The U.S. Court of Appeals for the Federal Circuit issued a decision February 2, 2026, affirming a lower court ruling in a complex international trade case involving antidumping and countervailing duties on mattresses imported from multiple countries. The case, *In re United States* (Fed. Cir. 2026), represents the latest development in a years-long trade dispute that has significant implications for the domestic mattress industry.
The Federal Circuit's decision upholds a December 19, 2023, ruling by the U.S. Court of International Trade that sustained the International Trade Commission's final injury determination. The Commission had found that a U.S. industry was materially injured by imports of mattresses sold at less than fair value from Cambodia, Indonesia, Malaysia, Serbia, Thailand, Turkey, and Vietnam, as well as by subsidized imports from China.
The original Commission determination, published in the Federal Register on May 14, 2021, concluded that these imports caused material injury to domestic mattress manufacturers. This finding is crucial in antidumping and countervailing duty cases, as it must be established alongside the existence of dumping or subsidization for duties to be imposed.
Circuit Judge Dyk authored the opinion for a three-judge panel that also included Circuit Judges Taranto and Chen. The court noted that this case serves as a companion to another decision issued the same day in case No. 2025-127, suggesting the Federal Circuit addressed related trade issues involving similar legal or factual questions.
The appeal arose from proceedings before Judge Stephen A. Vaden at the Court of International Trade in case No. 1:21-cv-00288-SAV. The International Trade Commission was represented by attorneys from its Office of General Counsel, including Courtney Sheehan McNamara, who argued the case, along with Margaret D. MacDonald, Karl von Schriltz, and Loren Misha Preheim.
The case attracted significant attention from outside parties, with multiple amicus curiae briefs filed. Andrew J. Dhuey, an attorney from Berkeley, California, argued as amicus curiae representing himself and was also represented by Bridget Anne Clarke. Additionally, Alexandra H. Moss from the Public Interest Patent Law Institute in La Quinta, California, served as amicus curiae counsel.
Antidumping cases like this one are designed to protect domestic industries from unfair foreign competition. When foreign manufacturers sell products in the U.S. market at prices below what they charge in their home markets or below their cost of production, it constitutes dumping. Similarly, countervailing duties address subsidized imports where foreign governments provide financial assistance to their domestic producers.
The mattress industry case spans eight countries across multiple continents, reflecting the global nature of modern manufacturing and trade. The countries involved - Cambodia, China, Indonesia, Malaysia, Serbia, Thailand, Turkey, and Vietnam - represent major textile and furniture manufacturing centers where labor and production costs may be significantly lower than in the United States.
For a successful antidumping or countervailing duty case, the Commission must find both that dumping or subsidization occurred and that it caused material injury to the competing domestic industry. The injury analysis typically examines factors such as declining market share, reduced profits, plant closures, and employment losses among domestic producers.
The Court of International Trade's 2023 decision to sustain the Commission's injury determination was significant for domestic mattress manufacturers who had sought relief from what they characterized as unfairly priced imports. The Federal Circuit's affirmation of that ruling provides additional legal certainty for the imposition of antidumping and countervailing duties on the subject imports.
The opinion notes that some information disclosed in the Court of International Trade's decision had been treated by the Commission as confidential business information. This is typical in trade cases where companies submit sensitive commercial data in response to Commission questionnaires during investigations.
The Federal Circuit's jurisdiction over appeals from the Court of International Trade in customs and trade cases makes it the primary appellate venue for significant trade disputes. The court's expertise in these complex areas of law provides important guidance for future trade cases involving similar legal and economic issues.
This decision adds to the substantial body of precedent governing how injury determinations are made in antidumping and countervailing duty cases. The ruling may influence how future cases involving multiple countries and complex injury analyses are adjudicated.
The practical impact of this decision extends beyond the immediate parties to affect the broader mattress industry, importers, retailers, and consumers. The sustained injury finding supports the continued imposition of duties designed to level the playing field between domestic and foreign mattress manufacturers.
As global trade continues to evolve, cases like this one highlight the ongoing tensions between free trade principles and the protection of domestic industries from what regulators determine to be unfair foreign competition.