Auction Sentinel 22-2-12548 9

1 FILED
2022 AUG 09 09:00 AM

2 KING COUNTY
SUPERIOR COURT CLERK
3 E-FILED
CASE #: 22-2-12548-9 SEA
4
7 SUPERIOR COURT OF THE STATE OF WASHINGTON

KING COUNTY
8
9 AMAZON.COM, INC., a Delaware corporation;

and AMAZON.COM SERVICES LLC, a
10 Delaware limited liability company, No.
11
Plaintiffs, COMPLAINT FOR DAMAGES
12 AND INJUNCTIVE RELIEF
v.
13
TREY KING, an individual; SENTINEL
14
SOLUTIONS LLC, a Massachusetts limited
15 liability company; and DOES 1-5, d/b/a
auctionsentinel.com, AuctionSentinel Group, and
16 Auction Sentinel LLC;
17 Defendants.
18
19 COMPLAINT
20 Plaintiffs Amazon.com, Inc. and Amazon.com Services LLC (collectively, “Amazon”)
21 bring this action against defendants Trey King; Sentinel Solutions LLC; and Does 1–5
22 (collectively, “Defendants”), who are responsible for the website AuctionSentinel.com (“Auction
23 Sentinel”), for injunctive relief and damages as follows:
24 I. SUMMARY
25 1. Every day, millions of consumers who shop in Amazon’s stores use customer
26 product reviews or seller feedback to assist with purchasing decisions. Customer trust and fair
27 competition in Amazon’s stores depend, in part, on the authenticity of those reviews and
Davis Wright Tremaine LLP
920 Fifth Avenue, Suite 3300
COMPLAINT - 1 Seattle, WA 98104-1610
206.622.3150 main · 206.757.7700 fax
1 feedback. The bad actors who pay for product reviews and seller feedback erode that customer
2 trust, compete unfairly with the millions of honest entrepreneurs who sell in Amazon’s stores,
3 and tarnish Amazon’s brand.
4 2. Customers can review the products they purchase in Amazon’s stores. Such
5 reviews describe the products’ quality, function, or usefulness, among other things. Customers
6 can also review their fulfilment experience with sellers by providing ratings and comments under
7 “seller feedback.” Seller feedback is intended to cover the experience provided by sellers, in
8 terms of reliability, quality, and overall order experience.
9 3. Amazon devotes extensive efforts to combat product reviews and seller feedback
10 that are false, inauthentic, or incentivized (collectively, “fake reviews” and “fake feedback”).
11 Incentivized reviews and feedback that are not identified as such are inherently false and
12 misleading because they are motivated by compensation, withhold that key information from
13 consumers, and therefore are likely to mislead consumers into believing they are unbiased and
14 independent.
15 4. Despite Amazon’s efforts, fake reviews and fake feedback persist because
16 schemes like paying for five-star reviews or feedback are organized and orchestrated largely on
17 third-party websites such as Auction Sentinel, or in dedicated groups on social media sites, as
18 opposed to within Amazon’s stores where the fake reviews and feedback are ultimately posted.
19 5. Amazon is bringing this action against the owners and operators of Auction
20 Sentinel, which sells fake 5-star “verified feedback” to Amazon sellers in order to artificially
21 inflate sellers’ feedback ratings in the Amazon.com store (“Amazon Store”). Defendants are
22 actively deceiving Amazon’s customers and tarnishing Amazon’s brand for their own profit, as
23 well as for the profit of dishonest sellers.
24 6. Auction Sentinel’s business model is based on providing services that are unfair
25 to customers, to honest Amazon selling partners, and to Amazon itself. Defendants’ services
26 violate Amazon’s policies and contracts with sellers and buyers, which prohibit, among other
27 things, providing payment or incentives for reviews or feedback.

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1 7. Auction Sentinel boasts that it provides services to “thousands of Amazon
2 sellers.”1 As shown on the following excerpt from its website, Auction Sentinel offers sellers a
3 number of packages for so-called “verified feedback” at different price points:
10
11
12
13 8. Auction Sentinel’s website promises sellers: “We make real purchases on your
14 Amazon account and turn them into 5 Star Positive Feedback.”2 Contrary to Defendants’
15 statement, the “purchases” that Auction Sentinel makes from the sellers’ accounts are not real—
16 the transactions are fraudulent and designed to deceive Amazon and its customers.
17 9. Auction Sentinel first instructs the seller to create the false appearance that the
18 seller is selling and shipping a particular product in the Amazon Store by listing pre-selected
19 products provided by Auction Sentinel. But the low-cost items that Auction Sentinel
20 recommends that the seller pretend to list, sell, and ship are not in the seller’s stock. Auction
21 Sentinel then poses as a customer purchasing the (nonexistent) product from the seller. After
22 Auction Sentinel and the seller have created the appearance in Amazon’s system of a real
23 product order and shipment, Defendants leave a five-star feedback rating for the seller under a
24 fake customer name.
25
26
1
https://www.auctionsentinel.com/feedback (accessed June 28, 2022).
27 2
Id.

