Nguyen v. The Lovesac Company

CourtDistrict Court, E.D. California
DecidedMarch 28, 2025
Docket2:24-cv-01293
StatusUnknown

This text of Nguyen v. The Lovesac Company (Nguyen v. The Lovesac Company) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nguyen v. The Lovesac Company, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 MICHAEL NGUYEN,

12 Plaintiff, No. 2:24-cv-01293-TLN-JDP

13 14 v. ORDER THE LOVESAC COMPANY, 15 Defendant. 16

17 18 This matter is before the Court on Defendant The Lovesac Company’s (“Defendant”) 19 Motion to Dismiss. (ECF No. 22.) Plaintiff Michael Nguyen (“Plaintiff”) filed an opposition. 20 (ECF No. 24.) Defendant filed a reply. (ECF No. 26.) For the reasons set forth below, the Court 21 GRANTS Defendant’s motion. 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 1 I. FACTUAL AND PROCEDURAL BACKGROUND1 2 The instant action arises out of Defendant’s allegedly unlawful marketing, sales, and 3 pricing of its sofas. (ECF No. 18.) Plaintiff alleges that in an effort to increase sales, Defendant 4 engages in a pervasive marketing scheme to artificially inflate the prices of its products for the 5 sole purpose of marking them at a discounted “sale” price. (Id. at 8.) Plaintiff further alleges that 6 Defendant is aware that consumers typically lack material information about a product and often 7 rely on information from sellers when making purchasing decisions, especially when a product’s 8 quality or value is difficult to discern. (Id.) 9 Defendant manufactures, markets, sells, and distributes its flagship Sactional sofas, which 10 it brands as “The World’s Most Adaptable Couch,” in stores across the United States and on its 11 website. (Id. at 2, 6, 8.) Unlike traditional couches, every aspect and feature of the Sactional 12 couch is customizable. (Id. at 9.) This includes the size, dimensions, cushion fill, and material of 13 the couch. (Id.) It also includes add-ons, like storage seats, sound systems, and charging hubs. 14 (Id.) Therefore, prices can vary widely depending on any number of features that a customer 15 selects during the purchasing process. (Id.) Plaintiff alleges this inherently results in a lack of 16 upfront transparency regarding the cost of Defendant’s products. (Id.) Plaintiff further alleges 17 that instead of making the process more transparent, Defendant utilizes multiple methods of 18 deceiving consumers into believing that they are receiving a bargain on the furniture they 19 purchase from Defendant. (Id.) 20 First, when consumers visit a Lovesac store, one of Defendant’s sales representatives 21 assists them in making a purchase. (Id.) Once a consumer navigates all of the different 22 purchasing options, they are presented with a quote. (Id.) This quote allegedly includes a 23 purported “discount” the customer is receiving on their purchase, which correlates with a “limited 24 time sale” being offered by Defendant. (Id.) Similarly, Defendant allegedly utilizes a fictitious 25 strikethrough reference price accompanied by a purported percentage off. (Id.) Next to the 26

