# Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 1 of 87 > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/agency%3Aftc%3Af123b32e3a0d2440 ## Record - **Collection:** Agency decision - **Document type:** Agency decision ## Text Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 1 of 87 1 2 3 4 5 6 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 7 8 9 COMPLAINT FOR PERMANENT INJUNCTION, CIVIL PENALTIES, MONETARY RELIEF, AND OTHER EQUITABLE RELIEF Plaintiff, 10 11 Civil Action No. ____________ 2:23-cv-0932 FEDERAL TRADE COMMISSION, v. AMAZON.COM, INC., a corporation, 12 Defendant. 13 14 Plaintiff, the Federal Trade Commission (“FTC” or “the Commission”), alleges: 15 1. Plaintiff brings this action under Sections 5(a), 5(m)(1)(A), 13(b), 16(a), and 19 of 16 the Federal Trade Commission Act (“FTC Act”), 15 U.S.C. §§ 45(m)(1)(A), 53(b), 57b, and the 17 Restore Online Shoppers’ Confidence Act, (“ROSCA”), 15 U.S.C. § 8404, which authorize the 18 FTC to seek, and the Court to order, permanent injunctive relief, restitution, civil penalties, and 19 other equitable relief for Defendant’s acts or practices in violation of Section 5(a) of the FTC 20 Act, 15 U.S.C. § 45(a), and Section 4 of ROSCA, 15 U.S.C. § 8403. 21 22 23 COMPLAINT Case No. _:__-cv-_____ 1 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 2 of 87 SUMMARY OF CASE 1 2 2. For years, Defendant Amazon.com, Inc. (“Amazon”) has knowingly duped 3 millions of consumers into unknowingly enrolling in its Amazon Prime service (“Nonconsensual 4 Enrollees” or “Nonconsensual Enrollment”). Specifically, Amazon used manipulative, coercive, 5 or deceptive user-interface designs known as “dark patterns” to trick consumers into enrolling in 6 automatically-renewing Prime subscriptions. 7 3. The Nonconsensual Enrollment problem was well known within Amazon. . 8 9 - ■ 10 11 12 13 4. In a draft memorandum 5. Some Amazon employees pushed the company executives responsible for 14 15 16 17 Prime—including Neil Lindsay (“Lindsay”), Russell Grandinetti (“Grandinetti”) and Jamil 18 Ghani (“Ghani”)—to address Nonconsensual Enrollment and make changes so that Amazon 19 would not be tricking its customers. 20 21 22 23 COMPLAINT Case No. _:__-cv-_____ 2 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 3 of 87 1 3 - 4 Amazon and its leadership—including Lindsay, Grandinetti, and Ghani—slowed, avoided, and 5 even undid user experience changes that they knew would reduce Nonconsensual Enrollment 6 because those changes would also negatively affect Amazon’s bottom line. 2 6. 7 8 9 7. For years, Amazon also knowingly complicated the cancellation process for 10 Prime subscribers who sought to end their membership. Under significant pressure from the 11 Commission—and aware that its practices are legally indefensible—Amazon substantially 12 revamped its Prime cancellation process for at least some subscribers shortly before the filing of 13 this Complaint. However, prior to that time, the primary purpose of the Prime cancellation 14 process was not to enable subscribers to cancel, but rather to thwart them. Fittingly, Amazon 15 named that process “Iliad,” which refers to Homer’s epic about the long, arduous Trojan War. 16 Amazon designed the Iliad cancellation process (“Iliad Flow”) to be labyrinthine, and Amazon 17 and its leadership—including Lindsay, Grandinetti, and Ghani—slowed or rejected user 18 experience changes that would have made Iliad simpler for consumers because those changes 19 adversely affected Amazon’s bottom line. 20 8. As with Nonconsensual Enrollment, the Iliad Flow’s complexity resulted from 21 Amazon’s use of dark patterns—manipulative design elements that trick users into making 22 decisions they would not otherwise have made. 23 COMPLAINT Case No. _:__-cv-_____ 3 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 4 of 87 JURISDICTION AND VENUE 1 2 9. 3 and 1345. 4 10. 5 This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1337(a), Venue is proper in this District under 28 U.S.C. § 1391(b)(2), (b)(3), (c)(1), (c)(2), (c)(3), and (d), and 15 U.S.C. § 53(b). PLAINTIFF 6 7 11. The FTC is an independent agency of the United States Government created by 8 the FTC Act, which authorizes the FTC to commence this district court civil action by its own 9 attorneys. 15 U.S.C. §§ 41-58. The FTC enforces Section 5(a) of the FTC Act, 10 15 U.S.C. § 45(a), which prohibits unfair or deceptive acts or practices in or affecting commerce. 11 The FTC also enforces ROSCA, 15 U.S.C. §§ 8401-8405, which prohibits the sale of goods or 12 services on the Internet through negative option marketing without meeting certain requirements 13 for disclosure, consent, and cancellation to protect consumers. A negative option is an offer in 14 which the seller treats a consumer’s silence—i.e., their failure to reject an offer or cancel an 15 agreement—as consent to be charged for goods and services. 16 C.F.R. § 310.2(w). DEFENDANT 16 17 12. Defendant Amazon transacts and has transacted business in this District and 18 throughout the United States. It is one of the world’s largest online retailers, and is 19 headquartered in Seattle, Washington, with its principal place of business at 410 Terry Avenue 20 North, Seattle, Washington 98109. 21 22 23 COMPLAINT Case No. _:__-cv-_____ 4 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 5 of 87 1 13. At all times relevant to this Complaint, acting alone or in concert with others, 2 Amazon advertised, marketed, distributed, or sold a paid subscription service, Prime, that gives 3 subscribers throughout the United States access to additional services otherwise unavailable or 4 available only at an additional charge to other consumers. Among other things, these premium 5 services include expedited “free” delivery of merchandise from Amazon’s vast online 6 marketplace, streaming content, and grocery delivery. COMMERCE 7 8 14. At all times relevant to this Complaint, Amazon has maintained a substantial 9 course of trade in or affecting commerce, as “commerce” is defined in Section 4 of the FTC Act, 10 15 U.S.C. § 44. DEFENDANT’S BUSINESS ACTIVITIES 11 12 13 15. Consumers pay $139 per year or $14.99 monthly to subscribe to Prime. Prime subscription fees account for $25 billion of Amazon’s annual revenue. 14 16. Approximately 70% of Amazon’s revenue comes from American consumers. 