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1 10. Auction Sentinel guarantees sellers that they “will only experience positive
2 results.”3 Auction Sentinel can make this guarantee because it is the one providing the fake
3 positive feedback in exchange for payment from unscrupulous sellers.
4 11. On information and belief, Defendants knew at all times that Amazon
5 contractually prohibits users of its services from, among other things, “offer[ing] request[ing], or
6 accept[ing] compensation for creating, editing, or posting content,” and against “post[ing] from
7 multiple accounts.”4 Defendants breached those obligations by, among other things, using fake
8 customer accounts to post fake seller feedback.
9 12. Defendants also knew at all times that Amazon’s contracts with sellers prohibit
10 fake seller feedback, and thus Defendants were incentivizing sellers to violate their contracts
11 with Amazon. For example, Auction Sentinel advertises that using their fake feedback service
12 may allow sellers to avoid account suspensions that may otherwise occur.5 In an effort to avoid
13 Amazon’s detection systems for fake feedback, Auction Sentinel also advises sellers that it
14 delays and spreads out the timing of when it posts the feedback: “After a few days we will
15 slowly drip the feedback onto your account until the project is complete.”6 Auction Sentinel
16 assures sellers that Amazon will not “flag” their accounts for using Auction Sentinel.7
17 13. Defendants also offer additional services that are damaging to Amazon, its
18 customers, and its honest selling partners. For example, Auction Sentinel advertises a so-called
19 “Stealth Account Setup Service.”8 The Auction Sentinel website purports to assist in creating
20 “stealth” selling accounts for sellers whose accounts have been suspended, blocked, or shut
21 down by Amazon because of violation of Amazon policies, or who wish to create multiple
22
23 3
Id.
4
“Conditions of Use,”
24 https://www.amazon.com/gp/help/customer/display.html?nodeId=GLSBYFE9MGKKQXXM (accessed June 28,
2022).
25 5
https://www.auctionsentinel.com/feedback (accessed June 28, 2022).
6
26 Id.
7
Id.
27 8
https://www.auctionsentinel.com/us-amazon (accessed June 28, 2022).

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1 selling accounts in violation of Amazon’s policies. The website explains that “stealth accounts”
2 “simply means accounts that amazons [sic] system cant [sic] connect/link to your others.”9 In
3 other words, Auction Sentinel assists in the creation of fraudulent selling accounts for Amazon
4 sellers who, for any number of reasons, would otherwise be ineligible to create a new selling
5 account.
6 14. Auction Sentinel explains the reasons sellers might be interested in this service,
7 all of which violate Amazon policies:10
10
11
12
13
14
15 15. Through the above-described actions and others, Defendants intentionally mislead
16 and cause harm to Amazon, its customers, and its honest selling partners.
17 16. In this action, Amazon brings claims for violations of the Washington Consumer
18 Protection Act (RCW Ch. 19.86), and Washington common law.
19 II. JURISDICTION AND VENUE

20 17. This Court has personal jurisdiction over Defendants, all of whom have conducted
21 business activities in and directed to Washington and are primary participants in tortious acts in
22 and directed to Washington. Defendants affirmatively undertook to manipulate seller feedback in
23 stores operated by Amazon, a corporation with its principal place of business in Washington, and
24 posted the fake feedback in the Amazon Store. Defendants also sold “stealth” Amazon seller
25 accounts for operation in the Amazon Store. Defendants’ acts deceived consumers who
26
9
Id.
27 10
Id.

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1 purchased products in the Amazon Store and harmed Amazon. Defendants knowingly committed
2 or facilitated the commission of tortious acts in and directed to Washington and have wrongfully
3 caused Amazon substantial injury in Washington.
4 18. Personal jurisdiction is also proper in this Court because Defendants consented to
5 exclusive jurisdiction in the state and federal courts of King County, Washington, when they
6 agreed to Amazon’s Conditions of Use in order to create customer accounts and post seller
7 feedback in the Amazon Store, among other activities.
8 19. Venue is proper in this Court pursuant to RCW §§ 4.12.010–.025 in that a
9 substantial part of the events or omissions giving rise to the claims pled herein occurred in King
10 County, Amazon seeks damages for personal injury or damage to personal property in King
11 County, and Amazon’s causes of action arose in King County. Venue is also proper because
12 Defendants consented to jurisdiction in this Court as set forth in Paragraph 18.
13 III. THE PARTIES

14 20. Amazon.com, Inc. is a Delaware corporation with its principal place of business
15 in Seattle, Washington. Amazon.com Services, LLC is a Delaware company with its principal
16 place of business in Seattle, Washington. Amazon owns and operates the Amazon Store and
17 website and equivalent international stores and websites. Amazon has over three hundred million
18 active customers.
19 21. Defendant Trey King is the Chief Executive Officer of Auction Sentinel. He is the
20 owner and operator of AuctionSentinel.com. On information and belief, King is a resident of
21 Rhode Island.
22 22. Defendant Sentinel Solutions LLC is a limited liability company organized in
23 Massachusetts. Sentinel Solutions LLC has a principal place of business at 185 Mediterranean
24 Dr., Apt. 39, Weymouth, Massachusetts 02188, and the Massachusetts Secretary of State
25 identification number 001403457. On information and belief, Defendant Trey King is the owner
26 of Sentinel Solutions LLC. On further information and belief, Sentinel Solutions LLC is
27 responsible with Mr. King and the Doe Defendants for operating AuctionSentinel.com.
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1 23. The “Terms and Conditions” page for AuctionSentinel.com identifies Auction
2 Sentinel LLC as an entity responsible for the website. However, Amazon has not been able to
3 locate any entity registered under the name “Auction Sentinel LLC” doing business in the United
4 States.
5 24. Amazon is unaware of the true names and capacities of Defendants sued herein as
6 Does 1–5 d/b/a AuctionSentinel.com, AuctionSentinel Group, and Auction Sentinel LLC, and
7 therefore Amazon sues these Defendants by such fictitious names. Amazon will amend this
8 complaint to allege their true names and capacities when ascertained. Amazon is informed and
9 believes and therefore alleges that each of the fictitiously named Defendants, along with the
10 named Defendants, are responsible in some manner for the occurrences alleged and that
11 Amazon’s injuries as herein alleged were proximately caused by said Defendants.
12 IV. AMAZON’S PRODUCT REVIEW AND SELLER FEEDBACK SYSTEMS

13 25. Amazon pioneered online customer reviews 25 years ago, and Amazon stores are
14 now home to billions of unique reviews. Reviews provide a forum for customers to share
15 authentic opinions about products—positive or negative. As long as Amazon’s customers abide
16 by Amazon’s Community Guidelines,11 which prohibit illegal, obscene, infringing, and other
17 abusive reviews, they may review and rate any product available in Amazon’s stores. Amazon
18 does not remove reviews if they are critical of the product; Amazon believes all helpful
19 information relevant to a product can inform its customers’ buying decisions.
20 26. Each product review is comprised of a “star rating” that ranges from one star to
21 five stars and can also include textual comments and product images or video. Amazon compiles
22 these product reviews, summarizes the compiled star ratings, and displays those results alongside
23 the listed product for shoppers to see while they are shopping.
24
25
26 11
“Community Guidelines,”
https://www.amazon.com/gp/help/customer/display.html?nodeId=GLHXEX85MENUE4XF (accessed June 28,
27 2022).

