SAN FRANCISCO (LN) — A U.S. District Court judge on Monday granted a motion to dismiss a putative class action against Saatva, finding that the mattress retailer’s “Made in the U.S.A.” website claims did not violate a California statute limited to physical merchandise and that the plaintiff failed to plausibly allege imported components exceeded a 5 percent safe harbor.

U.S. District Judge Jacqueline Scott Corley ruled that California Business & Professions Code Section 17533.7 applies only to words appearing on “merchandise or on its container,” a definition she said does not encompass websites or television advertisements.

“Because the plain meaning of ‘container’ does not encompass websites selling or advertising merchandise or television advertisements, section 17533.7 does not apply to Saatva’s alleged statements,” Corley wrote.

The court also dismissed the plaintiff’s claims under the state’s Consumer Legal Remedies Act, False Advertising Law, and Unfair Competition Law. Corley ruled those claims were barred harbor doctrine because the plaintiff, Nancy Samberg, did not plausibly allege that foreign-sourced parts in her 2023 mattress constituted more than 5 percent of its final wholesale value.

Samberg argued that Saatva’s price increases in 2025, driven by tariffs on imported goods, suggested that foreign inputs comprised about 15 percent of the mattress’s wholesale value. Corley rejected the argument, noting that allegations regarding 2025 tariffs and pricing had “no bearing” on the composition of the mattress Samberg purchased in November 2023.

The judge also dismissed Samberg’s breach of contract claim, finding it conclusory. Corley noted that Samberg did not allege specific facts about the mattress she received to support the inference that Saatva breached its contractual obligation to provide a mattress “Made.”

Corley granted Samberg leave to amend her complaint, noting that the plaintiff stated at oral argument that a “Made in the U.S.A.” label was attached to her mattress. If such a label exists, it could potentially satisfy the “merchandise or container” requirement of Section 17533.7.

Samberg must file an amended complaint by June 12, 2026. She may not add new claims or defendants without the court’s permission.