Sanders Collection v. dbest Products: Collapsible Cart Patent Dismissed Without Prejudice
Sanders Collection Inc. filed a patent infringement action against dbest Products, Inc. in the Southern District of New York, asserting US12103576B2 covering stackable collapsible cart technology across more than 40 accused product SKUs. The case was voluntarily dismissed without prejudice after 129 days, with each party bearing its own costs.
A Pre-Answer Dismissal Leaves Collapsible Cart Patent Dispute Unresolved
Sanders Collection Inc. filed suit against dbest Products, Inc. on 31 December 2024 in the U.S. District Court for the Southern District of New York before Judge Arun Subramanian. The complaint alleged infringement of US12103576B2, a patent covering stackable collapsible cart technology, and identified more than 40 accused product ASINs sold by dbest Products, spanning a broad range of rolling cart and utility cart variants listed on Amazon.
The case was voluntarily dismissed without prejudice on 9 May 2025 pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), at a point when dbest Products had not yet filed an answer or any motion for summary judgment. The dismissal notice explicitly confirmed this was Sanders Collection’s first dismissal of any federal or state action based on the same claims. Each party was left to bear its own costs, fees, and expenses, with no monetary or injunctive relief awarded.
The 129-day lifespan and pre-answer exit suggest the dispute may have been resolved through direct negotiation, licensing discussions, or a strategic reassessment of claim strength — though the public record is silent on the precise driver. Because the dismissal is without prejudice, Sanders Collection retains the right to refile based on the same patent and claims, which means dbest Products cannot treat this closure as a final resolution of its exposure under US12103576B2.
Filing to Voluntary dismissal in 129 days
129 days — resolved before defendant filed any answer or dispositive motion
Voluntarily dismissed: what the without-prejudice exit means for both parties
Rule 41(a)(1)(A)(i): unilateral dismissal before defendant responds
Fed. R. Civ. P. 41(a)(1)(A)(i) permits a plaintiff to dismiss an action without a court order if the defendant has not yet filed an answer or motion for summary judgment. Sanders Collection invoked this rule, making the dismissal self-executing upon filing. No judicial approval was required, and the court issued no findings on the merits of the infringement claims.
No merits rulingWithout prejudice: the door remains open for Sanders Collection
A dismissal without prejudice does not extinguish the underlying claims — Sanders Collection is legally free to refile an infringement action based on US12103576B2 against dbest Products. This contrasts with a with-prejudice dismissal, which would bar refiling on the same claims. The dismissal notice expressly invokes Rule 41(a)(1)(B) and states ‘without prejudice’, so the public record is unambiguous on this point.
Refiling remains possibledbest Products escapes judgment — but not permanent exposure
dbest Products obtained the dismissal without litigating the merits, incurring no adverse judgment, and bears its own costs rather than having them assessed against Sanders Collection. However, because the dismissal is without prejudice, dbest Products faces continued uncertainty over its collapsible cart product line. The absence of a ruling on invalidity or non-infringement provides no legal shield against a future action.
No res judicata protection40+ accused SKUs signal broad claim scope — watch for refiling
The sheer volume of accused ASINs — spanning numerous collapsible and stackable cart variants — suggests Sanders Collection was asserting broad claim coverage under US12103576B2. Competing sellers of similar utility cart products on e-commerce platforms should monitor for refiling activity. A pre-answer, without-prejudice exit is often consistent with ongoing licensing negotiations or a strategic pause pending reexamination or claim refinement.
Sector-wide licensing riskFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Sanders Collection Inc. | Company | Consumer goods patent holder — holder of US12103576B2 for stackable collapsible cart technologySearch in Eureka ↗ |
| Defendant | dbest products, Inc. | Company | dbest Products, Inc. — e-commerce seller of rolling and collapsible utility cartsSearch in Eureka ↗ |
| Plaintiff counsel | Michael Myer Steinmetz | Attorney | Counsel for Sanders Collection Inc.Search in Eureka ↗ |
| Plaintiff law firm | Garson Segal Steinmetz Fladgate LLP | Law Firm | Representing Sanders Collection Inc.Search in Eureka ↗ |
| Defendant counsel | Nancy Jill Mertzel. | Attorney | Counsel for dbest products, Inc.Search in Eureka ↗ |
| Defendant law firm | Mertzel Law PLLC | Law Firm | Representing dbest products, Inc.Search in Eureka ↗ |
| Presiding judge | Judge Arun Subramanian | Judge | New York Southern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The dismissal notice is procedurally straightforward but strategically significant. By invoking Rule 41(a)(1)(A)(i) before any responsive pleading was filed, Sanders Collection exercised its right to exit without judicial involvement. The explicit ‘without prejudice’ language and mutual cost-bearing terms confirm no settlement payment was recorded in the public docket. Because no merits were adjudicated, US12103576B2 has neither been validated nor invalidated by this proceeding, leaving its enforceability entirely intact for future actions.