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1 27. In addition to product reviews, Amazon also gives customers the opportunity to
2 provide a more general evaluation of the customer’s order and fulfilment experience with a
3 particular seller by providing a seller feedback rating. To leave a feedback rating for a seller, a
4 customer must purchase a product from the seller. After making a purchase, customers can leave
5 feedback by accessing their “Orders” page, and then clicking on the specific order, followed by
6 the link “Leave Seller Feedback.” Buyers can submit one feedback rating per order. Like a
7 product review, seller feedback consists of a rating of one to five stars and can be accompanied
8 by comments. Customers have 90 days from the order date to leave their feedback rating and
9 comments.
10 28. Below is an example of an excerpt from a seller page where a customer can leave
11 seller feedback:
12
13
14
15
16
17
18
19
20 29. The seller’s overall feedback rating is displayed beneath the seller’s name on the
21 seller’s public profile page.
22 30. Product reviews and seller feedback can both impact a seller’s sales in multiple
23 ways. Most immediately, positive product reviews can encourage customers to purchase a
24 particular product from a seller, while positive seller feedback can encourage customers to make
25 purchases from that seller. In addition, product reviews can influence a product’s sales ranking:
26 Amazon records and publishes “rankings” of products sold in its stores, which are based on
27 sales. Amazon uses product sales data to create its Best Seller Rank (“BSR”), and also provides
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1 best seller lists for categories and subcategories of products. This information is updated hourly
2 to reflect recent and historical sales of nearly every product sold.
3 31. Seller feedback similarly can influence a seller’s ranking. This information helps
4 consumers understand which sellers provide the best service, information that may help
5 influence shopping decisions. As such, positive seller feedback can indirectly increase a seller’s
6 rank.
7 32. Conversely, negative seller feedback may indirectly lower a seller’s rank. A high
8 proportion of negative feedback also may result in Amazon restricting a seller’s privileges,
9 including suspension of seller-fulfilled orders. Accordingly, by creating fake positive feedback
10 for sellers, Auction Sentinel fraudulently reduces those sellers’ negative feedback rates, and
11 thereby helps them evade consequences for poor customer service.
12 33. Manipulating seller feedback can also help sellers unfairly take advantage of
13 perks in the Amazon Store, including the likelihood that a seller’s products are selected as
14 “Featured Offers.” “Featured Offers” are offers for additional products that Amazon displays on
15 a product detail page with an “Add to Cart” button that customers can use to add items to their
16 shopping carts. Because the seller’s quality of customer service is considered (among other
17 things) by Amazon in selecting “Featured Offers,” procuring fake positive feedback increases the
18 likelihood a seller will be selected for this perk.
19 V. BUYER AND SELLER POLICIES AGAINST FAKE REVIEWS AND FAKE

FEEDBACK, AND AMAZON’S PREVENTION EFFORTS
20
34. Amazon strictly prohibits any attempt to manipulate customer reviews and
21
feedback and expressly prohibits compensated reviews and feedback.
22
35. In order to review a product or provide seller feedback, an individual must have
23
an Amazon customer account. To sign up for an Amazon customer account, a user must
24
affirmatively agree to the Conditions of Use of the Amazon Store. As a result, each person who
25
26
27
206.622.3150 main · 206.757.7700 fax
1 reviews products or provides seller feedback has agreed to and is bound by Amazon’s Conditions
2 of Use.12
3 36. By agreeing to the Conditions of Use, each feedback provider enters into a
4 contractual relationship with Amazon.
5 37. The Conditions of Use provide that in posting content on the Amazon Store, such
6 content is accurate and will not cause injury to any person or entity.
7 38. Furthermore, any person who uses Amazon’s “community features”—which
8 include providing reviews and star ratings—agrees to and is bound by Amazon’s Community
9 Guidelines.13
10 39. Amazon’s Community Guidelines further prohibit:
11 • Creating, editing, or posting content about the seller’s own products or services.
12 • Creating, modifying, or posting content in exchange for compensation of any kind
or on behalf of anyone else.
13
• Offering compensation or requesting compensation in exchange for creating,
14 modifying, or posting content.14
15 40. Separately, each seller who lists a product for sale in the Amazon Store has
16 agreed to and is bound by the Amazon Services Business Solutions Agreement (“BSA”).15
17 41. By agreeing to the BSA, each seller enters into a contractual relationship with
18 Amazon. Amazon prohibits sellers’ use of fake reviews and fake feedback, as clearly provided in
19 its Community Guidelines quoted above, which are part of the BSA.
20 42. In addition, Amazon’s Seller Code of Conduct, which is also incorporated into the
21 BSA, makes clear that sellers “may not attempt to influence or inflate customers’ ratings,
22 feedback, and reviews.”16 Among the conduct the Seller Code of Conduct prohibits is
23 12
“Conditions of Use.,”
https://www.amazon.com/gp/help/customer/display.html?nodeId=GLSBYFE9MGKKQXXM (accessed June 28,
24 2022).
13
Community Guidelines.
25 14
Id.
26 15
“Amazon Services Business Solutions Agreement,”
https://sellercentral.amazon.com/gp/help/external/G1791?language=en_US (accessed June 28, 2022).
27 16
Id.