15 17. Subscribers are critical to Amazon’s overall ecommerce business because Prime 16 subscribers spend more than 17 Prime shoppers. 18 18. 19 20 - as much shopping on Amazon as compared to non- Consequently, one of Amazon’s primary business goals—and the primary business goal of Prime—is increasing subscriber numbers. 19. Within Amazon’s corporate structure, the Prime organization or department 21 (“Prime Organization”) operates Prime. Amazon evaluates the Prime Organization’s 22 performance based on the 23 . COMPLAINT Case No. _:__-cv-_____ 5 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 6 of 87 Typical Prime Enrollment Experiences 1 2 20. Consumers can subscribe to Prime through multiple pathways including through 3 Amazon devices (like the Amazon Fire TV streaming device), while using Prime Video, or 4 through Prime’s unique webpage (“Prime Central”). However, 5 the Amazon shopping checkout process. 6 21. - subscriptions occur through The basic consumer checkout enrollment experience proceeds as follows on both 7 desktop and mobile devices. Consumers who are not Prime members visit Amazon’s website— 8 www.Amazon.com—to shop. They place items in their cart, and then provide (or confirm) their 9 billing and address information. They then select a large orange “Continue” button, which 10 typically appears in the lower right corner of the page, and move through additional pages to 11 proceed with their purchase. Finally, consumers either complete their order by purchasing the 12 items in their cart or abandon their cart. 13 22. Amazon presents all consumers who are not Prime subscribers with at least one 14 opportunity (also known as an “upsell”)—and often several opportunities—to join Prime before 15 those consumers place their order on the final checkout page. Amazon has two primary types of 16 upsells that enroll consumers: interstitials and non-interstitials. An interstitial is a page that 17 interrupts consumers’ online shopping experience by appearing before the page that consumers 18 seek to access in the first place. In contrast, non-interstitial upsells are elements imbedded 19 within checkout pages, including shipping-option selection and payment pages. 20 21 22 23 COMPLAINT Case No. _:__-cv-_____ 6 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 7 of 87 1 23. 2 called the On desktop devices, Amazon has several Prime upsells: an interstitial upsell an d three non-interstitial upsells called the 3 On mobile devices, Prime upsells miITor those on desktop, an d include 4 5 6 the 24. - 7 on Desktop . Amazon calls the Prime interstitial upsell th e . Although th e - has changed over time, it generally inte1n 1pts 8 consumers' online shopping experience by presenting them with a prominent button to enroll in 9 Prime and a comparatively inconspicuous link to decline. Consumers cannot avoid th e - . The upsell forces consumers to select either the button or the link to proceed to checkout. See 11 Attachments A- D. 12 13 14 15 25. The - orange button, which enrolls a consumer in Prime if clicked, is 16 located toward the bottom right of the screen and often includes language referencing "free 17 shipping" or a "free trial." See Attachment A 18 19 20 21 See Attachments C and D. 22 23 COMPLAINT Case No. - :- -cv-- - Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 7 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 8 of 87 1 see Attachment A and B, 2 see Attachments C and D, 3 26. 4 free trial, 5 27. If a consumer clicks the orange button, Amazon enrolls the consumer in a Prime The 6 7 10 11 Attachment C. 9 12 13 14 15 16 see Attachment A, see Attachment B. See See Attachment D. 28. - - See Attachments A–D. 29. The does not adequately disclose the price of the monthly auto-renewal feature of Prime. . See Attachments A–D. 17 18 - includes language that the consumer will not receive “free shipping.” -- 8 - ’s blue link, which declines the Prime membership if clicked, 30. 19 20 21 22 23 COMPLAINT Case No. _:__-cv-_____ 8 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 9 of 87 1 2 3 4 5 6 7 8 9 11 12 13 See Attachment E . 14 15 16 17 18 19 20 21 (c) 22 23 COMPLAINT Case No. - :- -cv-- - Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 9 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 10 of 87 See Attachment E. 1 2 3 (d) 4 5 See Attachment E. 6 7 8 9 10 11 12 13 (e) - See Attachment E. (f) 14 15 16 17 18 See Attachment E. 31. 19 20 (a) 21 22 23 COMPLAINT Case No. _:__-cv-_____ 10 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 11 of 87 1 See Attachment F. 2 (b) 3 4 See Attachment F. 5 (c) 6 7 8 9 See Attachment F. 10 (d) 11 12 . See Attachment F. 13 14 15 16 17 18 19 20 21 22 23 32. Separate from the - , various Prime upsells appear as elements within the online checkout flow, which itself appears in various versions to consumers depending on factors COMPLAINT Case No. _:__-cv-_____ 11 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 12 of 87 1 (i.e., whether a consumer has previously declined a Prime upsell). 2 3 4 33. on Desktop. 5 6 7 8 9 10 11 34. 12 13 . See Attachment G, at 3–4. 14 15 16 17 18 19 20 . See Attachment G, at 4. 21 22 23 COMPLAINT Case No. _:__-cv-_____ 12 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 13 of 87 1 2 3 4 5 6 7 8 9 10 35. 11 12 13 14 See Attachment G, at 5. 36. 15 16 17 See Attachment G, at 6. 18 19 20 21 22 23 COMPLAINT Case No. _:__-cv-_____ 13 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 14 of 87 1 2 3 4 5 See Attachment G, at 7 . 6 7 8 9 11 12 13 14 15 16 39. 17 18 19 20 21 22 23 COMPLAINT Case No. - :- -cv-- - Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 14 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 15 of 87 1 2 3 41. 4 See Attachment H, at 3–4. 5 6 42. 7 8 9 10 11 12 43. See Attachment H, at 5. 13 14 15 16 17 18 19 20 21 22 23 COMPLAINT Case No. _:__-cv-_____ 15 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 16 of 87 1 2 3 4 44. 5 6 See Attachment H, 7 8 9 at 5. 45. 11 12 13 14 15 16 17 18 19 20 21 46. See Attachment H, at 5. 22 23 COMPLAINT Case No. - :- -cv-- - Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 16 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 17 of 87 1 47. 2 3 4 5 6 7 8 9 See Attachment H, at 6. 10 11 48. 