commercially or legally at a time of its choosing.
Active portfolio enforcement riskFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | dbest products, Inc. | Company | Portable cart manufacturer — holder of US12275446B2 and US12304546B1Search in Eureka ↗ |
| Defendant | Guangzhou Nafenai Trading Co., Ltd. | Company | Guangzhou Nafenai Trading Co., Ltd. — Chinese trading company in portable goodsSearch 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 expressly invokes Rule 41(a)(1)(A)(i) and confirms two prerequisites: no answer filed, no prior dismissal of the same claims. The explicit without-prejudice characterisation is legally significant — it forecloses any argument that the termination bars future proceedings on the same patents. The cost-sharing provision (‘each party to bear its own costs’) is standard in uncontested early dismissals and does not reflect a negotiated settlement payment on the public record. No merits findings were made.
US12275446B2 & US12304546B1 — Portable Cart Technology
US12275446B2 (application US18/460131) and US12304546B1 (application US19/032431) both sit within dbest’s portable cart patent portfolio. These patents cover design and functional elements of portable cart products — a competitive consumer and utility goods category with significant import volume from Chinese manufacturers. The relatively recent application numbers suggest these are newer grants, indicating dbest has been actively building and refreshing its IP position in this space.
For competitors and importers of portable carts, both patents represent active enforcement risk. dbest’s willingness to file federal litigation — even if ultimately dismissed without prejudice — demonstrates that these patents are not merely defensive assets. Any company importing, distributing, or retailing portable carts in the US that overlap with the claimed features of US12275446B2 or US12304546B1 should conduct a thorough freedom-to-operate analysis. The absence of any invalidity ruling in this case means both patents carry full presumption of validity.
Should you run an FTO against US12275446B2 and US12304546B1?
If your company sources, imports, or retails portable carts in the US market — particularly through Chinese supply chains — both patents asserted in this case warrant immediate FTO attention. dbest has shown it will file in the Central District of California against Chinese trading companies, and a without-prejudice dismissal does not reduce the underlying risk. Product teams launching new cart SKUs or refreshing existing designs should treat these patents as live clearance requirements.
PatSnap Eureka’s FTO Search Agent allows R&D and IP teams to map the claim scope of US12275446B2 and US12304546B1 against your product specifications in minutes. Eureka can identify design-arounds, flag claim overlaps, and surface the broader dbest portfolio to assess whether additional patents are in play. Run a targeted FTO before your next product launch or supplier onboarding to avoid replicating the exposure Guangzhou Nafenai faced here.
Run a freedom-to-operate analysis on US12275446B2 to assess your product’s exposure
Run FTO in Eureka →Similar Portable Cart Patent Infringement Cases in C.D. Cal.
Explore related patent infringement actions involving portable cart and consumer goods patents litigated in the Central District of California against Chinese trading companies.
What this case signals for the portable cart IP landscape
A fast pre-answer dismissal rarely means the dispute is over — it often marks a strategic pause in an ongoing enforcement campaign.
Pre-answer dismissals often precede licensing deals or product changes
When a plaintiff voluntarily dismisses before the defendant has responded, it typically suggests the parties reached an informal resolution or the defendant made a commercial concession. The public record does not confirm this here, but the pattern is well-established in Chinese-importer enforcement cases before C.D. Cal.
Both patents remain live enforcement tools for dbest
US12275446B2 and US12304546B1 survived this case without any validity challenge on the record. That strengthens dbest’s posture for any future action — against this defendant or others selling similar portable cart products in the US market. IP teams sourcing portable cart products should run clearance checks against both patents.
dbest v Guangzhou — key questions answered
dbest products, Inc. filed a patent infringement action against Guangzhou Nafenai Trading Co., Ltd. in the Central District of California on 21 May 2025, asserting US12275446B2 and US12304546B1 covering portable cart technology. The case was voluntarily dismissed without prejudice on 15 September 2025 — 117 days after filing — before the defendant filed any responsive pleading.
Yes. A voluntary dismissal without prejudice under Rule 41(a)(1)(A)(i) does not adjudicate the merits and preserves the plaintiff’s right to refile substantially the same claims. However, under Rule 41(a)(1)(B)’s two-dismissal rule, a second voluntary dismissal of the same claims would operate as a dismissal with prejudice, permanently barring the same action.
dbest asserted two US patents: US12275446B2 (application no. US18/460131) and US12304546B1 (application no. US19/032431). Both patents relate to portable cart technology. Neither patent was subjected to validity or infringement analysis in this proceeding, as the case ended before any merits adjudication.
The public record does not disclose the reason for dismissal. Common explanations for a pre-answer voluntary dismissal include a private settlement or licensing agreement, the defendant ceasing the allegedly infringing conduct, a strategic decision to refile in a different venue, or a commercial resolution reached outside court. The explicit without-prejudice character of the dismissal suggests dbest preserved its options deliberately.
The dismissal notice states each party bears its own costs, fees, and expenses. This is standard in uncontested early dismissals filed as of right under Rule 41(a)(1)(A)(i), where no court order is required. It does not constitute a finding that either party acted improperly, nor does it reflect any disclosed payment between the parties.
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