Night and Day Furniture vs. Tianjin Mojia: Default Judgment & Permanent Injunction in Cabinet Bed Patent Case

In a decisive outcome for U.S. furniture patent holders asserting rights against foreign e-commerce sellers, the U.S. District Court for the Eastern District of Missouri entered a default judgment and permanent injunction against Tianjin Mojia E-Commerce Co., Ltd. in favor of Night and Day Furniture, LLC. The ruling, issued on February 11, 2026, found willful infringement of U.S. Patent No. 9,993,088 — a patent covering foldable chest and cabinet bed furniture systems — and commanded major online marketplaces including Amazon, Walmart, and Overstock to delist and cease fulfillment of the accused products.

This case exemplifies a growing enforcement pattern in which domestic furniture IP holders pursue Chinese e-commerce sellers distributing infringing products through U.S. digital marketplaces. For patent attorneys, IP professionals, and R&D teams in the furniture and consumer products space, Night and Day Furniture, LLC v. Tianjin Mojia E-Commerce Co., Ltd. (Case No. 4:23-cv-00176) offers a substantive roadmap for asserting and defending furniture product patents in the current enforcement landscape.

Case Overview

The Parties

The Patent at Issue

This landmark case involved U.S. Patent No. 9,993,088 (Application No. 14/809,736), which covers furniture objects designed for storing foldable beds. In plain terms, the patent protects a cabinet or chest-style enclosure that transitions between a closed position — forming a secure enclosure for a foldable mattress — and an open position that creates a functional sleeping platform capable of supporting that mattress. The dual-state design is the core inventive concept distinguishing this product from conventional furniture. Patents are registered with the U.S. Patent and Trademark Office (USPTO) and protect ornamental appearance rather than functional technology.

• • US 9,993,088 — Foldable chest and cabinet bed furniture systems

The Verdict & Legal Analysis

Outcome

Judge Ross granted Night and Day Furniture’s motion for default judgment in its entirety, entering judgment on all counts of the amended complaint. The court found Tianjin Mojia liable for willful patent infringement of U.S. Patent No. 9,993,088 under 35 U.S.C. § 271 for making, using, offering for sale, selling, and/or importing the accused products into the United States. Specific damages figures were not disclosed in the available case data; however, the scope of equitable relief granted was expansive and consequential.

Injunctive Relief

The permanent injunction issued under 35 U.S.C. § 283 is notably broad in scope:

• Party scope: Covers Tianjin Mojia and all affiliated entities, successors, assigns, and anyone acting in concert with it.
• Conduct scope: Prohibits all direct and indirect infringement acts — including making, importing, selling, offering for sale, advertising, and marketing — of any foldable chest or cabinet bed products incorporating the ‘088 Patent, and any products “substantially similar to or not colorably different from” the accused products.
• E-commerce enforcement: Directs named marketplace operators — Amazon, Walmart, Bed Bath & Beyond (Beyond, Inc.), and Overstock (Beyond, Inc.) — to permanently remove all listings of enjoined products and cease fulfillment upon Plaintiff’s request. Operators in possession of enjoined products may also be directed to sequester and surrender inventory to Plaintiff.

Verdict Cause Analysis

The infringement finding under 35 U.S.C. § 271 rested on the accused products’ structural and functional correspondence to the ‘088 Patent’s claims — specifically the open/closed configuration that forms an enclosure for a foldable mattress (closed) and a sleeping platform (open). Because the defendant defaulted, there was no contested claim construction, no invalidity defense, and no non-infringement argument presented. The plaintiff’s unrebutted technical showing carried the motion.

The willfulness finding carries significant strategic weight. A willfulness determination under Halo Electronics v. Pulse Electronics (2016) supports enhanced damages up to three times actual damages under 35 U.S.C. § 284 — a powerful deterrent and a meaningful lever if Plaintiff pursues further damages proceedings.

Legal Significance

The case reinforces several important principles for furniture patent litigation:

• Default judgment remains a viable enforcement tool against non-appearing foreign defendants, provided the plaintiff substantiates its infringement claims with adequate technical and legal support.
• E-commerce platform injunctions are increasingly being incorporated into patent default judgments, reflecting courts’ recognition that marketplace delisting is a practical enforcement mechanism where traditional collection may be difficult.
• Willfulness findings on default create a record supporting enhanced damages claims, even when the defendant is absent.