12 13 49. on Desktop. See Attachments I–K. 14 15 16 17 18 19 20 21 22 23 COMPLAINT Case No. _:__-cv-_____ 17 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 18 of 87 50. 1 2 3 4 5 6 Attachment I with Attachments J and K. 7 52. 8 9 See Attachment 11 12 13 14 I, at 3. - 15 16 17 18 19 20 21 22 23 COMPLAINT Case No. - :- -cv-- - Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 18 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 19 of 87 53. 1 See Attachment K, at 4. 2 3 4 5 6 7 8 9 54. 10 See Attachment I, at 4. 11 12 55. 13 14 15 16 17 - See Attachment I, at 4. 18 19 20 21 22 23 COMPLAINT Case No. _:__-cv-_____ 19 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 20 of 87 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 56. See Attachment I, at 4. 57. See Attachment I, at 4. 16 17 18 19 20 21 22 23 COMPLAINT Case No. _:__-cv-_____ 20 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 21 of 87 1 2 3 4 5 6 58. 7 8 9 11 12 13 14 15 16 17 18 19 20 See Attachment I, at 4. 21 22 23 COMPLAINT Case No. - :- -cv-- - Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 21 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 22 of 87 1 2 3 4 5 6 7 8 9 10 11 60. 12 See Attachment J, at 7. 13 14 15 See 16 17 Attachment J, at 7. 18 19 20 21 22 23 COMPLAINT Case No. _:__-cv-_____ 22 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 23 of 87 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 - 61. See Attachment K, at 5. 62. 17 See Attachment J, at 8. 18 19 20 21 22 23 COMPLAINT Case No. _:__-cv-_____ 23 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 24 of 87 1 See Attachment J, at 8. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 63. , Prime upsells on the mobile checkout flow have mirrored those on desktop checkout, and have included the 64. . Navigating Prime upsells on mobile devices is more difficult than on a desktop. 18 Amazon often places material terms such as price and auto-renewal terms at the very bottom of 19 the mobile page—past the point viewable on the screen unless the consumer scrolls down— 20 where consumers are least likely to see this information. On mobile devices, consumers are also 21 more likely to select a prominent option without scrutinizing fine print. 22 23 COMPLAINT Case No. _:__-cv-_____ 24 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 25 of 87 1 65. Mobile (Past). 2 3 4 5 66. 6 7 See Attachment L, at 4. 8 9 10 11 12 13 14 15 16 17 18 67. 19 See Attachment L, at 5-6. 20 21 22 23 COMPLAINT Case No. _:__-cv-_____ 25 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 26 of 87 1 68. See 2 3 Attachment L, at 7. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 69. 20 See Attachment L, at 7. 21 22 23 COMPLAINT Case No. _:__-cv-_____ 26 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 27 of 87 1 70. 2 3 4 5 6 See Attachment L, at 8. 7 8 9 10 71. The - problematic elements as the 72. The on mobile devices contained similar on desktop. on mobile required consumers to either 11 accept or decline a Prime subscription before allowing them to continue shopping. See 12 Attachment M. 13 14 15 16 17 18 19 20 21 22 23 COMPLAINT Case No. _:__-cv-_____ 27 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 28 of 87 1 2 3 4 5 6 7 8 9 10 11 12 13 as - 73. The on mobile also contained similar problematic elements on desktop. 74. 14 15 16 17 - See Attachment N, at 3-4. See Attachment N, at 5-6. 75. 18 19 20 21 See Attachment N, at 7. 22 23 COMPLAINT Case No. _:__-cv-_____ 28 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 29 of 87 1 2 76. 3 4 5 6 See Attachment N, at 8. 7 8 9 10 11 12 - 77. Mobile (Current). In 2022, Amazon 78. The current mobile upsells contain many of the same problematic elements as the —including misleading language and manipulative designs—which lead 13 14 15 consumers to enroll in Prime without their consent. 79. Consumers using mobile devices to navigate to Amazon.com can select a product 16 by clicking a large yellow button (“Add to Cart”), and continue shopping, or a large orange 17 button (“Buy Now”) to proceed directly to the checkout. See Attachment O, at 1. Consumers 18 who continue shopping add additional products to their cart by clicking the large yellow “Add to 19 Cart” button, until they finish and choose another large yellow button (“Proceed to checkout”), 20 which takes the consumer to the next step. See Attachment O, at 2. 21 22 23 COMPLAINT Case No. _:__-cv-_____ 29 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 30 of 87 80. 1 At this point, the consumer signs in (if the consumer has not already) and clicks a - 2 large yellow “Continue” button to proceed to a mobile 3 signed in proceed directly to the mobile 81. 4 . Consumers who have already . Consumers without an account must create one before reaching the mobile - 5 Creating an account involves four steps: entering an email address, creating a password, and 6 adding an address and a payment method. See Attachment O, at 3-4. Completing these steps 7 takes the consumer to the mobile 82. 8 - . When a consumer reaches the mobile , Amazon divides the page, with a 9 footer (sometimes known as a “sticky footer”) that occupies the screen’s bottom half, rendering 10 only a portion of the top half visible unless the consumer scrolls down. See Attachment O, at 5. 11 ama.zon 12 .n~ ,r lflr' illirimn, ..Ii 13 14 15 16 " w •r;p giving1you 30 d,ay~ of P, i11n for FREE A.1 . your Wllhou'l Prlm1, r Tl 17 18 19 20 Get F Two•Oay Oel.t~r:,r wl h Pr•me Salil! S5.99 , m ntl!,' en th llrffi!r 21 22 23 n COMPLAINT Case No. _:__-cv-_____ 30 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 31 of 87 1 83. At the top of the mobile - , Amazon informs the consumer that “we’re giving 2 you 30 days of Prime for FREE.” See Attachment O, at 5. Smaller text below reads: “After 3 your FREE trial, Prime is just $14.99/month,” but does not reference Prime’s auto-renewal 4 feature. Consumers can view this section without scrolling. 5 . re I v111lil ri11itie for 6 7 8 9 84. The sticky footer on the lower half of the screen contains double-stacked buttons: 10 the top yellow “Get FREE Two-Day Delivery with Prime” button and an image appearing to be a 11 gray lower button labelled “Save $5.99 instantly on this order.” See Attachment O, at 5. 12 Amazon enrolls consumers who click the yellow button in Prime. As such, a consumer can 13 enroll in Prime without viewing the portion of the page that the sticky footer hides. 