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1 “[p]ay[ing] for or offer[ing] an incentive (such as coupons or free products) in exchange for
2 providing or removing feedback or reviews” and “[r]eview[ing] your own products or a
3 competitors’ products.”17
4 43. Thus, the contracts that govern sellers’ and customers’ access to using the
5 Amazon Store clearly prohibit the parties from creating, posting, offering, or soliciting fake
6 reviews and feedback.
7 44. Unfortunately, at times, unscrupulous sellers try to gain unfair competitive
8 advantages in Amazon’s stores by paying for false, misleading, and inauthentic product reviews
9 and seller feedback. Fake reviews and feedback can significantly undermine the trust that
10 consumers, sellers, and manufacturers place in Amazon, which in turn tarnishes Amazon’s
11 brand.
12 45. Amazon takes the integrity of its customer reviews and seller feedback extremely
13 seriously. When it detects potentially abusive or otherwise objectionable reviews or feedback,
14 Amazon takes steps to protect customers through a variety of enforcement actions, such as
15 preventing further reviews and feedback from that customer, removing reviews and feedback,
16 and enforcing against associated seller and customer accounts. Amazon is constantly innovating
17 to improve its ability to identify and remove fake reviews and feedback, but when that abuse
18 takes place away from Amazon’s websites, bad actors are emboldened to act in direct
19 contravention of Amazon’s policies and the law.
20 VI. DEFENDANTS’ DECEITFUL ACTS

21 46. Beginning at a time unknown to Amazon, Defendants obtained the domain name
22 AuctionSentinel.com, a website through which they operate their illicit business of selling fake
23 seller feedback to Amazon sellers.
24 47. Auction Sentinel expressly targets its services to Amazon sellers. Through the
25 Auction Sentinel website, Amazon sellers pay Defendants for a set number of fake feedback
26
27 17
Id.

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1 ratings (which it calls “verified feedback”) for prices ranging from $200 to $700, in order to
2 manipulate their ratings.
3 48. After an Amazon seller selects a fake feedback package on Auction Sentinel,
4 Defendants provide the seller with a list of inexpensive products and their associated Amazon
5 Standard Identification Numbers (“ASINs”).18 Defendants instruct the seller to list some of those
6 items on its seller page, though there is no need for the seller to actually stock the items.
7 Defendants then pretend to purchase those products from the seller. Auction Sentinel charges
8 sellers both for its “feedback package” and for the cost of the items that Defendants “purchase.”
9 Defendants do not actually buy any products from the seller. Rather, they only create the
10 appearance of a purchase in the Amazon Store so they can leave fake feedback for the seller.
11 49. Auction Sentinel then provides the seller with a number of options to create the
12 false appearance in Amazon’s system that it is shipping the products to Auction Sentinel, such as
13 by creating fake tracking numbers, or sending Auction Sentinel empty envelopes to generate
14 actual tracking numbers. Auction Sentinel gives sellers a variety of tips on how to “get away”
15 with using fake or made-up tracking numbers without being detected by Amazon. The seller
16 does not actually provide Auction Sentinel with the products that Auction Sentinel appears to
17 “purchase.”
18 50. After the orders are placed and the illusion of shipment has been created,
19 Defendants, using customer accounts on the Amazon Store, pose as customers and provide the
20 agreed-upon number of five-star feedback ratings for the seller in order to boost the seller’s
21 feedback rating.
22 51. Auction Sentinel also offers additional services that aim to help sellers violate
23 Amazon’s policies and avoid detection, such as its so-called “Stealth Account Setup Service.”19
24 The website purports to assist in creating “stealth” selling accounts for sellers whose accounts
25
26 18
An “ASIN” is a unique series of ten alphanumeric characters that is assigned to each product listed for sale on
Amazon’s stores for identification purposes.
27 19

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1 have been suspended, blocked, or shut down by Amazon because of violation of Amazon
2 policies or for other reasons, or who wish to create multiple selling accounts in violation of
3 Amazon’s policies.20 Auction Sentinel is not only aware that this service violates Amazon
4 policies and the BSA, but informs sellers that it can help them evade Amazon’s identity
5 verification processes.
6 52. Auction Sentinel boasts that “[i]t does not matter if some of the [identity]
7 information you have is already used on a prior account. We have work arounds for that which
8 work flawlessly so amazon can not [sic] link you.”21
9 53. Upon information and belief, Defendants know that Amazon maintains
10 contractual relationships with sellers and with reviewers.
11 54. Upon further information and belief, Defendants also know that Amazon’s
12 policies (and thus contracts with sellers and reviewers) prohibit fake feedback and stealth
13 accounts and know and intend that their efforts in encouraging such fake feedback and stealth
14 accounts violate Amazon’s policies and improperly manipulate seller feedback ratings.
15 VII. REPUTATIONAL HARM TO AMAZON AND HARM TO THE PUBLIC

16 55. Fake reviews and feedback significantly undermine the trust that customers,
17 sellers, and manufacturers place in Amazon, which in turn tarnishes Amazon’s brand.
18 56. Reviews and feedback are an important part of a customer’s shopping experience,
19 and customers rely on the accuracy and authenticity of reviews and feedback to inform their
20 shopping decisions. Fake seller feedback harms customers by providing misleading information
21 about a seller, including the seller’s sales volume, responsiveness to customers, shipping times,
22 and overall reliability. When seller feedback is false, inaccurate, or misleading, customers’
23 expectations for quality and performance are not fulfilled. Customers are also harmed when a
24 seller that would not be allowed to sell in the Amazon Store because of a low seller feedback
25
20
A seller may only maintain one Seller Central account for each region in which it sells unless it has a legitimate
26 business need to open a second account and all of its existing accounts are in good standing. “Selling Policies and
Seller Code of Conduct,” https://sellercentral.amazon.com/gp/help/external/G1801?language=en_US.
27 21

