Wood v. MyPillow

Background

MyPillow, Inc. moved under Federal Rule of Civil Procedure 12(b)(6) to dismiss counts four and five of Elizabeth Wood’s complaint. The opinion identifies those claims as common-law fraud and unjust enrichment. Wood alleges that MyPillow induced purchases by advertising strikethrough prices for products that were never actually sold at the advertised, non-discounted prices. She relied on online archives concerning MyPillow’s pricing and sales history and alleged that the pricing strategy affected her and other class members.

Fraud Claim

MyPillow argued that Wood had not pleaded fraud with the particularity required by Rule 9(b). That rule requires a party alleging fraud to identify the circumstances of the alleged misconduct, including the who, what, when, where, and how. Wood conceded that she had not pleaded that MyPillow had a duty to disclose information, so the court considered only her fraud theory based on affirmative misrepresentations.

The court held that Wood’s allegations were sufficient at the pleading stage. She explained the nature of the alleged fraud, identified a specific pricing example, provided a date for her experience and a date range for the class, and cited online archives that allegedly supported her account. The court stated that Rule 9(b) does not require absolute particularity or a detailed recital of the evidence. Whether MyPillow actually sold the products at the advertised original prices could instead be decided at summary judgment or trial if Wood cannot prove her allegation.

Unjust-Enrichment Claim

MyPillow also argued that unjust enrichment is a remedy rather than an independent cause of action under California law. The court recognized that California generally does not treat unjust enrichment as a standalone cause of action. But it explained that courts may construe such a claim as a quasi-contract claim seeking restitution, meaning repayment to prevent a defendant from retaining a benefit unfairly when no valid contract governs.

The court found Wood’s allegations sufficient under that theory. She alleged that MyPillow’s misrepresentations induced her and other class members to purchase products and allowed MyPillow to retain revenue from those purchases. The court concluded that these allegations stated a quasi-contract claim for restitution.

Ruling and Case Management

The court DENIED MyPillow’s motion to dismiss. This ruling allowed the challenged claims to survive the pleading stage; it did not decide whether Wood will ultimately prove the alleged fraud or obtain restitution. The court also RESET the case management conference to September 29, 2026, at 2:00 p.m., and DIRECTED the parties to file a joint case management statement by September 22, 2026.