14 15 et F 16 5 el' ry me 17 18 19 20 21 22 23 COMPLAINT Case No. _:__-cv-_____ 31 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 32 of 87 1 85. If a consumer scrolls down, Amazon shows consumers a table comparing the 2 “Perks of Prime” with “Without Prime.” See Attachment O, at 5. For instance, perks of Prime 3 include “Fast, FREE delivery on Prime eligible items,” “[a]ll the music + top podcasts ad-free on 4 Amazon Music,” and “Prime Video – Enjoy award-winning Amazon Originals, movies and TV 5 shows” whereas without Prime, a consumer has “[m]inimum order requirements,” “[m]usic 6 listening with ads,” and Prime Video “[n]ot included.” - 7 8 9 30 10 11 12 13 14 15 16 17 18 19 20 21 22 23 COMPLAINT Case No. _:__-cv-_____ 32 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 33 of 87 1 86. The following text is visible at the bottom of the sticky footer, in the smallest type 2 on the screen: “By signing up, you acknowledge that you have read and agree to the Amazon 3 Prime Terms and . . . See all.” See Attachment O, at 5. If the consumer continues scrolling, 4 additional information about Prime’s “Terms and Conditions” and “Shipping Benefits” becomes 5 visible in small text beneath the “No thanks” link. A sentence in the middle of this additional 6 text reads: “Your Amazon Prime membership continues until cancelled. If you do not wish to 7 continue for $14.99/month plus any applicable taxes, you may cancel anytime by visiting Your 8 Account and adjusting your membership settings.” 9 Fast, FREE delivery on Minimum order requ irements Prime eligible items 10 All the music + top podcasts Music listening with ads ad-free on Amazon Music Not included Prime Video - Enjoy awardwinning Amazon Originals, 11 fi 12 movies and TV shows 13 Use my gift card balance, when ava ilable, to pay fo r Prime. 14 Get FREE Two-Day Delivery with Prime 15 Save $5.99 inst antly on t his order 16 No thanks 17 By signin g up, you acknowledge th at you have read and agree t o t he Amazon Prime Terms and Conditions and aut horize us to charge your defa ult payment method (Visa '"'- 3947) or another availab le payment m ethod on file after your 30-day free trial. Your Amazon Prime membership 18 continues until cancelled. If you do not wish to continue for $14.99/month plus any applicable taxes, you may cancel anytime by visiting Your Account and adjusting your membership settings. 19 20 For customers in Hawaii, Puerto Rico, and Alaska please vi sit the Amazon Prime Shippinq Benefits i ama zon .com 21 22 23 COMPLAINT Case No. _:__-cv-_____ 33 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 34 of 87 1 87. If a consumer clicks the downward arrow on the top right of the sticky footer, 2 Amazon also reveals the additional text beneath the “No thanks” link. The arrow is adjacent to 3 the yellow “Get Free Two-Day Delivery with Prime” button that will enroll the consumer in 4 Prime. If a consumer clicks the button while attempting to click the adjacent sticky footer arrow, 5 Amazon enrolls the consumer in Prime. 6 7 8 9 10 11 88. Consumers cannot view the full text beneath the “No thanks” link without 12 scrolling or clicking the sticky footer arrow. However, consumers can enroll in Prime by 13 selecting the large yellow “Get FREE Two-Day Delivery with Prime” button without scrolling. 14 See Attachment O, at 5. 15 16 17 89. Consumers can proceed with their purchase if they select either the yellow button or the blue “No thanks” link. See Attachment O, at 5. 90. If the consumer selects the yellow “Get FREE Two-Day Delivery with Prime” 18 button, Amazon brings the consumer to a final page with a yellow “Place your order” button and 19 “Congratulations, your Prime free trial has started! We’ll email you about all Prime benefits” 20 underneath. Therefore, Amazon enrolls the consumer in Prime before the consumer has even 21 placed the order. The final page of the flow also contains an “Order Total” that does not include 22 Prime’s price. See Attachment O, at 6. 23 COMPLAINT Case No. _:__-cv-_____ 34 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 35 of 87 1 91. On this final page, the consumer can change or confirm shipping and billing 2 information, remove products from the cart, and make other changes such as adding gift receipts 3 or providing delivery instructions. See Attachment O, at 6. The consumer can also select a 4 shipping method. 5 92. The yellow button labelled “Place your Order” allows consumers to make their 6 purchase. See Attachment O, at 6. Prime’s price and auto-renewal feature do not appear on the 7 page, the consumer cannot remove Prime, and the consumer cannot back up and choose “No 8 thanks” to Prime on the prior page. 9 93. In each pathway ( , and mobile), Amazon fails to 10 provide clear and conspicuous disclosures regarding the Prime subscription program’s material 11 terms: its price, and the fact that it renews automatically unless the consumer affirmatively 12 cancels. Furthermore, in each pathway 13 does not provide any disclosures at all before Amazon collects billing information from 14 consumers. 15 94. , and mobile), Amazon Prime Video. Prime Video is a distinct product from Prime. Specifically, Prime 16 Video is a subscription-based video streaming service. Although it is possible to sign up for 17 Prime Video alone, it is difficult to do so. 18 19 20 95. Amazon’s webpage tricked consumers into signing up for Prime instead of Prime Video, which would be a lower-cost option. 96. In particular, Amazon initially offers Prime Video as part of the full, more 21 expensive Prime package to consumers who reach the Prime Video homepage (or “storefront”) 22 to enroll in Prime Video. See Attachment P, at 1. 23 COMPLAINT Case No. _:__-cv-_____ 35 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 36 of 87 1 2 3 4 5 6 7 8 9 10 97. 11 Capitalizing on some consumers’ inability to appreciate the difference between 12 “Prime” and “Prime Video,” the Prime Video enrollment process fails to clarify Amazon will 13 enroll them in Prime rather than the less expensive Prime Video, on both desktop and mobile 14 platforms. This causes some consumers to enroll in Prime, rather than Prime Video, 15 unknowingly. 98. 16 17 Consumers can reach the Prime Video storefront through various ways, including by searching “Prime Video” in an online search engine or the Amazon search bar. 99. 