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1 rating—reflecting poor customer service—remains active because that seller fraudulently
2 obtained fake positive seller feedback.
3 57. When product reviews and seller feedback are not trustworthy, customers lose
4 confidence in the quality and performance of products and associated ratings in Amazon’s stores,
5 as well as the reliability of Amazon sellers. This loss of confidence damages the goodwill
6 Amazon has built with its customers and harms Amazon’s reputation.
7 58. Similarly, fake reviews and feedback threaten to undermine the trust of honest
8 sellers who sell products in Amazon’s stores. When dishonest sellers use fake reviews and
9 feedback to gain a competitive advantage, they harm honest sellers who play by the rules and
10 earn positive reviews and feedback by offering high-quality products and excellent customer
11 service. In turn, these honest sellers lose faith in the integrity of Amazon’s stores. Multiple
12 sellers have complained to Amazon about fake reviews, with comments like, “It is very
13 disadvantageous to compete with sellers who manipulate the reviews in this way.”
14 59. As a result of reviews abuse perpetuated in Amazon’s stores by bad actors, there
15 has been widespread media and government attention to fake reviews in Amazon’s stores.
16 60. The Wall Street Journal published a story regarding fake reviews in Amazon’s
17 stores on June 13, 2021, titled, “Fake Reviews and Inflated Ratings Are Still a Problem for
18 Amazon.”22 The article focuses on sellers and third parties who encourage reviews abuse against
19 Amazon policies.
20 61. Two days later, Amazon received its first inquiry from Congress, by Senator
21 Roger Wicker, Ranking Member of the Senate Commerce Committee, regarding the work
22 Amazon does to ensure reviews are authentic and inquiring whether reviews abuse in Amazon’s
23 stores detailed in the Wall Street Journal article is widespread.
24
25
26 22
“Fake Reviews and Inflated Ratings Are Still a Problem for Amazon,” Wall Street Journal,
https://www.wsj.com/articles/fake-reviews-and-inflated-ratings-are-still-a-problem-for-amazon-11623587313
27 (accessed June 28, 2022).

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1 62. In addition to Defendants’ fake feedback services, Defendants’ “stealth account”
2 services harm Amazon customers by exposing them to sellers who have lost selling privileges in
3 the Amazon Store due to their prior unscrupulous or illegal conduct or poor customer service.
4 Customers who are exposed to these “stealth account” sellers lose trust in the reliability of
5 Amazon sellers and the Amazon Store. This loss of confidence, in turn, damages the goodwill
6 Amazon has built with its customers and harms Amazon’s reputation.
7 63. In sum, as a result of bad actors’ perpetuation of reviews and feedback abuse and
8 other fraudulent conduct, Amazon and its customers have suffered substantial harm.
9
FIRST CLAIM FOR RELIEF
10 Consumer Protection Act (RCW Ch. 19.86)
11 64. Amazon incorporates by reference the allegations of each and every one of the
12 preceding paragraphs as though fully set forth herein.
13 65. Defendants have engaged in unfair and deceptive acts and practices occurring in
14 trade or commerce in violation of the Washington Consumer Protection Act, RCW Ch. 19.86.
15 66. Defendants’ actions were injurious to the public interest. The acts were committed
16 in the course of Defendants’ business and caused the public dissemination of false seller
17 feedback designed to trick consumers. Defendants’ acts had the capacity to and did, indeed, harm
18 consumers.
19 67. Defendants’ unfair and deceptive business practices have unjustly harmed
20 Amazon and are causing Amazon to suffer damages.
21 68. Amazon is entitled to treble damages and attorneys’ fees, pursuant to RCW
22 19.86.090.
23 69. As a result of such unfair and deceptive acts and practices, Amazon has also
24 suffered irreparable injury and, unless Defendants are enjoined from such unfair competition,
25 will continue to suffer irreparable injury whereby Amazon has no adequate remedy at law.
26
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1
SECOND CLAIM FOR RELIEF
2 Breach of Contract
5 71. By signing up for customer accounts in the Amazon Store and providing feedback
6 to sellers in the Amazon Store (among other activities), Defendants have accepted and are bound
7 by Amazon’s Conditions of Use and Community Guidelines.
8 72. Amazon fully performed all of its obligations under the Conditions of Use and
9 Community Guidelines.
10 73. Defendants have materially breached Amazon’s Conditions of Use and
11 Community Guidelines by, among other actions, (1) creating fake customer accounts for the
12 purpose of evading Amazon’s detection tools and violating Amazon’s policies, (2) requesting
13 and accepting compensation for creating and posting fake feedback in the Amazon Store, (3)
14 posting fake feedback in the Amazon Store that is misleading and injurious to others, and (4)
15 assisting sellers in the creation of “stealth” selling accounts to defraud Amazon and circumvent
16 Amazon’s policies.
17 74. Defendants’ breaches of Amazon’s Conditions of Use and Community Guidelines
18 has resulted in damage to Amazon.
19
THIRD CLAIM FOR RELIEF
20 Intentional Interference with Contractual Relations
23 76. Amazon maintains contracts with each seller of goods in the Amazon Store, as
24 each such seller agreed to the Amazon Services Business Solutions Agreement and other policies
25 maintained on the Amazon seller website.
26 77. Defendants have knowledge of these contracts and the contractual prohibitions
27 against fake and paid feedback.