US12103576B2 — Stackable Collapsible Cart Technology
US12103576B2, filed under application number US18/542495, protects innovations in stackable collapsible cart design — a category that encompasses folding utility carts capable of nesting or stacking for compact storage. This patent sits within a commercially active segment of the consumer goods and e-commerce accessories market, where product differentiation through structural and mechanical design is central to competitive positioning.
The breadth of the accused product list — more than 40 ASINs across dbest Products’ cart lineup — suggests the patent’s claims are drafted to cover a product family rather than a single configuration. For competitors in the collapsible cart and portable storage categories, US12103576B2 represents a monitored enforcement asset. Sanders Collection’s willingness to file immediately and name a large SKU set signals active patent enforcement intent, regardless of this case’s without-prejudice outcome.
Should you run an FTO analysis against US12103576B2?
If your company designs, sources, imports, or sells stackable collapsible carts — particularly through Amazon or other e-commerce channels — US12103576B2 warrants a formal freedom-to-operate review. The scope of accused products in this case spans a wide range of cart configurations, and the without-prejudice dismissal means enforcement risk has not been resolved. Even products not named in this action may fall within the patent’s claims depending on structural features.
PatSnap Eureka’s FTO Search Agent enables R&D and product teams to map specific cart designs against the claims of US12103576B2, identify prior art that could support design-around or invalidity arguments, and benchmark against the full Sanders Collection IP portfolio. Running a targeted FTO now provides documented due diligence ahead of any potential refiling or licensing approach.
Run a freedom-to-operate analysis on US12103576B2 to assess your product’s exposure
Run FTO in Eureka →Similar Patent Cases in Collapsible Cart and Utility Storage Technology
Cases involving collapsible and stackable cart patents filed in the Southern District of New York and related e-commerce product infringement actions.
What this case signals for the collapsible cart and utility storage IP landscape
A rapid pre-answer exit over 40+ accused SKUs typically signals unresolved commercial tension rather than a clean end to the dispute.
Without-prejudice dismissals are not case endings — monitor for refiling
Sanders Collection retains full rights to refile under US12103576B2. Companies selling collapsible or stackable cart products, particularly through Amazon, should track docket activity and consider whether their designs fall within the patent’s claims. A freedom-to-operate analysis now is less costly than defending a second action.
Pre-answer exits often reflect private resolution or litigation economics
The 129-day timeline and absence of any filed answer suggest this case may have moved toward a licensing arrangement or commercial settlement — or that Sanders Collection reassessed its litigation economics. Either way, US12103576B2 remains an active enforcement risk for the collapsible cart category.
Sanders v dbest — key questions answered
The case was voluntarily dismissed without prejudice on 9 May 2025, 129 days after filing. Plaintiff Sanders Collection Inc. invoked Fed. R. Civ. P. 41(a)(1)(A)(i) before defendant dbest Products filed any answer. No merits were adjudicated and each party bears its own costs.
Sanders Collection asserted US12103576B2, filed under application US18/542495, which covers stackable collapsible cart technology. The complaint accused more than 40 dbest Products ASINs, spanning multiple collapsible and rolling cart variants sold on e-commerce platforms including Amazon.
A without-prejudice dismissal means dbest Products obtained no merits judgment in its favour. Sanders Collection retains the right to refile the same infringement claims under US12103576B2. dbest Products has no res judicata or claim preclusion defence if a new action is filed, meaning its exposure to this patent remains live.
Yes. A Rule 41(a)(1)(A)(i) dismissal without prejudice does not bar refiling. Sanders Collection confirmed in the dismissal notice this was its first dismissal of any action based on the same claims. Under Rule 41(a)(1)(B), only a second voluntary dismissal of the same claim would operate as a dismissal with prejudice.
The public record does not disclose the reason for the early exit. The 129-day timeline and pre-answer dismissal are consistent with direct licensing negotiations, a commercial settlement not reflected in the docket, or a strategic decision by Sanders Collection to reassess its litigation position. No settlement terms were publicly filed.
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