18 The initial Prime Video storefront displays the Prime Video logo at the top and an 19 orange button labelled “Watch with Prime. Start your 30-day free trial.” See Attachments P and 20 V. 21 22 23 COMPLAINT Case No. _:__-cv-_____ 36 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 37 of 87 1 100. Amazon brings consumers who press the orange button to a second page and 2 prompts them to sign in (if they have an Amazon account) to confirm billing information, or to 3 create an account and submit billing information. This page also contains small print links to the 4 Amazon Prime Conditions of Use and Privacy Notice at the bottom of the page. See Attachment 5 V, at 2-5. 6 7 101. Amazon does not, to this point, present the consumer with any marketing regarding Prime, as opposed to Prime Video. 8 102. After sign in or account creation, Amazon brings consumers to a page containing, 9 from top to bottom: 10 (a) 11 trial”; 12 (b) the email associated with the account; 13 (c) a table with “Confirm your details” at the top followed by the plan type, 14 which is “Prime. Enjoy unlimited streaming of thousands of movies and TV 15 shows plus FREE Two-Day Delivery on millions of items. $14.99/month after 16 trial” (to get Prime Video rather than Prime, the consumer must click a gray 17 “change” box to the right); 18 (d) the consumer’s email, payment method, and billing address; 19 (e) at the bottom, “By signing up, you acknowledge that you have read and 20 agree to the Amazon Prime Terms and Conditions and authorize us to charge your 21 preferred card or another available credit card on file after your 30-day free trial. 22 Your Prime membership continues until cancelled. If you don’t want to continue 23 the Prime logo with “Watch now, cancel anytime. Start your 30-day free COMPLAINT Case No. _:__-cv-_____ 37 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 38 of 87 1 for $14.99/month plus any applicable taxes, you may cancel anytime by visiting 2 Your Account and adjusting your membership settings;” and 3 (f) 4 The button sits immediately above a gray area with text reading “Change or 5 cancel plan anytime. Pay later.” See Attachment P, at 2 and Attachment V, at 6. an orange button in the bottom right corner, labelled “Start your free trial.” 6 7 8 9 10 11 12 13 14 15 16 17 103. To enroll in Prime Video (instead of Prime), the consumer must click on the 18 “Change” button for the Plan information toward the top of the page, change the plan on the 19 subsequent page, and then navigate back to confirm the Prime Video selection. See Attachment 20 P, at 2 and Attachment V, at 6. 21 104. 22 23 COMPLAINT Case No. _:__-cv-_____ 38 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 39 of 87 1 See Attachment P, at 3. 2 3 4 5 6 7 8 9 10 105. After receiving the June 30, 2022 CID, Amazon changed the Prime Video 11 enrollment flow for Prime. Now, when consumers click “Start your free trial” Amazon shows at 12 least some consumers a page titled “Welcome to Prime, [name]” that describes certain Prime 13 membership services. On this page, there is no option to cancel the Prime membership. Toward 14 the bottom are two buttons: on the left “Discover Prime benefits” (gray button) takes consumers 15 to an overview of Prime-related services, and on the right “OK” (blue button) continues to the 16 Prime Video storefront. See Attachment V, at 7-8. 17 18 19 20 21 22 23 106. Prime Video (Mobile). Consumers may also enroll in Prime through Prime Video on a mobile device. 107. Like Prime Video on desktop, Prime Video on mobile tricked consumers into signing up for Prime instead of Prime Video, which would be a lower-cost option. 108. Like desktop Prime Video, the Prime Video mobile storefront displays the Prime Video logo at the top and, toward the bottom of the page, an orange button labelled “Watch with COMPLAINT Case No. _:__-cv-_____ 39 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 40 of 87 1 Prime. Start your 30-day free trial.” Above the orange button, in blue text, reads “Prime” and 2 then, in white text, “Watch for $0.00 with Prime.” See Attachment U, at 1. 3 4 5 6 7 8 9 10 11 12 13 14 109. Amazon brings consumers who press the orange button to a “Welcome” page to 15 sign in (if they have an Amazon account) to confirm billing information, or to create an account 16 and submit billing information. The page also contains links to “Amazon’s Conditions of Use 17 and Privacy Notice.” See Attachment U, at 2. 18 110. After sign in or account creation, Amazon then brings consumers to a page that 19 asks consumers to “Confirm your details,” and includes the following information from top to 20 bottom: 21 (a) 22 movies and TV shows plus FREE Two-Day Delivery on millions of items. 23 Next to “Plan” reads: “Prime. Enjoy unlimited streaming of thousands of COMPLAINT Case No. _:__-cv-_____ 40 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 41 of 87 1 ($14.99/month after trial).” Next to this text is an arrow similar to a greater-than 2 sign (“>”). 3 (b) 4 information. 5 (c) 6 Prime’s price and auto-renewal feature. 7 (d) 8 text beneath: “Change or cancel plan anytime. Pay later.” See Attachment U, at 5. The page also lists consumer’s email, payment method, and billing address There is then a link to Amazon Prime terms and conditions, as well as Toward the bottom is an orange button “Start your free trial” with black -~ 9 prime 10 Confirm your details Plan 11 Prime Enjoy ul'im- t~ streamng of tha.isands of IT10\0eS aDd TV shows pl,, l'llEE Two-DdV Deli'lefy on millt::lns of items. l$14.93/m011t11a1tor lria\l 12 > tm:iil 13 > f"'Jym('nt 111ethod Gift Caret lGi~ card batance- v.,fl 14 be used w.-.er1 a·1alab&el > BiUin,g 15 .address 16 By sigriing LIP. )'OU ack:nm-.1ed9e tra:t you have read Jnd.o,gtt'C to (h~ 11.!l'J](M'I, Pn.me T('1ffl', ,1nrl ((}(l('.:l flon.-; MOouthO Amazon Prime 12 Yo u can end your Prime members h ip by selecting the End Membership b utton on this page. 13 Paid mem bers who haven't used t heir benefits are eligible for a fuU refund of the current m e mbers hip period_ We'll process. t he re fu nd in th ree t o five business days, 14 End 'Vour Prirne Membe,ship 15 • Additional subscript ions t ied to yo ur membe r.ihip wo n't renew once you r Prime me m bership e nd s. • If your Prime me m be rsh ip 1s ass:ocia ed wit h a service yo u recerve t hrough an ot her company (such as Sp rint), cont act that company to m a nage you r Prime me m bership . • Customers who sig n u p fo r Amazo n Pri me using the Android mobile shopping app m ust mana ge the ir subsc riptio n t hrough Go ogle Subscript ion services. 