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1 78. Defendants intended to disrupt and, with malice and through unfair means, did
2 interfere with the performance of these contracts.
3 79. As a result of Defendants’ actions, Amazon has been harmed.
4
FOURTH CLAIM FOR RELIEF
5 Unjust Enrichment/Restitution
8 81. Defendants unjustly received benefits in the form of payments from Amazon
9 sellers in exchange for their deceptive services, at Amazon’s expense through their wrongful
10 conduct, including their interference with Amazon’s business relationships and other unfair
11 business practices. Defendants continue to unjustly retain these benefits at Amazon’s expense. It
12 would be unjust for Defendants to retain any value they obtained as a result of their wrongful
13 conduct.
14 82. Amazon is entitled to the establishment of a constructive trust consisting of the
15 benefit conferred upon Defendants by the revenues derived from their wrongful conduct at
16 Amazon’s expense and all profits derived from that wrongful conduct. Amazon is further entitled
17 to full restitution of all amounts in which Defendants have been unjustly enriched at Amazon’s
18 expense.
19 PRAYER FOR RELIEF
20 WHEREFORE, Amazon respectfully requests judgment as follows:
21 1. That the Court issue permanent and injunctive relief against Defendants and that
22 Defendants, their officers, agents, representatives, servants, employees, attorneys, successors and
23 assigns, and all others in active concert or participation with Defendants be enjoined and ordered
24 to:
25 (a) Cease and desist from selling or facilitating the sale of Amazon feedback;
26
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1 (b) Provide information sufficient to identify each Amazon feedback created
2 in exchange for payment and the accounts and persons who created or paid for such
3 feedback;
4 (c) Cease and desist from offering “stealth account setup” services;
5 (d) Provide information sufficient to identify each “stealth” selling account
6 created in exchange for payment and the accounts and persons who created or paid for
7 such services; and
8 (e) Cease and desist from assisting, aiding, or abetting any other person or
9 business entity in engaging in or performing any of the activities referred to in
10 subparagraph (a) above.
11 2. That the Court enter an Order requiring Defendants to disgorge their profits and
12 declaring that Defendants hold in trust, as constructive trustees for the benefit of Amazon, their
13 illegal profits gained from the sale of fraudulently compensated feedback, and requiring
14 Defendants to provide Amazon with a full and complete accounting of all amounts obtained as a
15 result of Defendants’ illegal activities;
16 3. That the Court enter an Order instructing Defendants, jointly and severally, to pay
17 Amazon’s general, special, actual and statutory damages, including treble damages pursuant to
18 RCW Ch. 19.86;
19 4. That the Court order Defendants to pay Amazon both the cost of this action and
20 attorneys’ fees incurred in prosecuting this action; and
21 5. That the Court grant Amazon such additional and further relief as is just and
22 proper.
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206.622.3150 main · 206.757.7700 fax
1 DATED this 9th day of August, 2022.
2 Davis Wright Tremaine LLP

3 Attorneys for Plaintiffs
4
By /s/ Scott Commerson
5 Scott Commerson, WSBA #58085
865 South Figueroa Street, Suite 2400
6 Los Angeles, CA 90017-2566
Tel: (213) 633-6800
7 Fax: (213) 633-6899
Email: scottcommerson@dwt.com
8
/s/ Eric Franz
9
Eric Franz, WSBA #52755
10 920 5th Avenue, Suite 3300
Seattle, WA 98104-1610
11 Tel: (206) 622-3150
Fax: (206) 757-7700
12 Email: ericfranz@dwt.com
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206.622.3150 main · 206.757.7700 fax
KING COUNTY SUPERIOR COURT
CASE ASSIGNMENT AREA DESIGNATION and CASE INFORMATION COVER SHEET
(CICS)
Pursuant to King County Code 4A.630.060, a faulty document fee of $15 may be assessed to new case
filings missing this sheet.
CASE NUMBER: _______________________________________________________________

(Provided by the Clerk)
CASE CAPTION: Amazon.com, Inc. and Amazon.com Services LLC v. Trey King, Sentinel Solutions LLC, and Does 1‐5
d/b/a auctionsentinel.com, AuctionSentinel Group and Auction Sentinel LLC
(New case: Print name of person starting case vs. name of person or agency you are filing against.)
(When filing into an existing family law case, the case caption remains the same as the original filing.)
Please mark one of the boxes below:

☒ Seattle Area, defined as:
All of King County north of Interstate 90 and including all of the

Interstate 90 right-of-way; all the cities of Seattle, Mercer Island,
Bellevue, Issaquah and North Bend; and all of Vashon and Maury
Islands.
☐ Kent Area, defined as:

All of King County south of Interstate 90 except those
areas included in the Seattle Case Assignment Area.
I certify that this case meets the case assignment criteria, described in King County LCR 82(e).
s/ Scott Commerson 58085 August 9, 2022

Signature of Attorney WSBA Number Date
or
Signature of person who is starting case Date
865 South Figueroa Street, Suite 2400, Los Angeles, CA 90017 2566
Address, City, State, Zip Code of person who is starting case if not represented by attorney
KING COUNTY SUPERIOR COURT
CASE ASSIGNMENT AREA DESIGNATION and CASE INFORMATION COVER SHEET
CIVIL
Please check the category that best describes this case.
APPEAL/REVIEW
☐ Administrative Law Review (ALR 2)
(Petition to the Superior Court for review of ☐ Third Party Collection (COL 2)*
rulings made by state administrative (Complaint involving a third party over
agencies.( e.g. DSHS Child Support, Good to a money dispute where no contract is
Go passes, denial of benefits from involved.)
Employment Security, DSHS)
JUDGMENT
☐ Board of Industrial Insurance Appeals – ☐ Abstract, Judgment, Another County (ABJ 2)
Workers Comp (ALRLI 2)*
(A certified copy of a judgment docket from
(Petition to the Superior Court for review of another Superior Court within the state.)
rulings made by Labor & Industries.)
☐ Confession of Judgment (CFJ 2)*
☐ DOL Revocation (DOL 2)* (The entry of a judgment when a defendant
(Appeal of a DOL revocation Implied consent- admits liability and accepts the amount of
Test refusal ONLY.) RCW 46.20.308(9) agreed-upon damages but does not pay or
perform as agreed upon.)
☐ Subdivision Election Process Review (SER 2)*
(Intent to challenge election process) ☐ Foreign Judgment (from another State or
Country) (FJU 2)
☐ Voter Election Process Law Review (VEP 2)* (Any judgment, decree, or order of a court of
(Complaint for violation of voting rights act) the United States, or of any state or territory,
which is entitled to full faith and credit in this
☐ Petition to Appeal/Amend Ballot Title (BAT 2) state.)
CONTRACT/COMMERCIAL ☐ Tax Warrant or Warrant (TAX 2)