27 1 The factual background is taken largely verbatim from Plaintiff’s First Amended Complaint. (ECF No. 18.) 28 1 allegedly fictitious reference price is a lower purported “sale” price. (Id.) Defendant further 2 warrants to consumers that their purchase received a certain “% off” of their purchase, resulting 3 in “-$XX” to the initial subtotal. (Id.) The representations concerning the false reference prices 4 are allegedly substantially the same on Defendant’s e-commerce website and in all of Defendant’s 5 brick-and-mortar stores. (Id. at 10.) 6 Plaintiff alleges Defendant’s sales tactics are not offered in good faith and are made for 7 the sole purpose of deceiving and inducing consumers into purchasing products they otherwise 8 would not have purchased. (Id.) Plaintiff further alleges Defendant never sells its products at the 9 advertised “discounted” or strike-through price. (Id.) This was allegedly confirmed through 10 online archives documenting Defendant’s pricing and sale history for the three months prior to 11 Plaintiff’s purchase date and the three months after Plaintiff’s purchase date, as well as through 12 Defendant’s pricing and sale history for the three months prior to filing the instant action. (Id.) 13 The instant action was filed in Sacramento County Superior Court on March 22, 2024. 14 (ECF No. 1-1.) Defendant removed the action to this Court on May 3, 2024. (ECF No. 1.) 15 Plaintiff filed the operative First Amended Complaint (“FAC”) on July 15, 2024, alleging claims 16 for: (1) a violation of the Consumer Legal Remedies Act (“CLRA”), California Civil Code §§ 17 1750, et seq.; (2) a violation of the False Advertising Law (“FAL”), California Business & 18 Professions Code §§ 17500, et seq.; (3) a violation of the Unfair Competition Law (“UCL”), 19 California Business & Professions Code §§ 17200, et seq.; (4) fraud; and (5) unjust enrichment. 20 (ECF No. 18 at 12–23.) Defendant filed the instant motion to dismiss on August 12, 2024. (ECF 21 No. 22.) 22 II. STANDARD OF LAW 23 A motion to dismiss for failure to state a claim upon which relief can be granted under 24 Federal Rule of Civil Procedure (“Rule”) 12(b)(6) tests the legal sufficiency of a complaint. 25 Navarro v. Block, 250 F.3d 729, 732 (9th Cir. 2001). Rule 8(a) requires that a pleading contain 26 “a short and plain statement of the claim showing that the pleader is entitled to relief.” See 27 Ashcroft v. Iqbal, 556 U.S. 662, 678–79 (2009). Under notice pleading in federal court, the 28 complaint must “give the defendant fair notice of what the claim . . . is and the grounds upon 1 which it rests.” Bell Atlantic v. Twombly, 550 U.S. 544, 555 (2007) (internal quotations omitted). 2 “This simplified notice pleading standard relies on liberal discovery rules and summary judgment 3 motions to define disputed facts and issues and to dispose of unmeritorious claims.” Swierkiewicz 4 v. Sorema N.A., 534 U.S. 506, 512 (2002). 5 On a motion to dismiss, the factual allegations of the complaint must be accepted as true. 6 Cruz v. Beto, 405 U.S. 319, 322 (1972). A court is bound to give the plaintiff the benefit of every 7 reasonable inference to be drawn from the “well-pleaded” allegations of the complaint. Retail 8 Clerks Int’l Ass’n v. Schermerhorn, 373 U.S. 746, 753 n.6 (1963). A plaintiff need not allege 9 “‘specific facts’ beyond those necessary to state his claim and the grounds showing entitlement to 10 relief.” Twombly, 550 U.S. at 570. 11 Nevertheless, a court “need not assume the truth of legal conclusions cast in the form of 12 factual allegations.” U.S. ex rel. Chunie v. Ringrose, 788 F.2d 638, 643 n.2 (9th Cir. 1986). 13 While Rule 8(a) does not require detailed factual allegations, “it demands more than an 14 unadorned, the defendant-unlawfully-harmed-me accusation.” Iqbal, 556 U.S. at 678. A 15 pleading is insufficient if it offers mere “labels and conclusions” or “a formulaic recitation of the 16 elements of a cause of action.” Twombly, 550 U.S. at 555; see also Iqbal, 556 U.S. at 678 17 (“Threadbare recitals of the elements of a cause of action, supported by mere conclusory 18 statements, do not suffice.”). Moreover, it is inappropriate to assume the plaintiff “can prove 19 facts that it has not alleged or that the defendants have violated the . . . laws in ways that have not 20 been alleged.” Associated Gen. Contractors of Cal., Inc. v. Cal. State Council of Carpenters, 459 21 U.S. 519, 526 (1983).

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Nguyen v. The Lovesac Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nguyen-v-the-lovesac-company-caed-2025.