16 17 To end yo ur Amazon Prime membership: 1. Go t o your Prime membe rship. 2 . Select Up da t e, C.i:ncel, ;rnd m o re, and fo ll ow the on-s.c reen instructions. 18 19 > End Your Amazon Prime Membership 123. The search bar pathway to the Iliad Flow varied somewhat depending on what 20 search the consumer ran. For instance, searching “how to turn off Prime,” or “cancel prime” 21 (rather than “how to cancel Prime”) took the consumer to a page with a link to Prime Central, 22 from which the consumer had to then locate the path to the Iliad Flow. Searching “End 23 COMPLAINT Case No. _:__-cv-_____ 45 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 46 of 87 1 Membership” took the consumer to a page with three blue links under the heading “Closing your 2 Amazon account,” and a subheading “Get information on how to close your Amazon account.” 3 The middle link was “cancel membership.” Clicking “cancel membership” did not cancel 4 membership. Instead, it took the consumer to the Iliad Flow. 5 6 7 8 124. Typing “cancel membership” in the search bar on a mobile device brought the consumer to the Iliad Flow through similar steps. See Attachment S. 125. Thus, to reach the Iliad Flow, consumers had to do one of the following: 1) contact customer service and inform a customer service agent that they wanted to cancel ■ ; 2) navigate from Amazon.com to 9 10 the Prime account management page (Prime Central), locate the “manage membership” 11 dropdown, and press a button labelled “End Membership”; or 3) search “How to cancel 12 membership” in the Amazon search bar, then move through subsequent steps to reach the Iliad 13 Flow—frequently, selecting a link reading “End Your Amazon Prime Membership” and then 14 pressing a button reading “End Your Prime Membership.” 15 126. Once consumers reached the Iliad Flow, they had to proceed through its 16 entirety—spanning three pages, each of which presented consumers several options, beyond the 17 Prime Central page—to cancel Prime. See Attachment Q. 18 127. On the first page of the Iliad Flow, Amazon forced consumers to “[t]ake a look 19 back at [their] journey with Prime” and presented them with a summary showing the Prime 20 services they used. Amazon also displayed marketing material on Prime services, such as Prime 21 Delivery, Prime Video, and Amazon Music Prime. Amazon placed a link for each service and 22 encouraged consumers to access them immediately, i.e., “Start shopping today’s deals!”, “You 23 COMPLAINT Case No. _:__-cv-_____ 46 Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 (202) 326-3320 Case 2:23-cv-00932 Document 1 Filed 06/21/23 Page 47 of 87 1 can start watching videos by clicking here!”, and “Start listening now!” See Attachment Q, at 3. 2 Clicking on any of these options took the consumer out of the Iliad Flow. 3 You still have 7 days left to enjoy your Prime benefits until the next billing cycle 4 Your benefit usage PRIM[BENEmsusrn: 5 0 6 Pac ges st,1pped for free with Prim~ Dielivery. Strice: $'29:-99- 0 FREE Retu rns FREE delivery Tuesday;, D@cemberr 2-0 ion o~de.rs shipp!i!d by Am-az,on ove r $25. Ord!i!r w ithin 8 hrs 28 mi ns Arrives bcf-ore Chrlstmia m |2 Case 2:23-cv-00932 Document 1-15 Filed 06/21/23 Page 4 of 8 amazon -_, Add a new address Use current location OR United States V Full name (First and Last name) Phone number Address Street address or P.O. Box Apt, Suite, Unit, Building (optional) City State ZIP Code _ _ v [Select 0 Make this my default address Delivery instructions (optional) Notes, preferences, access codes and more Use this address add Conditions of Use Privacy Notice > • Interest-Based Ads © 1996-2022, Amazon.com, Inc. or its affiliates |3 Case 2:23-cv-00932 Document 1-15 Filed 06/21/23 Page 5 of 8 -Oa)' Delwer)' with Pnme S.rve SS.99 Mtanll:,, on t his ,order 0ill No t h nks Sy sign"n9 up, you ackno....tedg:e lh at yoo have read ood ,agree to the Amazon Pr,me Te,m~ .ind Get FREE Two-Day De livery with Prime - Goe FREE Two-Day D:elrvery with Pi'ome o,,~ order Save $5 .99 instantly on this order No thanks Nil U nk.i ot .mks 'k~ all By $l9nii19 up. ~001 t kntwltcdg 111 I yfime T rm~ .,,d _ See up, y,ot1, c ~ tt, rt l'QU MW- r i amazon.com 1 ',,hrit:fl,... Tool~,! 1 f~,V Hf'.>lfh ... H,()u•.t''l(l(c1 (()uo')(')O~ P,-1 ~, 1(1()1...,, \m.,.,M fl,~~ .......,;on H"'""' =i,-...,,1, ... ~n,'IJ(.y,- "'"""'" Monthly $14.99 Ph-':OTh'K) Hm.irt H«N' Am,\ "'()I' l,"t..ulrl'lf,1c1 ......_,,on Rit',nM~ Zr~,i" (1"t'lo:H,,.., ~o~~~ "\;/c.-irt C,l ft Cil~ u ~n • ~ ~\ .... "''' Membership bMWil Oilte September 2, 2022 -Hello, _ _ Chetk out whats ,ncluaed w,th your P·,me m embership - - - - - - - - - - - - - - - - - - VaurPrim• EzdusN•A•w~rdJ - - - - - - - - - - - - - - - - - - - Exclusive deals for Prime members See more ways Prime members save s Chtckout OUI' e:dUSl'IO OC-A Mt for Pnme mtm~ "<> ~(IIM 1,of1lm'l'I .-.dlla.ibla Nl,.,..,,.y ~membersQttf ~tOnt•l»)'O&..c-y • |1 Case 2:23-cv-00932 Document 1-17 Filed 06/21/23 Page 3 of 6 a~zon = "-II .-,) ~t '4'1-°"' T,,d!o. I j l~ lte.:,ht Ill, 11,..,,_,1...,.-, (..,..,.....,. > r\:! ~ , , e • ,-,,..,,..,., a....... An"'"'' 11,,,, "' D,e....,,1 Ill, r.,,,,._,.-.,1 C_..,, rt.,..,.,.... , 11..,.,,e f.».,.vv.::, ,.,, I ~ " "' I ,..,.,,e ,._,.,.,._.,, U,.,..,~.t i,<>J P'rflMP'WI . :-1~~1'1 "\Jc:..., G,lk ~ud upt>J'I 11,~,..•I Min.111• Monthly $14.99 September 2, 2022 Membership Upd,lite',out~frllthod • -- M1mbt:nhlp SUdna Share your benefits Hello, Check out what's ,nclud ed w,th your Prime membership Rem ind me before renewing C so, 2012. s ~ !:,:::;=::!1n' - - - - - - - - - - - - - - - - - - - Yo ur P rime Exclusive Rew~rds - - - - - - - - End Membership 8)'8l(lil"9 ~ ~ Mlp ~ w• t0Wl«l'S$ to yo11rPrlrHl:lenffltl. See more w Exclusive deals for Prime members Ch.-dl•w•----HNi,..sct... Prlme......,...,, ' . ◄ Deals and promotions for Prime members ,_,_. I - - - - - - - - - - - - - - - - - - - P r ime Mcmb1:nhip B-1:ncfit; h • ii#'- 14iiihl·U'M-fi Fast, FREE delivery on over 100 m1l~on items ~t.WCl'lfVHy.tl'l'ISO'""" ,on,.or,tt"'n"' ~t1,.