☐ Breach of Contract (COM 2)* (A notice of assessment by a state agency or
(Complaint involving money dispute where a self-insured company creating a
breach of contract is involved.) judgment/lien in the county in which it is
filed.)
☐ Commercial Contract (COM 2)*
(Complaint involving money dispute where a
☐ Transcript of Judgment (TRJ 2)
contract is involved.) (A certified copy of a judgment from a court
of limited jurisdiction (e.g. District or
☐ Commercial Non-Contract (COL 2)* Municipal court) to a Superior Court.)
(Complaint involving money dispute where
PROPERTY RIGHTS
no contract is involved.)
☐ Condemnation/Eminent Domain (CON 2)*
Page 2 of 6
Civil-CICS Revised 04/2022
(Complaint involving governmental taking of ☐ Birth Certificate Change(PBC 2)
private property with payment, but (Petition to amend birth certificate)
not necessarily with consent.)
☐ Foreclosure (FOR 2)*
☐ Bond Justification (PBJ 2)
(Complaint involving termination of
(Bail bond company desiring to transact
ownership rights when a mortgage or tax
surety bail bonds in King County facilities.)
foreclosure is involved, where ownership
is not in question.)
☐ Change of Name (CHN 5)
☐ Land Use Petition (LUP 2)* (Petition for name change, when domestic
violence/anti-harassment issues require
(Petition for an expedited judicial review
confidentiality.)
of a land use decision made by a local
jurisdiction.) RCW 36.70C.040 ☐ Certificate of Rehabilitation (CRR 2)
☐ Property Fairness Act (PFA 2)* (Petition to restore civil and political rights.)
(Complaint involving the regulation of private
property or restraint of land use by a ☐ Certificate of Restoration Opportunity(CRP 2)
government entity brought forth by Title 64.) (Establishes eligibility requirements
for certain professional licenses)
☐ Quiet Title (QTI 2)*
(Complaint involving the ownership, use, ☐ Civil Commitment (sexual predator) (PCC 2)
or disposition of land or real estate other (Petition to detain an individual
than foreclosure.) involuntarily.)
☐ Residential Unlawful Detainer (Eviction) ☐ Notice of Deposit of Surplus Funds (DSF 2)

(UND 2)
(Deposit of extra money from a foreclosure
(Complaint involving the unjustifiable after payment of expenses from sale and
retention of lands or attachments to land, obligation secured by the deed of trust.)
including water and mineral rights.)
☐ Emancipation of Minor (EOM 2)
☐ Non-Residential Unlawful Detainer (Eviction) (Petition by a minor for a declaration
(UND 2) of emancipation.)
(Commercial property eviction.)
☐ Foreign Subpoena (OSS 2)
OTHER COMPLAINT/PETITION
(To subpoena a King County resident
☐ Action to Compel/Confirm Private or entity for an out of state case.)
Binding Arbitration (CAA 2)
(Petition to force or confirm private binding ☐ Foreign Protection Order (FPO 2)
arbitration.) (Registering out of state protection order)
☐ Assurance of Discontinuance (AOD 2) ☐ Frivolous Claim of Lien (FVL 2)

(Filed by Attorney General’s Office to (Petition or Motion requesting a
prevent businesses from engaging in determination that a lien against a mechanic
improper or misleading practices.) or materialman is excessive or unwarranted.)
Page 3 of 6
☐ Application for Health & Safety Inspection (The process of appointment by a court of
(HSI 2) a receiver to take custody of the property,
business, rents and profits of a party to a
lawsuit pending a final decision on
☐ Injunction (INJ 2)* disbursement or an agreement.)
(Complaint/petition to require a person to ☐ Relief from Duty to Register (RDR 2)
do or refrain from doing a particular thing.) (Petition seeking to stop the requirement
to register.)
☐ Interpleader (IPL 2)
(Petition for the deposit of disputed earnest ☐ Restoration of Firearm Rights (RFR 2)
money from real estate, insurance proceeds, (Petition seeking restoration of firearms
and/or other transaction(s).) rights under RCW 9.41.040 and 9.41.047.)
☐ Malicious Harassment (MHA 2)* ☐ School District-Required Action Plan (SDR 2)

(Suit involving damages resulting from (Petition filed requesting court selection of a
malicious harassment.) RCW 9a.36.080 required action plan proposal relating
to school academic performance.)
☐ Non-Judicial Filing (NJF 2)
(See probate section for TEDRA agreements.
☐ Seizure of Property from the Commission
of a Crime-Seattle (SPC 2)*
To file for the record document(s) unrelated
to any other proceeding and where there will (Seizure of personal property which was
be no judicial review.) employed in aiding, abetting, or
commission of a crime, from a defendant
☐ Other Complaint/Petition (MSC 2)* after conviction.)
(Filing a Complaint/Petition for a cause
of action not listed)
☐ Seizure of Property Resulting from a
Crime-Seattle (SPR 2)*
☐ Minor Work Permit (MWP 2) (Seizure of tangible or intangible property
(Petition for a child under 14 years of age which is the direct or indirect result of a
to be employed) crime, from a defendant following criminal
conviction. (e.g., remuneration for, or
☐ Perpetuation of Testimony (PPT contract interest in, a depiction or account
of a crime.))
2) (Action filed under CR 27)
☐ Structured Settlements- Seattle (TSS 2)*
☐ Petition to Remove Restricted Covenant
(RRC 2) (A financial or insurance arrangement
Declaratory judgment action to strike whereby a claimant agrees to resolve a
discriminatory provision of real property personal injury tort claim by receiving
contract. periodic payments on an agreed schedule
rather than as a lump sum.)
☐ Public records Act (PRA 2)*
☐ Vehicle Ownership (PVO 2)*
(Action filed under RCW 42.56)
(Petition to request a judgment awarding
ownership of a vehicle.)
☐ Receivership (RCVR 2)
TORT, ASBESTOS
Page 4 of 6
☐ Personal Injury (ASP 2)* (Complaint involving injury resulting from
other than professional medical treatment.)
(Complaint alleging injury resulting
from asbestos exposure.) ☐ Personal Injury (PIN 2)*
(Complaint involving physical injury not
☐ Wrongful Death (ASW 2)* resulting from professional medical
treatment, and where a motor vehicle is
(Complaint alleging death resulting
not involved.)
from asbestos exposure.)
TORT, MEDICAL MALPRACTICE ☐ Products Liability (TTO 2)*

