Professional Documents
Culture Documents
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AMERICAN ARBITRATION ASSOCIATION
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AMAZON.COM, INC., a Delaware
6 corporation, No. ____________________
7 Claimant,
8 v.
10 Respondent.
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AMAZON.COM, INC.’S DEMAND FOR
12 ARBITRATION
13 Amazon.com, Inc. (“Amazon”), for its demand for arbitration, states as follows:
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I. SUMMARY
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1. Each day, millions of consumers use Amazon’s website to assist with their
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purchasing decisions. In order to make those decisions more informed, Amazon provides
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customer reviews of products and services available on Amazon.com. Amazon pioneered
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customer reviews 20 years ago and is now home to hundreds of millions of unique
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reviews. Reviews provide a forum for sharing authentic feedback about products and
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services—positive or negative. Amazon does not remove reviews because they are
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critical of products; Amazon believes all helpful information can inform its customers’
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buying decisions. Whether positive, negative, or anywhere in between, Amazon takes the
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credibility of its customer reviews very seriously.
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2. A very small minority of sellers attempt to gain an unfair competitive
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advantage by creating false, misleading, and inauthentic customer reviews for their
3 15. Sellers are clearly advised that failure to comply with the terms of the
4 Prohibited Seller Activities and Actions policy can result in cancellation of listings,
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IV. RESPONDENT’S ILLEGAL ACTS
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16. In or around August 2014, Respondent registered as an Amazon seller,
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using seller name “Arobo Trade INC/Aumax Direct.”
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17. Since that time, Respondent has created or caused to be created fake
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reviews for his product. For example, on a sample of 11 ASINs with abuse linked to
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Amazon Seller Arobo Trade, 1,269 out of 2,343 reviews were abusive (54%).
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18. At all times, Respondent knew that Amazon’s policies prohibited these
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activities, and knew and intended that his activities would lead to an increase in sales at
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the expense of Amazon’s customers. The result of these intentional efforts is the
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deception of Amazon’s customers and unfair competition with sellers on Amazon’s
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marketplace.
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FIRST CLAIM FOR RELIEF
18 Federal Unfair Competition (Lanham Act, 15 U.S.C. § 1125(a))
19 19. Amazon incorporates by reference the allegations of each and every one of
20 the preceding paragraphs as though fully set forth herein.
21 20. Respondent made false and misleading statements of fact in the
22 commercial advertisement of his products.
23 21. Those statements deceived or had the capacity to deceive a substantial
24 segment of potential consumers.
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15 26. Amazon incorporates by reference the allegations of each and every one of
17 27. Respondent established one or more Amazon seller accounts and has
21 proven at trial.
22 29. Respondent’s acts have caused irreparable injury to Amazon. The injury to
24 alone cannot fully compensate Amazon for its injuries and Amazon lacks an adequate
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