~bl('O/".NNy OJ"!o')n(l'°'l'I' ll'I :,t41Ph,t..~-~qe• Q'-.i.OrleOay011...,.,., O II! >l II, ol rm. • I |2 Case 2:23-cv-00932 Document 1-17 Filed 06/21/23 Page 4 of 6 • =======~ .=======~ J - thank you for being a member with us. Take a look back at your journey with Prime. You still have 7 days left to enjoy your Prime benefits until t he next b illing cycle Your benefit usage PR1ME BENEFITS usEo: Packages shipped for free JIOI\ PAST 12 MONTHS Movies and TV shows watched with Prime Video. You can .tart watching videos by clicking here! Q with Pnme Delivery. Start m O shopping today's dealS! Rffllind Me Later -- Cont .,ue To C.1ncel ~ I PAST io DAvs 0 • Songs listened to wrth Amazon Music Pnme. Start listening now1 Keep My Bene/ li Conhnue enjoying your delivery benefit. Prime Video and mar,y other benefits. |3 Case 2:23-cv-00932 Document 1-17 Filed 06/21/23 Page 5 of 6 • • - save $40.88 over 12 months by switching to annual payments Items tied to your Prime membership will be affected if you cancel your membership. 1. By cancelling, you will no longer be eligible for your unclaimed Prime exclusive offers. Get all the benefit s of Prime for less We'd like t o offer you the chance to enjoy all the benefits of Pr ime for only $139/year. ArQ you ;i rtudelnt7 Have an EBT card/receive government assistance? By dicking •switch tc, aMu:il payments•, yc,ur default P3Ymen1 method c,1 another available payment method on file w,U be charged S139/year plus any appl1ca01e taxes. Yo111 Pr1me membership w,u conunue until cancelled. You will Ile retunCICCI 514.!:l!:I for your '1' mmbershlp rm,w,. Keep M )' M c m bc.-,hlp 'c'oo will mntlmK! mf.,.,Jn9 ~u lf>I! benefil!~use your n'iemhersl-tip . Plll~Q and benefils will be pal.Ill!1J' Pli!N btiMf-b. Lam Mi)f 'I!'~ Cancel your Prime mcm b~r5h ip: Items tieCI to your Prirne memberShiP will be ~ttec:ted if you cancel your memberShip. Enclon ~ pternber02, 2022 YGIUl"benmb. w 1L-1 ~!i:1111.trUr wnU S~p t.tillbel'-oa.i 20:il ~ .aftr:r wtllih ~ [ aird WIii rnalbe' dldl'fl!(.I. OR E-,cil lf - Yourbenetn wlLl end lrrmedlat!ly and 'f"Uw,11 1H r,mmoed $ H .119 for tl>e l!m~n~q p ..JOd of yt>'] o~ :,nr 111mce ~ndmo,-a l!I l"ri11111~ Monl~.y Q,Jmer. C4Ch.el~ contc11t,. ~- &udlba.. (ihJrt11111!1, O,l!)r..•I ..J,11(1 "-!ll~ f tld llf1'2 ..,)ti,... ~nf fer~· lnbe•ul • 6 Pri- Ead~ Ault» f>i lu\l"' JO 11th111hl ,i See more plans Renewal Date January 24, 2023 > Update your payment method Manage Membership > Update, cancel and more Credil cards expire. Make sure you r benefits don't. Add a backup payment method today. Add a card. Ill 0 l!-rship, USmind Me tilter Remind me three days before my membership renews. When would you like to cancel? Items tied to yoor Prim,; rnemb.!nhip wlll bl!c aff«wd if you ,;,nc4'1 yow mcmb•rsltlp. 1 . By cancelling, you will no longer be ebg[ble for your unclaimed Prime exclusive offers. End on January 24, 2023 Your benefits will continue until Jam1ary 24, 2023, after which your card will not be charged. OR £11dNow • Your benefits will end itnmedjately and you will~ refunded $16.32 fw the remmn1n9 pcrtod of yoor memb~shlp. 18 Case 2:23-cv-00932 Document 1-18 Filed 06/21/23 Page 10 of 11 2·06 I) oc ~ !XI X el • 0 SG .. 98'4. I OJ 0 i amazon.com. 1njhor·1p:;1cr, Cancellation Survey ex We are sorry to see you go. Help us improve our services by taking a quick 5-minute survey. Start Survey Clicking this link wlll take you out of Amazon.com Ill 0 Qrd. m P'rrrn• 0.Hnry D'I wn 1-0) ntlUan ..._.,,. [q] _""..._. > Prtm• Yrdeo 0-,.., thou.,.,-. mitr.4n .and ...,. ,.1.... lttt- t ) V - - Explore Prime Reading - - Top Read in Prime Reading Q,d' uilimlted .'fHE P~FECT M';J'RIAGE 110 Case 2:23-cv-00932 Document 1-19 Filed 06/21/23 Page 1 of 7 ATTACHMENT S Case 2:23-cv-00932 Document 1-19 Filed 06/21/23 Page 2 of 7 how to cancel membership how do i cancel my prime membership how to cancel prime membership immediat ... how to cancel audible membership how to cancel memberships and subscriptions how to cancel kindle unlimited membership $4.99/mo. Iii amazon.com Done AV "membership" w e q a 123 memberships r t membership's u y 0 s d f g h k z x c v b n m space p search |1 Case 2:23-cv-00932 Document 1-19 Filed 06/21/23 Page 3 of 7 ,, amazon 5G • 8 V-/ - " ' prime Q how to cancel membership @ Deliver to prime Books Filters v Kindle Store 0 ALEXA'S ANSWER How to cancel member5hip? To canc el your Prime membership, visit End Your Amazon Prime MembershiR, then select End Member5hip. Paid members who haven't used their benefits are eligible for a full ref und of the current membership period. Was that answer helpful? Yes No RESULTS Sponso red Bee People and the Bugs They Love by rra,, k Mort me r ··••*81 Kindle Edition $Q 00 k.ndeunlim ited r•c2 with Kindle Unlim ited AA G (lJ |2 Case 2:23-cv-00932 Document 1-19 Filed 06/21/23 Page 4 of 7 I Q. Search Help Manage Your Prime Membership > Ed,t Membership • - • thank you for being a member with us. Take a look back at your journey with Prime. You still have 18 days left to enjoy your Prime benefits until the next billing cycle Your benefit usage PRIME BENEFITS usm: PAST 12 MONTHS I PAST 30 □Avs Movies and TV shows 0 Packages shipped for free wrth Prime Delivery. Start shopping today's deals! tQl\ Q watched with Prime ~ Video. You can start watching videos by dicking her~ 0 Songs listened to wit h Amazon Music Prime. Start listening nowt 00/tS noc /Nll.lM Add-On UibSLrlplJOn IJSDge bom Amaze,, Musi£ Unvmft~ Plott. ond Pm,w Vldfro btltJJI! 