☐ Hospital (MED 2)* (Complaint involving injury resulting from
a commercial product.)
(Complaint involving injury or death resulting
from a hospital.)
☐ Property Damages (PRP 2)*
☐ Medical Doctor (MED 2)* (Complaint involving damage to real or
personal property excluding motor vehicles.)
from a medical doctor.)
☐ Property Damages-Gang (PRG 2)*
☐ Other Health care Professional (MED 2)* (Complaint to recover damages to property
related to gang activity.)
from a health care professional other than a
medical doctor.) ☒ Tort, Other (TTO 2)*
(Any other petition not specified by
TORT, MOTOR VEHICLE other codes.)
☐ Death (TMV 2)*
(Complaint involving death resulting from
☐ Wrongful Death (WDE 2)*
an incident involving a motor vehicle.) (Complaint involving death resulting from
other than professional medical treatment.)
☐ Non-Death Injuries (TMV 2)*
(Complaint involving non-death injuries WRIT
resulting from an incident involving a ☐ Habeas Corpus (WHC 2)
motor vehicle.) (Petition for a writ to bring a party
before the court.)
☐ Property Damages Only (TMV 2)*
(Complaint involving only property damages ☐ Mandamus (WRM 2)**
resulting from an incident involving a motor (Petition for writ commanding performance
vehicle.) of a particular act or duty.)
☐ Victims Vehicle Theft (VVT 2)* ☐ Review (WRV 2)**

(Complaint filed by a victim of car theft (Petition for review of the record or decision
to recover damages.) RCW 9A.56.078 of a case pending in the lower court; does
not include lower court appeals or
TORT, NON-MOTOR VEHICLE administrative law reviews.)
☐ Other Malpractice (MAL 2)*
Page 5 of 6
⃰ The filing party will be given an appropriate case schedule at time of filing. **
Case schedule will be issued after hearing and findings.
Page 6 of 6

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Auction Sentinel 22-2-12548 9

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1 FILED

2022 AUG 09 09:00 AM

7 SUPERIOR COURT OF THE STATE OF WASHINGTON

9 AMAZON.COM, INC., a Delaware corporation;

20 Plaintiffs Amazon.com, Inc. and Amazon.com Services LLC (collectively, “Amazon”)

23 Sentinel”), for injunctive relief and damages as follows:

3 and tarnish Amazon’s brand.

8 terms of reliability, quality, and overall order experience.

23 well as for the profit of dishonest sellers.

27 things, providing payment or incentives for reviews or feedback.

3 number of packages for so-called “verified feedback” at different price points:

24 fake customer name.

Davis Wright Tremaine LLP

3 positive feedback in exchange for payment from unscrupulous sellers.

8 customer accounts to post fake seller feedback.

Davis Wright Tremaine LLP

7 all of which violate Amazon policies:10

18 Protection Act (RCW Ch. 19.86), and Washington common law.

19 II. JURISDICTION AND VENUE

22 and directed to Washington. Defendants affirmatively undertook to manipulate seller feedback in

Davis Wright Tremaine LLP

3 caused Amazon substantial injury in Washington.

7 feedback in the Amazon Store, among other activities.

8 19. Venue is proper in this Court pursuant to RCW §§ 4.12.010–.025 in that a

12 Defendants consented to jurisdiction in this Court as set forth in Paragraph 18.

13 III. THE PARTIES

20 owner and operator of AuctionSentinel.com. On information and belief, King is a resident of

22 22. Defendant Sentinel Solutions LLC is a limited liability company organized in

11 Amazon’s injuries as herein alleged were proximately caused by said Defendants.

12 IV. AMAZON’S PRODUCT REVIEW AND SELLER FEEDBACK SYSTEMS

15 authentic opinions about products—positive or negative. As long as Amazon’s customers abide

19 information relevant to a product can inform its customers’ buying decisions.

Davis Wright Tremaine LLP

21 seller’s public profile page.

2 to reflect recent and historical sales of nearly every product sold.

9 including suspension of seller-fulfilled orders. Accordingly, by creating fake positive feedback

11 thereby helps them evade consequences for poor customer service.

18 likelihood a seller will be selected for this perk.

19 V. BUYER AND SELLER POLICIES AGAINST FAKE REVIEWS AND FAKE

4 contractual relationship with Amazon.

7 38. Furthermore, any person who uses Amazon’s “community features”—which

10 39. Amazon’s Community Guidelines further prohibit:

Davis Wright Tremaine LLP

2 providing or removing feedback or reviews” and “[r]eview[ing] your own products or a

6 reviews and feedback.

7 44. Unfortunately, at times, unscrupulous sellers try to gain unfair competitive

13 seriously. When it detects potentially abusive or otherwise objectionable reviews or feedback,

19 contravention of Amazon’s policies and the law.

20 VI. DEFENDANTS’ DECEITFUL ACTS

23 seller feedback to Amazon sellers.

Davis Wright Tremaine LLP

2 manipulate their ratings.

Davis Wright Tremaine LLP

8 work flawlessly so amazon can not [sic] link you.”21

10 contractual relationships with sellers and with reviewers.

15 VII. REPUTATIONAL HARM TO AMAZON AND HARM TO THE PUBLIC

Davis Wright Tremaine LLP

2 obtained fake positive seller feedback.

23 stores detailed in the Wall Street Journal article is widespread.

Davis Wright Tremaine LLP

12 preceding paragraphs as though fully set forth herein.

20 Amazon and are causing Amazon to suffer damages.

4 preceding paragraphs as though fully set forth herein.

7 by Amazon’s Conditions of Use and Community Guidelines.