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.
11 Respondent.
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AMAZON.COM, INC.S
13 DEMAND FOR ARBITRATION
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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 Amazons websites to assist with their
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purchasing decisions. In order to make those decisions more informed, Amazon provides
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Amazon Best Sellers, best-seller lists of all the products in the Amazon marketplace,
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including general merchandise, physical books and the e-books sold in the Kindle Store.
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The Kindle Store is home to hundreds of thousands of authors and millions of e-books.
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2. One segment of books available in the Kindle Store are books self-
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published on Amazons Kindle Direct Publishing (KDP) service and sold by Amazon
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Digital Services LLC and other Amazon affiliates on various Amazon websites. Authors
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and publishers who use this service to deliver their books to their readers agree to the
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KDP terms and conditions.
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14 Exhibit 3.
15 16. Amazon takes the integrity of Amazon Best Sellers very seriously.
16 Amazon has developed sophisticated technologies and protocols to detect and remove
17 products from the Kindle Store whose Amazon Best Seller rank is the result of a
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fraudulent promotion or sale to false email address.
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IV. RESPONDENTS ILLEGAL ACTS
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17. On or around March 14, 2016, Respondent registered the Thomas Glenn
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Amazon account. In creating the Thomas Glenn Amazon account, Respondent agreed to
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Amazon Conditions of Use.
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18. On information and belief, Respondent has caused to be created fake
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Amazon Kindle Store users.
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