0, dta,w,el subscriptJottS.. Conunue To ,eel Keep My Beneh~ Continue enJoying your delivery benefit, Prime Video and marry other benefits Amazon ?rime Teri™ and Condtlfons Back to top |4 Case 2:23-cv-00932 Document 1-20 Filed 06/21/23 Page 6 of 9 X i amazon.com/mc/prpehnes/cancellat1on?ref_=pcen_ccn_mlct_con_cn_btn&pld=cancellauon&ep=alternat1ve_offer1fi.2.Caltematwe_martet1ng%2Cc.ancellat10n&cp=atternatwe_mark.ellng&ms3_c=fd8019f39dd132eb212fddf33cee3bdb Your Account> Manage Your Prime Membership > Edit Mem bersh ip • • save $40.88 over 12 months by switching to annual payments Get all the benefits of Prime for less We'd like to offer you the cha nce to enjoy all the benefits of Prime for only $139/year. S1N1tch to annu.al paymem:s s Are you a student? Have an EBT card/receive government assistance? By clK.kmg "Swrtch to annu.:il p.ryments", ycur dcf.lult payment method o r anot her av.11labte payment method on file ~II be ch.:irgcd $139/ yciK plus a ny applk .ible taxes. Your Prime m embership will contin ue until canceUed You will be rt>fu nded $ 16.31 for your curre nt plan. Remmd Me Latet Keep My MembershtO Remind me 3 days be.fa~ my membership rmews. Continue en1oying your delivery benefit. Prime Vidffl and many other beneflts. Amazon Prime Terms and Cond itions Sadr. to top Waiting fo, cache_, Get to Know Us Make Money with Us Amazon Payment Products Let Us Help You Carff'rs Sell products on Ama ,w n Amarnn Rewards Vis.a Signature Cards AmaLon and COVID19 Sell apps on Amazon |5 Case 2:23-cv-00932 Document 1-20 Filed 06/21/23 Page 7 of 9 i amazon.com/mc/p1peline5/canc.ella11on?ref_ =pcen_co,_of_con_cn_btn&p1d=cancelt.i11on&ep=altemawe_offer%2Ca11emawe_marketll'l9%2Ccancellat10n&lp::.a11erna1tve_market1ng&cp=altemat,ve_offer&ms3_c=dS4a8cfcc 11023d2080690b89d3dac.ab You,. Account > Manage Your Prime Membersh,p > Edit Membefship - we're sorry to see you go. Please confirm the cancellation of your membership. You could also consider the following: Remind Me Later ReniondMeLilter Remind me three diiys before my membership renews. Keep My Membership Keep ~ Membenh1p You will continue enjoying all the benefits of Prime V,ew eYeryt hing induded ln Prime Pause your Prime membership: Items tied to your Prime membership will be affected if you pause your membership. l. By pausing, you will no longer be eligible fOf your unclaimed Prime exclusive offers. Cilek here to see your offers. Pause on March 02, 2023 Your benefits access will continue until March 02. 2023. After tl\at date, your billrng and benefits will be pau~. and you will no longer be charged for your Pnme membership. Use the qud:;~resume function anytime to regain access to your Pnme benefits. learn Mo~ Pai.r..eonM,mh0l,2023 Cancel you r Prime membership: Items tied to your Prime membership will be affected if you cancel your membership. l. By cancelling, you will no longer be eligible for your unclaimed Prime exclusive offers. Pause on March 02, 2023 Your benefits ;acces5 will continue until M;arch 02. 2023. After tl\at date, your b1lltn9 and benefits. will be pau~. and you will no longer be charged fOf your Prime membership. Pau!>l!onMarch0l,2023 u~ the quick-resume function anytime to regain access to your Prime benefits. l earn Mo~ Cancel your Prime membership: Items tied to your Prime membership will be affected if you cancel your membership. l. By cancelling, you will no longer be eligible for your unclaimed Prime exclusive offers. End on March 02, 2023 Your benefits will contlflue until March 02, 2023, alter wh,ch your card will not be charged End on Marc:h 02. 2023 OR End Now Your benefiuwm l!lld lmmediatety and you will be refunded $16.31 for the remaining period of your membefship Amazon Prime Terms and Conditions |6 Case 2:23-cv-00932 Document 1-20 Filed 06/21/23 Page 8 of 9 C i amazon.com/mc/home?act1onSuccess.=true&act:ionTalcen=CancelJat10n Cance llation Survey We are sorry to see you go. Help us improve our services by taking a quick 5-minute survey. St.art Survl')" Clicking this !link will t.lke you out of .&maton .com I ...... . . . Yau • .....,. . . . . . 111. . . . . . . aitt . . . . . . . . ......... Cilnt•---~..._~......... Ctellt'«:aal |7 Case 2:23-cv-00932 Document 1-20 Filed 06/21/23 Page 9 of 9 C i amazon.com/mr/home?act1onSuce:~s=trut'&actionTaken=CancellatJOn ama ....._.....zon , @j ' := All Chn1c J .a EN . Health & Househotd Amazon Home Unique Finds Coupons Beauty & Personal care Amazon Basics Pet Supplies Pharmacy Home Improvement Smart Home Ftnd a Gift Amazon Business .. Hello, Returns Acco~sts Buy Agam ¥ & Orders "'l O , ':-! Cart Celebrate Black History Month Last Payment February 2, 2023 View all payme nt rece ipts & Cancellation confirmed Your membership has been cancelled . You may rejoin Prime at any time. Prime movies and shows you may like , see more • . (' -~ ~ , .i 0 11~ [' + Add to Watchlist + ' I :0;/ c1z1 1 I I Add to Watchlist •!-, Add a payment method Gift Cards, Vouchers & Promotional Codes I Enter Code Apply Continue Conditions of Use Privacy Notice Send Us Feedback Help © 1996-2023, Amazon.com, Inc. or its affiliates Ill a ($14.99/month after trial) Email > Payment method Gift Card (Gift card balance will be used when ava ilable) > Billing address By signing up, you acknowledge that you have read and agree to the Amazon Prime Terms and Conditions and aut horize us t o charge your pref erred card or another available credit card on file after your 30-day free trial. Your Prime membership continues unt il cancelled. If you don't want to continue for $14.99/month plus any applicable taxes, you may cancel anytime by visiting Your Account and adjusting your membership settings. Start your free trial. • Change or cancel plan anytime Pay later |5 Case 2:23-cv-00932 Document 1-21 Filed 06/21/23 Page 7 of 7 2:13 0 0 00 l!l ~ . • X 5G,, 1 95% ■ i Amazon.com: Prime Vi ... amazon.com |6 Case 2:23-cv-00932 Document 1-22 Filed 06/21/23 Page 1 of 9 ATTACHMENT V Case 2:23-cv-00932 Document 1-22 Filed 06/21/23 Page 2 of 9 |1 Case 2:23-cv-00932 Document 1-22 Filed 06/21/23 Page 3 of 9 Sign in ~ (e. Already Nve ,n M(" JOOO Add a Payment Metho:l Credit or d ebit card s Am.uon ;k(~!( m.'ljOI ((fa I ;ind ~ I C.Md( Name on card Card numb?r bpir.JliOO d..-tct Q V X)'J V Amazon Store Card Au~~ 10 M,;(h""Vt" hn,ln(ing oHr« No .,nnu.,t fN> ltoro fr,.'IIJ(t 1,,,bol1ty - le.o1mmore Gift Cards, Vouchers & Prc,motional Code.s (ont1t111fl (MdlOM-S('tflJ...,. Priv,lCyNoU c., W9b-20H Am,w,1.I. Bi!Ung.c!dress "° tW \IQ!l!f1l;; up, you c)(.blO•NW<>Qe tlt.ll ycu nM reao .llld .)Qlee the ;..n,,:uon Yume 1e f1'Yt .i•·-o {.(lt11.r tioi:,, cJl'IO -'Uthoue vs to th.l1Qe)Ou1 pre!"euedt.:nd or anOIJ'l(>f d"fcl1lab!e ued l urcl on f J2 ofte' your 30-cuy f1e1: (IIJI_ Your Prime memtershi,, continues until cancelled. II you oo,r t wa11t to COf1ti,.-J e fOI 'i 1.a..H/m on rn pk.IS a ,lf appi cal)le ta.-.es,. you may ca,xet .:t1)yti.-.e l)yviSiti119 vo-.i, Accou,n ar.o .iqusttlllf you, membership settings. Chang,t or (¥Kd plan .nytll'l'lt p~"'''' 11\ Inc. QI II\ Kldltf.tlll'l |6 Case 2:23-cv-00932 Document 1-22 Filed 06/21/23 Page 8 of 9 p r ime video - -? COf\dtOnSc,f ~ ~ )N(,! S. ~ 1':~ffd~• H